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NEUROBLOOM, INC.
PRIVACY POLICY

Last Updated: October 19, 2026


1. INTRODUCTION

Neurobloom, Inc. ("Neurobloom," "we," "us," or "our") respects individual privacy and is committed to the responsible collection, use, protection, and management of personal information.

Neurobloom provides AI-assisted, human-reviewed screening and practical support services designed to help individuals better understand patterns associated with reading, attention, executive functioning, neurodevelopmental differences, and related functional challenges.

Our services may be used by individuals, families, coaches, healthcare professionals, educational institutions, employers, and other organizations.

Neurobloom provides screening and informational services. Our assessments and reports do not independently establish medical, psychological, or educational diagnoses and are not substitutes for comprehensive professional evaluations where appropriate.

This Privacy Policy explains how we collect, use, process, disclose, retain, and protect personal information, as well as the rights and choices available to individuals.

It applies to our public websites, digital assessment platforms, screening services, reports, and related communications.

Additional privacy notices, consent requirements, or contractual terms may apply to particular services, organizational relationships, or jurisdictions.


2. INFORMATION WE COLLECT

The information we collect depends on how an individual interacts with Neurobloom and the services provided.

PERSONAL AND CONTACT INFORMATION

We may collect names, email addresses, dates of birth, contact information, and other details necessary to administer assessments, communicate with participants, and deliver reports.

When assessments involve minors, we may also collect information concerning parents, legal guardians, or other appropriately authorized individuals.

ASSESSMENT AND SCREENING INFORMATION

We collect information provided or generated during screening activities, including:

- Responses to assessment questions and questionnaires.
- Reading, spelling, decoding, attention, and related task performance.
- Accuracy, response times, and other performance measurements.
- Audio recordings of spoken responses.
- Screening scores, observations, and performance patterns.
- Reviewer decisions, corrections, and quality-control information.
- Generated reports, interpretations, and practical recommendations.

This information may reveal or suggest characteristics concerning an individual's health, learning, cognition, neurodevelopment, or functional abilities.

Such information may qualify as sensitive personal information, consumer health data, or special-category personal data under applicable privacy laws.

EDUCATIONAL, OCCUPATIONAL, AND FUNCTIONAL INFORMATION

We may collect information concerning educational background, professional responsibilities, workplace environments, learning experiences, functional difficulties, and support needs.

This information helps contextualize screening results and develop recommendations relevant to an individual's circumstances.

DEMOGRAPHIC INFORMATION

We may request demographic information, including gender, race, or ethnicity, for purposes such as fairness analysis, scientific validation, and assessment-quality improvement.

Where designated optional, individuals may decline to provide this information.

Demographic characteristics are not used as direct determinants of an individual's screening score, screening outcome, or support recommendations.

PAYMENT AND TRANSACTION INFORMATION

When assessments or related services are purchased, payment information is processed through authorized payment providers, including Stripe.

Neurobloom may receive billing information, transaction records, payment confirmations, and information necessary for order fulfillment, accounting, customer support, and applicable legal obligations.

WEBSITE AND TECHNICAL INFORMATION

When individuals visit our websites or use our services, certain technical information may be collected, including IP addresses, browser characteristics, device information, operating systems, website interactions, cookies, and diagnostic information.

Our public website uses Wix and its analytics tools for website operation and performance measurement.

Neurobloom's assessment software operates separately from its Wix website.

Website analytics are not intended to collect or analyze private assessment results, screening responses, or recorded assessment audio.


3. SOURCES AND PURPOSES OF INFORMATION PROCESSING

Personal information may be collected directly from participants, parents, legal guardians, customers, or other individuals interacting with Neurobloom.

Information may also be provided by appropriately authorized coaches, clinicians, schools, employers, or other organizations arranging access to our services.

Additional information may be generated through automated assessment processing, scoring, human review, and report preparation.

We use personal information for the following purposes:

ASSESSMENT ADMINISTRATION

Providing assessment access, processing responses, evaluating performance, and supporting screening activities.

HUMAN REVIEW AND REPORTING

Enabling authorized reviewers to evaluate screening information, verify scoring, correct errors, and finalize reports.

PERSONALIZED GUIDANCE

Providing relevant practical recommendations concerning learning, work, everyday functioning, and potential support strategies.

QUALITY ASSURANCE

Monitoring reliability, investigating technical problems, correcting errors, and improving assessment and reporting quality.

CUSTOMER SUPPORT

Responding to inquiries, assisting participants, delivering reports, and resolving operational issues.

PAYMENT ADMINISTRATION

Processing purchases, maintaining transaction records, and fulfilling financial obligations.

SECURITY AND LEGAL COMPLIANCE

Protecting systems, preventing fraud, investigating misuse, responding to security incidents, and complying with applicable laws.

RESEARCH AND IMPROVEMENT

Conducting appropriate scientific validation, fairness analysis, and methodological improvement using de-identified, aggregated, or otherwise lawfully processed information.

COMMUNICATIONS

Sending necessary service information and, where appropriately authorized, promotional communications.

We do not use sensitive screening information for targeted advertising, behavioral advertising, or unrelated commercial profiling.

Information required to administer an assessment may include identifying details, relevant responses, and recorded speech. Without certain required information, we may be unable to provide the requested service. Optional demographic information may be declined.


4. LEGAL BASES FOR PROCESSING

Where applicable privacy laws require an identified legal basis, Neurobloom processes personal information under an appropriate lawful basis for the relevant activity.

Depending on the circumstances, these may include:

CONSENT

Where an individual has provided valid authorization for a specified processing activity.

CONTRACTUAL NECESSITY

Where processing is necessary to provide requested services or fulfill a contract with the individual.

LEGITIMATE INTERESTS

Where processing is necessary for legitimate purposes such as service security, fraud prevention, and operational reliability, provided those interests are not overridden by applicable individual rights.

LEGAL OBLIGATIONS

Where processing is necessary to comply with applicable laws or regulatory requirements.

Where the European Union General Data Protection Regulation (GDPR) or United Kingdom GDPR applies, processing must have an appropriate Article 6 lawful basis.

Processing special-category information, including relevant health or neurodevelopmental information, also requires a separate applicable Article 9 condition.

Where explicit consent is required, that consent must be obtained through an appropriate authorization process.

Neurobloom does not treat acceptance of general service terms as blanket consent for unrelated processing of sensitive information.

Where Neurobloom processes personal information on behalf of another organization, the applicable customer relationship, legal responsibilities, and contractual arrangements may determine the relevant lawful basis and processing obligations.


5. ARTIFICIAL INTELLIGENCE AND HUMAN REVIEW

Neurobloom uses automated technologies, including artificial intelligence, to assist with certain assessment, scoring, analysis, and report-generation activities.

These technologies are intended to improve efficiency, consistency, accessibility, and the practical usefulness of screening services.

HUMAN OVERSIGHT

Human review is an integral part of Neurobloom's standard screening and reporting process.

Authorized reviewers may evaluate assessment evidence, examine relevant responses, verify scoring, correct errors, and finalize reports.

Reviewers may include appropriately trained Neurobloom-authorized personnel or qualified professionals, depending on the applicable workflow.

Neurobloom does not use automated screening results to independently establish medical diagnoses, determine disability status, or make legally significant employment or educational eligibility decisions.

THIRD-PARTY TECHNOLOGY PROVIDERS

Neurobloom may use specialized technology providers to support functions such as speech processing, automated analysis, secure infrastructure, and report preparation.

These providers may process information necessary to perform their authorized services.

Neurobloom's policy prohibits authorizing third-party general-purpose AI providers to use participant assessment information to train their general-purpose foundation models.

PROPRIETARY AI DEVELOPMENT

Neurobloom may develop, evaluate, and improve its own proprietary assessment and scoring technologies.

Routine assessment processing and quality assurance are distinct from using participant information to train new proprietary AI models.

Participation in an assessment does not constitute general authorization for unrelated AI-model training.

Any separate proprietary AI-development activity involving identifiable or sensitive participant information requires an appropriate legal basis, applicable authorization, safeguards, and retention limits.

Where such participation is optional, declining it will not prevent an individual from receiving the standard screening service.

Voice recordings require additional consideration because removing names or contact information does not necessarily make recorded speech anonymous.

Neurobloom's current policy does not authorize optional proprietary AI training using minors' assessment information.


6. CONFIDENTIALITY AND INFORMATION SHARING

Neurobloom recognizes that screening information may be highly personal and sensitive.

We distinguish between private screening information and reports designed for authorized sharing.

PRIVATE SCREENING INFORMATION

Individual assessment records and private screening reports are intended for the participant or another appropriately authorized recipient.

Purchasing or sponsoring an assessment does not automatically grant a coach, employer, school, or other purchaser access to the participant's private screening information.

REPORT DELIVERY

Reports are ordinarily delivered to the designated email address provided and confirmed through the assessment process.

For minors, report delivery and sharing are governed by the applicable parent or guardian authorization and any legally permitted institutional arrangement.

WORKPLACE AND OTHER SHAREABLE REPORTS

Neurobloom may generate separate reports designed to communicate relevant functional information and practical support recommendations.

Participants, or appropriately authorized parents or legal guardians, may choose to share appropriate reports with employers, educators, coaches, clinicians, or other recipients.

An employer does not automatically receive an employee's private screening information merely because the employer purchased or sponsored an assessment.

Workplace reports are intended to support understanding and accommodation discussions, not hiring, promotion, termination, disciplinary decisions, or employee performance evaluation.

AUTHORIZED PERSONNEL

Neurobloom personnel and authorized reviewers may access information necessary to perform legitimate assessment, review, reporting, support, and operational responsibilities.

Access is restricted according to authorized roles and responsibilities.

SERVICE PROVIDERS

We may disclose information to service providers supporting:

- Hosting and information storage.
- Assessment and speech processing.
- AI-assisted analysis and reporting.
- Communications and report delivery.
- Payment processing.
- Security and technical operations.
- Website hosting and analytics.

Service providers process information according to their authorized functions and applicable contractual and legal requirements.

PROFESSIONAL AND ORGANIZATIONAL CUSTOMERS

Neurobloom may provide services directly to individuals or through arrangements with clinics, coaches, schools, employers, and other organizations.

Depending on the relationship, Neurobloom may independently determine the purposes and means of processing or may process information on behalf of another organization.

Where required, appropriate data-processing agreements govern the relevant responsibilities.

Organizational sponsorship does not, by itself, authorize unrestricted access to participant information.

LEGAL DISCLOSURES

We may disclose personal information when required by law or lawful legal process, or where otherwise legally permitted and reasonably necessary to investigate security incidents, prevent fraud, protect individuals, or establish, exercise, or defend legal rights.

CORPORATE TRANSACTIONS

Personal information may be transferred in connection with a merger, acquisition, financing, restructuring, or transfer of relevant business assets, subject to applicable law and appropriate data-protection obligations.

NO SALE OF PARTICIPANT INFORMATION

Neurobloom does not sell participant assessment information, neurodevelopmental information, recorded audio, or related sensitive personal information to advertisers, data brokers, marketers, or other parties for commercial profiling.


7. RESEARCH, VALIDATION, AND PRODUCT IMPROVEMENT

Neurobloom is committed to improving the scientific reliability, accessibility, and usefulness of its screening technologies.

We may use appropriately de-identified, aggregated, or otherwise lawfully processed information for purposes such as:

- Evaluating assessment reliability.
- Improving scoring quality.
- Examining item performance.
- Assessing fairness across demographic groups.
- Conducting scientific validation.
- Improving usability and accessibility.
- Improving assessment methods and reporting quality.

Information is treated as de-identified only when it satisfies applicable legal standards.

Pseudonymized or otherwise linkable information remains subject to applicable personal-data protections.

EXTERNAL RESEARCH PARTNERSHIPS

Neurobloom may establish collaborations with legitimate universities, clinicians, academic institutions, or scientific research organizations.

Any future external research disclosure involving personal information must have an appropriate legal basis and applicable authorization, contractual protections, and ethical safeguards.

Research partners may not use participant information for unauthorized advertising, data brokerage, commercial profiling, or resale.

Neurobloom does not currently operate a general external research-data-sharing program.


8. CHILDREN'S PRIVACY

Neurobloom provides screening services that may involve children and adolescents, including children under 13.

We recognize that children's personal information requires additional care and protection.

PARENTAL AND GUARDIAN AUTHORIZATION

Minor participation must be authorized by a parent or legal guardian or conducted through another legally permitted arrangement.

Where applicable law requires verifiable parental consent, that requirement must be satisfied before the relevant collection or processing of children's personal information.

Additional safeguards may apply depending on the child's age, location, and the assessment arrangement.

CHILDREN'S INFORMATION

Information collected in connection with a child's assessment may include:

- Identifying and age-related information.
- Parent or guardian contact information.
- Assessment and questionnaire responses.
- Recorded spoken responses.
- Performance measurements and screening scores.
- Reviewer observations and decisions.
- Generated screening reports.

This information is used to administer authorized assessments, evaluate responses, prepare reports, support quality review and correction, and fulfill other legally permitted purposes.

Children's private assessment information is not made publicly available through Neurobloom's standard screening service.

PARENTAL RIGHTS

Subject to applicable law and appropriate verification of identity or authority, parents and legal guardians may request to review personal information collected about a child, correct inaccurate information, request deletion of eligible information, or withdraw authorization for further collection or processing where legally permitted.

Requests may be submitted to support@neurobloomhealth.com.

EDUCATIONAL AND CLINICAL ARRANGEMENTS

Where assessments are arranged through schools, clinics, or other institutions, additional privacy obligations and agreements may apply.

Institutional authorization does not replace parental consent where applicable law requires it.

CHILDREN'S INFORMATION AND AI DEVELOPMENT

Children's identifiable assessment information and recordings are not authorized for optional proprietary AI-model training under Neurobloom's current adult-only AI-development policy.

Any future change would require a separate legally appropriate framework.

RETENTION OF CHILDREN'S INFORMATION

Children's information is subject to the retention principles described in Section 9.

Where children's privacy laws impose additional restrictions or shorter retention periods, those requirements govern.


9. DATA RETENTION AND DELETION

Neurobloom maintains retention policies intended to limit personal-information storage to appropriate periods based on the purposes for which information is collected.

ASSESSMENT INFORMATION

Assessment-related information is retained for purposes such as report preparation and delivery, scoring verification, quality review, correction of errors, report regeneration, and reasonable service support.

Neurobloom has adopted a standard retention target of up to 12 months after report finalization for routine assessment records, subject to applicable legal and contractual exceptions.

The technical processes supporting that retention standard, including deletion from different systems and backup expiration, may operate on different schedules.

Accordingly, the target should not be interpreted as a guarantee that every copy is automatically deleted at an identical time.

INCOMPLETE ASSESSMENTS

Information associated with incomplete assessments may be retained for a limited period to permit resumption, troubleshooting, or appropriate follow-up.

Retention depends on the participant's last activity, the status of the assessment, applicable service requirements, and any legal obligations.

OTHER RECORDS

Certain records may be retained for separate periods appropriate to their purposes.

These include:

- Consent and authorization evidence.
- Payment and accounting records.
- Security and operational logs.
- Records necessary to investigate incidents.
- Information required to resolve disputes or comply with legal obligations.

Neurobloom's approved recordkeeping policy generally provides for retaining necessary financial and consent evidence for seven years, subject to applicable legal requirements.

Retaining minimal financial or authorization records does not authorize indefinite retention of underlying assessment information.

DELETION REQUESTS

Individuals may request deletion of eligible personal information by contacting Neurobloom.

We may verify the identity or legal authority of the requester before processing a request.

Requests are evaluated according to applicable law, contractual obligations, and legitimate recordkeeping or security requirements.

Qualifying information will be deleted according to applicable procedures.

Residual copies may remain temporarily in protected backups until those backups expire, where legally permitted.


10. INFORMATION SECURITY

Neurobloom uses administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, disclosure, alteration, misuse, and loss.

Our security approach includes measures relating to secure processing, information access restrictions, confidentiality, authorized personnel, and oversight of relevant technology providers.

The safeguards applied depend on the nature and sensitivity of the information and the services involved.

We review and adapt our security practices as our technology, operations, and applicable obligations evolve.

No electronic information system can be guaranteed completely secure.

If a security incident occurs, Neurobloom will investigate and take appropriate action, including providing notifications required by applicable law.


11. INTERNATIONAL DATA PROCESSING

Neurobloom is incorporated in the United States and makes its services accessible internationally.

Personal information may be processed, stored, or accessed in jurisdictions other than the individual's country of residence.

Applicable privacy laws may impose different obligations concerning sensitive information, children's data, international transfers, and individual rights.

EUROPEAN UNION AND UNITED KINGDOM

Where GDPR or UK GDPR applies, Neurobloom processes personal information subject to the relevant legal requirements.

These may include obligations concerning lawful processing grounds, special-category information, transparency, individual rights, processor agreements, international transfers, and data protection impact assessments.

Individuals may exercise applicable statutory rights and lodge complaints with the relevant supervisory authority.

For individuals in the United Kingdom, the supervisory authority is the Information Commissioner's Office (ICO).

INTERNATIONAL TRANSFERS

Where applicable law requires additional safeguards for international transfers, an appropriate legal transfer mechanism or other permitted arrangement must govern the relevant processing.

Such arrangements may include applicable adequacy decisions, approved contractual protections, or other lawful transfer mechanisms.

Individuals may contact Neurobloom for information concerning safeguards applicable to their personal information.

OTHER JURISDICTIONS

Individuals in other jurisdictions may have additional privacy rights and protections.

Additional jurisdiction-specific notices may supplement this Privacy Policy where required.


12. WEBSITE COOKIES AND ANALYTICS

Neurobloom's public website uses Wix and Wix Analytics to support website operation, performance measurement, and understanding of visitor interactions.

These technologies may collect information about devices, browsers, IP addresses, and website activity.

Our assessment software operates separately from our Wix website.

Website analytics are not intended to collect private screening responses, assessment scores, or recorded assessment audio.

Where applicable law requires consent for nonessential cookies or analytics technologies, visitors will be provided with appropriate consent choices.

Visitors may also manage certain cookie preferences through their browser settings.


13. COMMUNICATIONS AND INDIVIDUAL PRIVACY RIGHTS

SERVICE COMMUNICATIONS

Neurobloom may send communications necessary to administer assessments, provide access information, deliver reports, respond to support requests, process payments, and communicate important service or security information.

MARKETING COMMUNICATIONS

Promotional communications are separate from necessary service communications.

Where required, Neurobloom obtains appropriate authorization before sending promotional communications.

Recipients may unsubscribe through the available unsubscribe mechanism or by contacting Neurobloom.

INDIVIDUAL PRIVACY RIGHTS

Depending on applicable law and individual circumstances, individuals may have rights to:

- Access personal information.
- Correct inaccurate information.
- Request deletion of eligible information.
- Restrict or object to certain processing.
- Withdraw consent where applicable.
- Request data portability where legally available.
- Challenge certain automated decisions where applicable.
- Appeal certain privacy-rights decisions where required by law.
- File complaints with an appropriate privacy or data-protection authority.

Requests may be submitted to:

support@neurobloomhealth.com

Neurobloom may verify the identity or authority of the requester before fulfilling a request.

Where Neurobloom processes information on behalf of another organization, we may coordinate with that organization to address the request appropriately.

We will not unlawfully discriminate against individuals for exercising applicable privacy rights.


14. CHANGES TO THIS PRIVACY POLICY

Neurobloom may update this Privacy Policy to reflect changes in its services, technologies, information practices, or legal requirements.

The current version will be available through our website and will identify its effective or updated date.

Material changes will be communicated where required by applicable law.

Where new processing activities require additional consent or authorization, Neurobloom will obtain the required authorization before undertaking those activities.

Additional jurisdiction-specific notices may supplement this Privacy Policy.

Nothing in this Policy limits rights or protections that cannot lawfully be waived.


15. CONTACT INFORMATION

For questions, concerns, or requests relating to this Privacy Policy or Neurobloom's information practices, contact:

Neurobloom, Inc.

1831 North Gramercy Place 303
Los Angeles, CA 90028
United States

Email: support@neurobloomhealth.com

Website: www.neurobloomhealth.com

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