This Privacy Policy explains how Neuro Group LLC, operating the Neuroptima Performance Lab ("NPL," "Neuroptima," "we," "us," or "our"), collects, uses, discloses, and protects personal information in connection with our website, membership program, bootcamps, 1:1 coaching and clinical consultation bookings, and Discord community (collectively, the "Services"). This Policy should be read together with our Terms and Conditions.

Neuroptima is not a "covered entity" or "business associate" under the Health Insurance Portability and Accountability Act ("HIPAA"), and the health-related information you provide through the Services is generally not protected by HIPAA. An independent clinician you book through the Platform (our Registered Dietitian, licensed psychologist, or chiropractor) may separately owe you obligations under HIPAA or their professional licensing rules with respect to records they create and maintain themselves in their own practice; that is between you and the clinician, and Section 6 explains how our disclosures to Providers work.

2. Information We Collect

2.1 Information You Provide Directly.

Account and registration information: name, email, date of birth (for age verification), Discord username, and, for minors, parent/guardian name and contact information.
Payment information: billing name, address, and payment card or other payment details, collected and processed by our third-party payment processor (Section 6). We do not store full payment card numbers on our own systems.
Health and performance information you choose to log: sleep, meals/nutrition, training and game statistics, mood or stress indicators, and similar entries made in our performance-tracking templates.
Communications: messages you send us, in Discord channels, in intake forms, or during coaching/clinical bookings, including topics discussed and scheduling notes (not clinical treatment notes, which the Practitioner maintains separately per Section 1).
Content you submit: VODs, screenshots, or other materials submitted for coaching or VOD review.
Booking details: session type, date/time, and Provider selected.

2.2 Information Collected Automatically. Standard website and app usage data (IP address, device/browser type, pages visited, referring URL), and cookies/similar technologies as described in Section 9.

2.3 Information From Third Parties. If you sign in via or interact with us through Discord, or if a Coach/Practitioner shares session notes relevant to your continued coaching (e.g., "focus areas" for your next session), we may receive limited information from them as described in Section 6.

3. How We Use Information

We use personal information to: create and administer your account and subscription; process payments and payouts to Providers; schedule and deliver coaching, workshops, and clinical consultations; personalize your tracking templates and content recommendations; operate community features and enforce our Code of Conduct; communicate with you about your account, billing, and program updates; send marketing communications (with the ability to opt out, Section 10); detect fraud and enforce our Terms; comply with legal obligations; and improve the Services.

We do not use your health information to make automated decisions that produce legal or similarly significant effects on you without human involvement.

4. Legal Bases and Sensitive Data

Certain data we collect — including health, fitness, and mental-performance information — is treated as sensitive personal information under state privacy laws, including California's definition of "sensitive personal information" and Washington's definition of "consumer health data." We collect this information only where you choose to provide it (for example, by using a tracking template or booking a clinical consultation), and we describe your rights over this category of data specifically in Sections 12 and 13.

5. Minors' Information

We do not knowingly collect personal information from anyone under 13. Users 13-17 may only use paid Services with a parent or guardian registered on the account per our Terms, and information about a minor Member (including performance and health data logged in tracking templates) is visible to the registering parent/guardian and, where applicable, treated as sensitive information under Section 12.2 (California) and Section 13 (Washington). If we learn we have collected information from a child under 13, we will delete it promptly; parents may contact us at performance@neuroptima.com to request this.

6. How We Share Information

We do not sell your personal information, and we do not sell consumer health data, as those terms are defined under applicable state law.

We share information with:

Coaches and Practitioners, limited to what is necessary for them to deliver a session you booked (your name, relevant intake/tracking data you choose to share, and prior session notes relevant to continuity of coaching).
Service providers who help us operate the Platform, currently including: Discord Inc. (community/chat hosting), Notion Labs, Inc. and/or Google LLC (Google Forms/Workspace) (intake forms and performance-tracking templates), our payment processor, video-conferencing providers for live sessions, and email/SMS communication platforms. These providers process data under their own privacy policies and, where required, under contractual confidentiality and security commitments to us.
Professional advisors and legal authorities where necessary to comply with law, enforce our Terms, or protect the safety of any person (including mandatory reporting related to suspected abuse of a minor).
A successor entity in the event of a merger, financing, or sale of assets, subject to this Policy or a materially similar one.

6.1 Discord Specifically. Our community operates on Discord, a platform independently owned and operated by Discord Inc. Messages, voice activity, and profile information you share in our Discord server are subject to Discord's own Privacy Policy and Terms of Service, and are visible to other Discord users in shared channels, including Coaches and other Members. We do not control Discord's data retention, security practices, or international data transfers. Review Discord's policies directly before sharing sensitive information there.

6.2 Third-Party Tools Generally. Because certain tracking templates and intake processes currently run through general-purpose third-party tools (such as Notion or Google Forms) rather than a purpose-built health platform, those tools' own security and access controls apply to data entered there. We limit access to these tools to authorized staff and Providers who need it to deliver your Services, but we encourage you not to include highly sensitive medical details (such as specific diagnoses) in these general tracking fields; discuss those directly and privately with your Practitioner instead.

7. Data Retention

We retain personal information for as long as your account is active and for a period afterward to be prepared to continue offering services with you should you resume membership, resolve disputes, enforce our agreements, and comply with legal, tax, and accounting requirements. Health and performance data you logged is retained on the same basis unless you exercise a deletion right under Section 12 or 13.

8. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, and we require service providers to maintain appropriate safeguards. No method of transmission or storage is completely secure, and we cannot guarantee absolute security, particularly for data processed through third-party tools as described in Section 6.2.

9. Cookies and Tracking Technologies

We and our service providers use cookies and similar technologies for authentication and analytics. As of the Last Updated date above, we do not have advertising or referral-tracking cookies active on the Platform. We plan to introduce cookie-based tracking (including advertising identifiers) to attribute credits under our Referral Program, described in our Referral Program Terms. Before any advertising or cross-site tracking cookies go live, we will update this Policy, post a cookie consent banner or equivalent notice, and provide the opt-out mechanism described in Section 12 (California) and Section 14 (Other U.S. States). You can control cookies through your browser settings at any time; disabling some cookies may limit Platform functionality.

10. Marketing Communications

If you subscribe to our email list or provide a phone number for SMS updates, we will send you program and promotional communications from Neuroptima and the Performance Lab consistent with your consent. You may opt out of marketing emails using the unsubscribe link in any message, and of SMS by replying STOP, without affecting transactional messages related to your account or bookings.

11. Your General Privacy Choices

You may access, update, or correct your account information through your account settings, request a copy of your data, or request deletion of your account, by contacting performance@neuroptima.com or contacting us securely through private messaging in Discord. We will honor legally required deletion and access requests and may retain limited information as needed for legal, security, or fraud-prevention purposes.

12. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the right to: know the categories and specific pieces of personal information we collect, use, and disclose; delete personal information we hold about you, subject to exceptions; correct inaccurate personal information; know whether we sell or share personal information (we do not sell or share personal information for cross-context behavioral advertising); limit the use of sensitive personal information to purposes permitted by law; and not be discriminated against for exercising these rights.

12.1 Categories Collected (Past 12 Months). Identifiers (name, email, IP address); customer records (billing/payment information); commercial information (purchase/subscription history); internet/network activity; geolocation (approximate, from IP); health information you log in tracking templates or discuss in clinical bookings (sensitive personal information); and, where applicable, the personal information of a minor under 16, which is automatically treated as sensitive personal information under California law.

12.2 Minors Under 16. We do not sell or share the personal information of consumers we know to be under 16 years old.

12.3 How to Exercise Rights. Submit a request to performance@neuroptima.com with the subject line "Privacy Request," or through the "Do Not Sell or Share My Personal Information" link at neuroptima.gg/privacy-choices once advertising cookies described in Section 9 go live. We will verify your identity (or, for a minor's account, the parent/guardian's identity and authority) before fulfilling access or deletion requests, and will respond within the time required by law. You may designate an authorized agent to submit a request on your behalf.

12.4 Notice of Financial Incentive. Our referral program and Founding Member pricing may be considered a financial incentive tied to your use of the Platform. Participation is voluntary, and the value is reasonably related to the value of your continued Membership and referrals; you may withdraw from these programs at any time without losing access to core Services.

13. Washington Consumer Health Data Notice

This section is provided pursuant to Washington's My Health My Data Act and applies to "consumer health data" — information that identifies your physical or mental health status, including data about sleep, nutrition, fitness, and mental/emotional performance that you log through the Services.

13.1 Categories of Consumer Health Data We Collect: self-reported sleep, nutrition, and training data entered in tracking templates; topics and scheduling details of clinical consultations booked with our Registered Dietitian, psychologist, or chiropractor (not the clinical content of those sessions, which the Practitioner maintains independently); and any health-related information you voluntarily share in Discord or intake forms.

13.2 Purpose. We collect this data to personalize coaching and clinical-booking recommendations, track your progress over time, and facilitate your sessions with Providers.

13.3 Sources. Directly from you.

13.4 Categories Shared and With Whom. We share consumer health data with the Coach or Practitioner you are booked with (to deliver the session) and with the service providers listed in Section 6 who host the tools where this data is entered. We do not sell consumer health data, and we do not disclose it for advertising purposes.

13.5 Your Rights. You have the right to confirm whether we are collecting, sharing, or selling your consumer health data; to access it; to withdraw consent to its collection or sharing; and to request deletion, including from our service providers' systems where feasible. Submit requests to performance@neuroptima.com; we will respond within 45 days (extendable by an additional 45 days when reasonably necessary, with notice to you). We do not geofence, or use geofencing to identify or track consumers seeking health care services, around any health care facility.

14. Other U.S. State Privacy Rights

If you reside in Virginia, Colorado, Connecticut, Utah, Oregon, Texas, or another state with a comprehensive consumer privacy law, you may have rights similar to those described in Section 12, including rights to access, correct, delete, and obtain a portable copy of your personal information, and to opt out of targeted advertising, the sale of personal information, or certain profiling. To exercise these rights, contact us using the information in Section 16. We will not discriminate against you for exercising any privacy right.

15. Changes to This Policy

We may update this Policy from time to time. If we make a material change to how we handle health or other sensitive information, we will provide advance notice and, where required by law (including under Washington's My Health My Data Act for new categories or purposes), obtain your affirmative consent before the change takes effect. The "Last Updated" date above reflects the most recent revision.

16. Contact Us

Neuro Group LLC

7205 Hancock Ct Unit 1E, Davenport, IA 52806

Privacy inquiries and general support: performance@neuroptima.com