Privacy Policy

Effective date: 13/08/2025
 

ViewMind Inc., ViewMind Sarl, and ViewMind S.A. (“ViewMind”, “we”, “us”, or “our”) are committed to safeguarding the privacy of our users. This Privacy Policy outlines how we collect, use, disclose, and protect your personal data when interacting with our website or using ViewMind’s products, software, and services.

By accessing our website or using our products and services, you consent to the practices described in this Privacy Policy. Unless otherwise defined, terms used in this Privacy Policy have the same meaning as in our Terms of Use.

Scope

This Privacy Policy applies to:

  • Website: Covers personal data collected through our public-facing websites, portals, or communication channels.
  • Product: Includes personal data collected during the use of ViewMind’s software, hardware, and associated services in a research, clinical, or healthcare setting. 

Definitions

  • Service: Any ViewMind software, product, or service provided to users.
  • Personal Data: Any information that identifies an individual directly or indirectly.
  • Usage Data: Data collected automatically, generated during the use of our website or product.
  • Cookies: Small data files placed on devices to enhance user experience, and track preferences.
  • Encryption: A method of securing data by converting it into coded formats, making it inaccessible to unauthorized individuals.
  • Tracking Technologies: Tools used to collect information about user behavior on a website or application, including cookies, pixels, and web beacons.
  • Third Parties: External entities, not part of ViewMind, that may interact with your personal data through the use of our services, such as analytics providers or social media platforms.
  • De-Identified Data: Information that has been modified to remove personal identifiers, ensuring it cannot reasonably be used to identify an individual.
  • Anonymized Data: Data that has been processed to irreversibly prevent re-identification of the individual it pertains to.
  • You: The individual using ViewMind’s website or product, or the organization or entity represented by such an individual.

Website Section

Data Collected via the Website

  1. Personal Data: 
    • Name, biological sex, date of birth, years of education, and location where the Service is used.
      Subject IDs (Unique, encrypted alphanumeric identifiers assigned by the user organization. These identifiers do not correspond to any personal identification document, such as passport, social security number, or any other official identifier).
  2. Usage Data:
    • IP addresses, browser type, pages visited, geolocation information, and other analytics data.
  3. Cookies and Tracking Technologies:
    • Includes cookies, web beacons, pixels, and other tracking technologies to enhance user experience and analyze website performance.

Use of Website Data

We use data collected from the website for:

  • Communication (e.g., responding to inquiries or sending updates).
  • Website analytics to improve user experience.

Product Section

Data Collected via ViewMind Products

  1. Personal Data: 
    • Name, biological sex, date of birth, years of education, and location where the Service is used.
      Subject IDs (Unique, encrypted alphanumeric identifiers assigned by the user organization. These identifiers do not correspond to any personal identification document, such as a passport, social security number, or any other official identifier).
  2. Usage Data:
    • Eye-tracking data, such as X & Y eye position, timestamps, and pupil diameter.
    • System-generated information like device type, software version, and unique identifiers.

Use of Product Data

We collect product data for:

  • Assessing cognitive performance.
  • Providing secure storage and analysis for research and clinical use.
  • Enhancing product functionality.

 

Disclaimer: ViewMind’s product does not provide a clinical diagnosis and is intended for cognitive performance measurement. Decisions based on data should be made in consultation with qualified professionals.

Aggregated Information

We may aggregate, de-identify, and/or anonymize any information collected such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-Personal Information) for any purpose, including without limitation, for research and marketing purposes, and may also share such data with our affiliates and third parties, including advertisers, promotional partners, and others. 

Links to Third-Party Websites and Social Media

For your convenience, the Website and this Privacy Policy may contain links to other third-party websites and social media sites such as Facebook, Instagram, X and LinkedIn. ViewMind does not control or take responsibility for the privacy practices, advertising, products, services, or content of such other websites. Please review the privacy policies and terms of service of these third parties for details about how your information is processed and what steps you can take to limit or avoid data sharing.  

