NeurGear Inc. is committed to protecting the privacy and data of its customers.  We at NeurGear Inc
(“NeurGear,” “we,” or “us”) recognize the importance of appropriate policies and procedures to
protect personal information we collect and the privacy of our website users.  We have, therefore,
created this notice to describe our privacy practices and procedures relating to the use of our
website and the personal information we collect.
This notice describes how we collect and use information we receive from visitors to our
website, (“Site”), and registered users.  This policy applies only to information
collected on the Site and not to other information NeurGear may collect from you through other
ways, whether online or offline.  Please review this Privacy Policy carefully to understand how we
collect information, how we use the information, with whom we share it, and the choices available
regarding our use of the information.  If you do not agree with our policies and practices, you may
choose not to use our Site.  By accessing and using the Site, you accept and agree to this Privacy
Our Site may provide links to other websites for your convenience and information.  These websites
may operate independently from us.  As a result, this notice does not apply to other websites linking
to the Site or websites to which the Site links.  Linked websites may have their own privacy policies,
which we strongly suggest you review if you visit any linked websites.  We are not responsible for
those websites’ content, any use of those websites, or the privacy practices of those websites.
This privacy notice is an integral part of NeurGear’s Terms of Use and use of the Site and Content
provided by NeurGear are subject to the terms and conditions that appear in the Terms of Use.

  1. About NeurGear.  NeurGear is the developer and seller of portable consumer products that are
    designed to provide vagus nerve stimulation, including the ZenBud, which may allow the user to
    experience less stress and anxiety, enhanced focus, improved sleep, and brighter mood. 
  2. Our Contact Information.  The Site is operated by NeurGear inc.  If you would like to discuss this
    privacy notice, or provide us with feedback, questions, or concerns about our privacy practices,
    please contact our privacy team at 
  3. Our Collection of Personal Information on our website.
    a. “Website user personal information,” or “personal information” for short, refers to information we
    collect in connection with our website or your communications with us.
    b. We collect personal information from users of our Site via web forms and other communications. 
    We will collect the personal information of website visitors who complete a web form to submit a
    registration to receive marketing information.  Using this form, we collect names and email
    addresses.  On our website, we also encourage website visitors to send us email inquiries to learn
    about our products.  If you send us an email using the web form on the Site, we will collect your
    name, email address, phone number, and whatever personal information you include in your email.  If
    a communication prompts follow-up, we may collect additional information that you provide to us.
    c. In addition, we may use various technologies to observe how users use our Site.  For instance, we
    may use “cookies” to recognize return visitors and to understand how users use our websites. 
    Cookies are small files stored in your computer or mobile devices.  When used, they help us improve
    your user experience when using our Site, for instance by showing you information relevant to your
    interests.  We may use cookies and other behavioral indications to track how you use our Site in
    order to understand what information is of most interest to you.  
    d. Most browsers allow you to control cookies, including whether to accept and/or remove them. 
    You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies
    with your browser.  If you decide not to accept cookies, however, some of the Site’s features or
    functions may not be available to you.
    e. Google’s ability to use and share information collected by Google Analytics is restricted by the
    Google Analytics Terms of Service, available at, 
    and the Google Privacy Policy, available at  You may learn
    more about how Google collects and processes data specifically in connection with Google
    Analytics at  You may prevent your data from
    being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser
    Add-on, available at  

f. We also review information logged by our web servers to understand our Site visitors better.  It is
very common for websites to collect these kinds of logs.  For example, we collect information such
as your Internet Protocol address, your location, domain name, the type of web browser and
operating system you are using, the pages on our websites that you view, when you visit, and how
long you view each page visited.

  1. Our Collection of Personal Information on our Mobile Application (“App”)
    a. The App may use analytical tools such as “Google Analytics” to collect information about use of
    the App (“Analytics Tools”).  These Analytics Tools collect information, such as how often users use
    the App and what App features they use. We use the information we get from these Analytics Tools
    to maintain and improve the App and our products.  We do not combine the information collected
    through the use of Analytics Tools with personally identifiable information.  Analytics Tools typically
    utilize “cookies.”
  2. How We Use Personal Information.
    a. We will use personal information collected as described in Section 3 above solely with the
    objective of communicating with you, including communications relating to NeurGear’s products. 
    For other purposes, we will obtain your consent. 
    b. Specifically, we may use personal information for the following general purposes: (i) identification;
    (ii) establishment and maintenance of our relationship with you; (iii) to provide you with products
    and services; (iv) to respond to your requests and inquiries; (v) to fulfill your requests to register for
    and to deliver updates, publications, and other information; (vi) marketing purposes, such as
    understanding your activity, browsing, and usage information concerning our Site and/or your
    demographic information that you may have voluntarily provided to us, in order to better tailor our
    marketing activities; (vii) providing information to third-party administrators or other providers
    necessary to optimize our services and operation of our website; (viii) maintaining business records
    for reasonable periods, and generally managing and administering our business; (ix) meeting legal,
    regulatory, insurance, security, and processing requirements and court or administrative orders; and
    (x) otherwise with consent or as permitted or required by law.  We may keep any and all of your
    personal information on hand for as long as permitted by law for any and all of the purposes
    described in this Section.

c. In addition, we may use information collected online through cookies or other automated means
for purposes such as (i) customizing our users’ visits to our Site, (ii) delivering content tailored to our
users’ interests and the way our users browse our Site, and (iii) managing our business.  We may
also use this information to help diagnose technical and service problems, administer our Site,
identify users of our Site, and gather demographic information about our users to better meet the
needs of our users.

  1. Sharing and Transfers of Personal Information.
    a. Personal information may be disclosed to: (a) our employees, agents, representatives, advisors,
    affiliates, and independent contractors, in connection with providing products or their performance
    of services for or on behalf of our customers; and (b) service providers who help us with our
    business operations, sales and marketing, information technology, or professional services.
    b. We do not sell or rent personal information to anyone.  Nonetheless, we may sell, transfer, or
    otherwise share some or all of NeurGear’s assets in connection with a merger, acquisition,
    reorganization, or sale of assets of our business, or in the event of bankruptcy.  These assets may
    include personal information collected by NeurGear as described above.
    c. Also, we may disclose personal information when required by a subpoena, court order, search
    warrant, other legal process, requests by law enforcement agencies, or applicable law.  Moreover, we
    may disclose personal information to the extent necessary to maintain the security of our Site,
    products, or services, resolve disputes, or investigate possible misconduct.
    d. Safeguarding Personal Information.  We will take reasonable measures to ensure that your
    personal information collected, used, disclosed, or otherwise processed for us or on our behalf is
    protected and not used or disclosed for purposes other than as directed by NeurGear.  Specifically,
    NeurGear is committed to maintaining reasonable and appropriate administrative, physical, and
    technical safeguards to:
    (i) Provide assurances of the integrity and confidentiality of personal information collected as
    described above;
    (ii) Protect personal information against any reasonably anticipated threats or hazards to the
    security or integrity of personal information, and unauthorized uses or disclosures of personal
    information; and

(iii) Maintain compliance with the legal framework of requirements for the privacy and security of
personal information.
e. Unfortunately, the transmission of information via the internet is not completely secure. Although
we do our best to protect your information, we cannot guarantee that information may not be
accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or
administrative safeguards.  Any transmission of information is at your own risk.  You agree that
NeurGear is not liable for the unauthorized release of your information, unless such release was the
result of gross negligence or willful misconduct on the part of NeurGear.

  1. Location
    a. Our Site is hosted in the United States of America.  We make no representations that the
    information on our Site is appropriate or available for use in any location outside of the United
    States.  If you are a resident of another country or are accessing the Site from outside of the United
    States, please note that you are transferring your data to the United States of America which does
    not have the same data protection laws as the European Union and other regions.
  2. Children’s Privacy
    a. Our Site is not intended for children under thirteen (13) years of age. No one under age thirteen
    (13) may provide any information on our Site.  Any person who provides their personal information to
    NeurGear through the Site represents that they are thirteen (13) years of age or older. 
    b. We do not knowingly collect, maintain, or use Personal Information, as defined by the Federal
    Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) Rule, from children under 13
    years of age, and no part of the Service is directed to children under the age of 13.  If you learn that
    your child has provided us with Personal Information without your consent, then you may alert us at  If we learn that we have collected any Personal Information from children
    under 13, then we will promptly take steps to delete such information and terminate the child’s
  3. Access to Personal Information and Amendments.  If you would like to access your personal
    information we may have, please contact us at We may not accommodate a
    request to change information if we believe the change would violate any law or legal requirement or
    cause the information to be incorrect.
  4. Your California Privacy Rights.  Residents of California have the right to request a disclosure
    describing what types of Personal Information we have shared with third parties for their direct
    marketing purposes, and with whom we have shared it, during the preceding calendar year. You may
    request a copy of that disclosure by contacting us at 
  5. Resolving Disputes.  If you have a complaint about our privacy practices, you may submit a
    complaint to us at the above contact information.  Our privacy team will look into your complaint and
    provide a response.  You will need to provide sufficient information for us to evaluate your complaint
    and we may ask you to provide additional information as a condition of evaluating your complaint.
  6. Changes to Privacy Notice.  NeurGear reserves the right to make changes to this privacy notice
    from time to time.  If NeurGear makes a change to this notice, it will post a new copy of the privacy
    notice on the Site.  All changes are effective immediately upon posting; the date the Privacy Policy
    was last revised is identified at the top of the page. We encourage you to periodically review this
    Privacy Policy to stay informed about how we are protecting the information we collect.  Your
    continued use of the Site and content received from NeurGear after such notification indicates your
    continued agreement to the privacy notice as amended.