TERMS AND CONDITIONS OF USE

This website, accessible at www.cogweb.com is registered in the name of NEUROINOVA, LDA., with registered office at Avenida Sacadura Cabral, 1694, 4410-463 Arcozelo, Vila Nova de Gaia, tax identification number 509 678 092 and contact +351 911 194 909, hereinafter referred to as NEUROINOVA, and is operated by it. It provides information and allows access to specialized cognitive training services aimed at individuals and legal entities. Access to and use of the website is subject to the terms and conditions described below and implies prior and unreserved acceptance of them.

1. INTELLECTUAL PROPERTY AND OTHER RIGHTS

All content, texts, images and sounds, as well as logos, names, brands and distinctive signs on the website are protected by intellectual property rights and/or others that are the exclusive property of NEUROINOVA or are licensed to it. The use or reproduction, in any form, of the website's contents is expressly prohibited without prior written authorization from NEUROINOVA.

2. QUALITY OF INFORMATION ON THE WEBSITE

The information accessible on the website was produced and/or selected by NEUROINOVA with the required care, considering the content of the information and who it is intended for. However, NEUROINOVA does not guarantee that all information provided is free from errors – human or computer – such as inaccuracies, omissions, changes, interruptions, data loss, delays or other defects. The User accepts that they should not base or make decisions or perform actions based on any information or service available on the website without prior verification or critical analysis. Furthermore, despite the technical and security measures implemented, NEUROINOVA does not guarantee that all files are free from corruption.

3. GENERAL CONDITIONS

The use of this Website implies full and unreserved acceptance of all provisions included in these Terms and Conditions of Use and Privacy Policy.
By using the services available through this website, the User tacitly accepts the Terms and Conditions and Privacy Policy in force.
Violation of any of the conditions established in the Terms and Conditions of Use and Privacy Policy gives the NEUROINOVA has the right to close the offending user's Personal Area and prevent him or her from using the service.

4. USE OF THE WEBSITE OR SERVICE

The COGWEB^® website has associated cognitive training services. In order to use all the functionalities of the services, the User will have to register with COGWEB^® providing certain personal data for this purpose.
The User undertakes to immediately inform the COGWEB^® team if you become aware that the confidentiality of your password has been compromised, NEUROINOVA cannot be held responsible for any loss or damage resulting from improper access by third parties to the user's Personal Area.
Sharing access data to a Personal Area between different users is not permitted. Each user must use unique and non-transferable access data.
In addition to these Terms and Conditions of Use and Privacy Policy, your use of links to other websites through the COGWEB website^® may be subject to additional terms and conditions. If applicable, be sure to read such additional terms and conditions before using the websites and/or purchasing the services and products available there.

5. RESPONSIBILITY

NEUROINOVA will not be responsible for the incorrect use of its services, nor for losses, damages or losses caused by its misuse. Nor will it be responsible for any type of damage, loss or loss suffered by the user or third parties due to the use of the internet or acts of God or force majeure.

6. TERMINATION

The User accepts that NEUROINOVA may suspend access to services available on the website for various reasons, including non-payment, violation of intellectual property rights, breach of confidentiality, violation of these terms and conditions of access and use, decision of any administrative or judicial authority under the terms of the law, and NEUROINOVA will not be responsible for the loss of access to the services available on the website.

7. APPLICABLE LEGISLATION AND JURISDICTION

These “Terms and Conditions of Use and Privacy Policy” were executed in accordance with the applicable legislation on the matter, in particular with the General Regulation on Data Protection – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/) and theDecree- Law no. 7/2004 of 7 January (which transposed directive no. 2000/31/EC, of the European Parliament and the Council, of 8 June 2000) and may be reviewed, modified at at any time and adapt to any changes in current legislation. In this case, the new content will be immediately applicable, as long as it is published on the website, remaining accessible to its users. All conflicts that may arise as a result of the use of this website will be resolved in accordance with the legislation in force in Portugal, submitting to the jurisdiction and competence of the courts of the district of Porto, expressly renouncing any other forum or jurisdiction.

8. FINAL PROVISIONS

NEUROINOVA reserves the right at any time, without the need for prior notice, to change, add, update, totally or partially eliminate or revise these “Terms and Conditions of Use and Privacy Policy”, with immediate effect on from the date of publication on the website. The User must periodically consult the page where they are located to confirm whether updates or changes have been made.

---

¹ Call to Portuguese national mobile network. COGWEB Team^®

PRIVACY POLICY

Personal information and data entered within the scope of the registration necessary for the provision of the various services by COGWEB^® will be treated in accordance with Directive 95/46/EC - General Data Protection Regulation, current national legislation and with the confidentiality obligations to which all NEUROINOVA employees are bound.

1. RESPONSIBLE FOR DATA PROCESSING

The responsibility for processing data lies with NEUROINOVA, which is available to provide any information/clarification regarding the processing of personal data, via email: rgpd@neuroinova.com.

2. REGISTRATION OF PERSONAL DATA

Due to the nature and objectives of the services provided, the user is required to register with COGWEB^®, which involves providing information that may be considered personal (identification, contacts and some clinical information ). The data collected is the exclusive property of NEUROINOVA and is intended for the operation of the COGWEB^® system, user characterization, quality control and anonymized statistical analyzes necessary to improve the performance of the aforementioned system, and in the context of clinical research projects. All clinical data collected by the system will be provided voluntarily and will be preceded by informed consent from the user. You are responsible for all content, information and data that you register or transmit through the website, and you agree to evaluate and assume all risks associated with their transmission. The User must register or transmit true, correct and complete information and always keep it updated. NEUROINOVA guarantees that no personal identification data will be provided to third parties without the prior consent of the holder, except in cases of legal imposition or court order. All services always comply with the provisions of the Personal Data Protection Law – Law No. 58/2019 of 8 August.

3. TYPES OF DATA THAT MAY BE COLLECTED

For the use of COGWEB^® and/or services provided, the following data may be collected and stored:

• Personal information: include name, date of birth, gender, education, demographic data, consents and contacts;
• Clinical and health data: include health risk factors, cognitive complaints, diagnosed pathologies, prescribed medication, among others;
• Performance data: during cognitive training sessions, user results are recorded, which include adherence and intensity data, overall performance and results by function and exercise.

4. LEGAL BASIS FOR THE USE OF PERSONAL DATA

The use of personal data must be justified under at least one of the legal bases defined in the General Data Protection Regulation.
The personal data recorded and processed by NEUROINOVA are essential for the fulfillment of the services presented on the website and the registration of personal data is not carried out without the prior consent of the data subject.
The personal data registered will have the following purposes: communication actions, evaluation and establishment of potential commercial relationships, management of commercial relationships, cognitive training and compliance with legal obligations.

5. STORAGE AND SECURITY OF PERSONAL DATA PROCESSING

Your data is processed in compliance with legislation on the protection of personal data. To protect the confidentiality of users' personal data and reduce the possibility of loss, destruction, alteration or any type of illicit use, NEUROINOVA uses physical measures, security techniques and specific organizational strategies. However, despite all the security measures implemented, the user recognizes that the transmission of their data occurs via the internet, and it is not possible for NEUROINOVA to guarantee the absolute security of their circulation, and therefore recognizes the possibility, even if reduced, of that your data can be seen and used by unauthorized third parties. The user also acknowledges that there is the possibility of data loss due to failures in storage, servers, IT, network disruptions or other telecommunications service providers, and NEUROINOVA cannot be held responsible.
Without prejudice to the security measures adopted, NEUROINOVA recommends that the data subject take all precautions to protect their personal data as an Internet user, namely, changing their access password regularly, using an up-to-date computer and browser and ensuring authenticity of the websites you visit on the internet.
Due to the exercise of their functions, everyone who has access to personal data is bound by professional secrecy and/or confidentiality obligations.
All clinical data are anonymized whenever their statistical treatment is carried out. In this context, de-identified information may also be used in clinical research activities.

6. DATA SUBJECT’S RIGHTS

The data subject has the following rights:

• Right to obtain information about the processing of personal data: the data subject has the right to obtain confirmation that their personal data is being processed, the purposes of the processing and to have access to the data; the data is accessible to the professional responsible for cognitive training through COGWEB^® and, with the holder's prior consent, may be communicated to other professionals or family members accompanying the user;
• Right of access to data: consists of the right to access data at any time and can be done by logging into the COGWEB^® system to consult the information;
• Right to change/rectify data: the right to access and rectify any data that directly concerns you is guaranteed, under the terms of the law. The user has access to their personal data through the Account area of the COGWEB^® system and can consult, update or rectify them at any time;
• Right to be forgotten: the data subject has the right to request that their personal data be forgotten, as long as there is no valid justification for their conservation;
• Right to withdraw consent to the processing of personal data: data processing depends on the authorization of the data subject, through consent. The holder has the right to withdraw their consent whenever they wish, without compromising the lawfulness of the processing carried out based on the consent previously given;
• Right to limit data processing: which consists of limiting the use of data for a period of time, which cannot be communicated, transferred or deleted;
• Right to data portability: which consists of the right to receive, from the data controller, your personal data in a structured format, which allows its transmission to third parties;
• Right to notify the National Data Protection Commission: in case of suspected violation of the General Data Protection Regulation.

You can also request more information at any time via rgpd@neuroinova.com.

Note: the right to access data, the right to change/rectify data, the right to be forgotten and the right to data portability data are not applicable if the information is anonymized as it is not possible for the person responsible for processing the data to identify the data subject. The information may be anonymized at the request of the data subject or if the purposes for which the data is being processed do not require or no longer require the identification of the data subject by the data controller.

7. DATA STORAGE PERIOD

The personal data of COGWEB^® users are processed in strict compliance with applicable legislation. The data is stored in specific databases for this purpose and will be kept throughout the life of the product and up to 10 years after the last use of the product.
In the case of clinical research projects, it may be analyzed with the promoter /principal investigator of the project the possibility of there being a different deadline for the conservation of data or its anonymization.

8. SUPPORT FOR THE EXERCISE OF RIGHTS BY DATA SUBJECTS

The data subject may request the exercise of their rights, ask questions or submit complaints related to the use of their personal data in writing, free of charge, via email at rgpd@neuroinova.com. The response must be sent within a maximum period of 30 days.
You have the right to lodge a complaint with the National Data Protection Commission (CNPD).

9. LINKS TO OTHER WEBSITES

This website may contain links to other websites operated by third parties. NEUROINOVA cannot control or be responsible for the privacy practices and content of third parties. If you choose to access any of these websites, it is recommended that you read their respective privacy policies to understand how these third parties collect and process your personal data.

10. CHANGES TO THE PRIVACY POLICY

NEUROINOVA may change this Privacy Policy at any time. These changes will be published on the website www.cogweb.com.

---

COGWEB Team^®

COOKIES

The cookies used by COGWEB^® are strictly necessary and allow navigation on the website and the use of its applications, as well as access to secure areas of the website. Without these cookies, the Service subscribed by the Customer cannot be provided.

1. WHAT ARE THEY?

Cookies are small text files with relevant information that your access device loads (computer, cell phone/smartphone or tablet), through the internet browser (browser), when a website is visited by the user. The use of cookies will help the website to recognize the user's device the next time they visit it, but will also often be essential for the website to function properly. The cookies used by COGWEB^® do not collect personal information that allows the user to be identified, they only process and store generic information essential to the proper functioning of the website.

2. FEATURES

Cookies can have different purposes: there are technical cookies (for language settings), session cookies (temporary) and tracking cookies (cookies that record user behavior on the website to offer a better experience). Cookies can be installed by the server of the website visited or by a partner with which this website collaborates. The website server can only read cookies that it has installed itself. It does not have access to other information on the user's computer or mobile device.
In general, cookies are used to improve the user's browsing experience, increasing the speed and efficiency of response. They eliminate the need to repeatedly enter the same information and help determine whether the advertising messages that the user sees are relevant and fit their interests.
The cookies used observe the principles of anonymity and confidentiality and have the sole purpose of recognizing the user, and will not be used under any circumstances to collect information that identifies the user, nor for direct marketing purposes.

3. BLOCK USE OF COOKIES

At any time, the user can, through their internet browser, decide to be notified about the receipt of cookies, as well as block their entry into their system. It is worth highlighting the fact that refusing to use cookies on the website may result in the user being unable to access some of its areas.

---

COGWEB Team^®