 

To limit the sharing of information, you can log out of your social media accounts before visiting our Website or adjust the privacy settings on those platforms to restrict data sharing

 

Additionally, our Website may include social media plugins. If you visit our Website while logged into a social networking account, certain personally identifiable information about your browsing activity may be automatically shared with the social media platform operating that account. For further details on what information may be transferred and how you can manage this, please refer to the terms of service and privacy policies of the respective third-party platforms.

General Provisions

Data Security & Privacy

  • Compliance: All data is processed in compliance with GDPR, HIPAA, and applicable data protection laws.
  • Encryption: Personal and usage data are protected using advanced encryption protocols during both transmission (“in transit”) and storage (“at rest”), ensuring data confidentiality and security.
  • Data Anonymization:  Subject IDs are anonymized and encrypted to prevent direct or indirect identification of individuals through ViewMind’s systems. These identifiers are not linked to any official identification documents through ViewMind’s systems.

Retention of Data

  • Website Data: Retained as long as necessary for communication or marketing purposes, unless otherwise requested.
  • Product Data: Retained for the duration of clinical/research agreements and as required by applicable regulations.

Data Breach Notification

In the event of a data breach that may affect You, we will notify You without undue delay of any loss, misuse, or alteration of personal information. We will also notify the relevant regulatory authorities within 72 hours of discovering the breach.

Transfer of Data

We do not sell, trade, or otherwise transfer your personally identifiable information to outside parties. However, your information may be transferred to, stored, or otherwise processed in a destination outside of your jurisdiction where data protection laws may differ from those in your region.

 

For users in the European Union (EU), we comply with the General Data Protection Regulation (GDPR) and take steps to ensure that any data transferred outside the European Economic Area (EEA) is subject to appropriate safeguards. These safeguards include contractual agreements or adherence to frameworks such as the EU-U.S. Data Privacy Framework.

 

By entering into a Service Agreement with ViewMind, you acknowledge and consent to the transfer, storage, and processing of your data outside the EEA when necessary to provide our services. All data transfers are conducted in compliance with applicable data protection laws, and we ensure adequate security measures are in place to protect your information.

International Transfer of Personal Information

ViewMind may share customer information within our family of companies to support our global operations and provide you with information about our products and services. To facilitate these operations, personal information may be transferred from your home country to other ViewMind locations worldwide.

 

We strive to ensure that all data transfers comply with applicable data protection laws. For transfers to countries that may not offer an equivalent level of data protection as determined by the European Commission, we are committed to implementing appropriate safeguards to protect your information, such as contractual agreements or other lawful mechanisms.

Cookies and Tracking Technologies

We use cookies and tracking technologies to:

  • Assess website performance and improve functionality.
  • Provide personalized content and advertisements (with user consent).
  • Track user preferences to enhance user experience.

 

You can manage cookies and tracking preferences through your browser settings. Please note that disabling certain cookies may impact website functionality. For detailed instructions on managing cookies, refer to your browser’s help section

Do Not Track (DNT) and Global Privacy Control (GPC)

  • We currently do not respond to DNT signals due to the lack of a universal standard.
  • We honor GPC signals for U.S.-based users as an opt-out of the sale or sharing of personal data.

Children's Privacy

Our services are not directed to individuals under the age of 18. If we discover that we have collected information from a minor without the consent of their legal guardian, we will immediately delete such information and notify the guardian of the incident.

Your Rights

As a user, you have the right to:

  • Access and correction: Request access to or correction of your personal data.
  • Erasure: Request deletion of your personal data, subject to legal obligations.
  • Restriction: Request restrictions on the processing of your personal data.
  • Withdraw Consent: Opt-out of marketing communications or withdraw consent for data collection.

 

To exercise your rights, you can contact us via email at [email protected]. Once we receive your request, we will confirm receipt and proceed to verify your identity before processing it. The estimated response time is 30 days.

Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in legal requirements or operational practices. Updates will be posted on our website with the effective date.

Contact Information

For questions or concerns, reach us at: