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    NeuroTorq — differently wired. Build to thrive.

    Privacy Policy

    Last updated: 7 August 2026

    NeuroTorq helps people with ADHD get a grip on focus, medication, supplements and routines — via this website and via the NeuroTorq app. In doing so, we process personal data, including health data. This policy sets out exactly which data that is, why we process it, how long we keep it and what rights you have under the GDPR.

    1. Who we are

    NeuroTorq is the data controller for the data processed via this website and the NeuroTorq app. You can reach us via info@neurotorq.com.

    Questions about privacy, a request for access or deletion, or reporting a data breach? Use the same email address; we respond within 30 days at the latest.

    2. What data we process

    Account data

    • Name and email address
    • Password (stored encrypted, we cannot view it)
    • Language preference and account settings

    Profile and health data (only if you enter it)

    • Age, weight, height, training experience
    • Physical and mental goals, food allergies
    • Medication: name, brand, dosage, frequency, reason, notes and any photo of the packaging
    • Supplements: product, dosage and intake times
    • Side-effect log: daily scores and notes
    • Focus sessions: start and end time, interruptions and blocked apps

    Usage and technical data

    • Device and browser information, IP address (truncated where possible)
    • Pages visited and click behaviour — only with consent for analytical cookies
    • Security and error logs

    Contact and marketing data

    • Newsletter sign-ups (email address)
    • Messages via contact forms, waiting-list and coach requests

    3. Purposes and legal basis

    PurposeLegal basis (GDPR)
    Creating an account and logging inPerformance of the contract (Art. 6.1.b)
    Showing and managing your medication, supplements, logs and focus statisticsPerformance of the contract (Art. 6.1.b) + explicit consent for health data (Art. 9.2.a)
    AI summaries and explanations about medication or supplementsExplicit consent (Art. 6.1.a and 9.2.a)
    Securing the website, resolving faults and improving itLegitimate interest (Art. 6.1.f)
    Analytical cookies and advertising measurementConsent (Art. 6.1.a)
    Sending the newsletterConsent (Art. 6.1.a)
    Responding to your question or requestLegitimate interest / performance of the contract
    Legal obligations (e.g. bookkeeping)Legal obligation (Art. 6.1.c)

    4. Health data (special category)

    Data about medication, side effects, supplements and complaints is health data. We process this exclusively on the basis of your explicit consent, which you can withdraw at any time (in the app via your profile, or by email). This data is only visible to you: row-level security applies at database level, meaning each account can only read and write its own rows.

    NeuroTorq provides general information and is not medical advice or a diagnosis. Always consult your GP or treating clinician if you have complaints or questions about medication.

    5. Use of AI

    Some features (such as explanations about a medicine or supplement, or scanning a package) use AI models from OpenAI (OpenAI, L.L.C., United States). For this we only send the data needed for that specific query — for example the name and dosage of a product or the photo you took — to OpenAI via our own secure server function. Your name, email address or account details are not included. OpenAI processes this data as a processor via the API, does not use it to train models and retains it for a maximum of 30 days for abuse detection. Transfer to the US takes place under the European Commission's Standard Contractual Clauses (SCCs). Where health data is involved, we ask for your explicit consent beforehand via the AI disclaimer. AI outputs may contain errors; always check important information with a healthcare provider.

    6. Cookies and tracking

    We place three types of cookies:

    • Necessaryneeded to log in, keep your session and remember your cookie choice. These are always on.
    • AnalyticalGoogle Analytics 4, to see which pages work well. Only with your consent.
    • MarketingGoogle Ads and Meta Pixel, for measuring and showing adverts. Only with your consent.

    Without consent, analytical and marketing cookies are switched off by default (Google Consent Mode v2: denied). You can always change or withdraw your choice via .

    7. Sharing with third parties and processors

    We never sell your data. We do engage service providers (processors), with whom a data processing agreement has been signed:

    • Supabase (Supabase Inc.) — database, authentication and file storage for the website and the NeuroTorq app, hosted in the EU region Ireland (AWS eu-west-1). This holds your account, profile and health data, protected with row-level security.
    • OpenAI (OpenAI, L.L.C.) — the AI models behind the scan and explanation features, only for the duration of processing and without training on your data.
    • Email service for account and newsletter emails
    • Google (Analytics/Ads) and Meta (Pixel) — only with consent for the relevant cookies

    In addition, we may share data when legally required, or when you explicitly consent to it (for example when requesting contact with a coach).

    8. Retention periods

    • Account, profile and health data: for as long as your account exists and up to 30 days after deletion
    • Newsletter: until you unsubscribe
    • Contact and request messages: a maximum of 2 years
    • Analytical data: a maximum of 14 months
    • Data subject to a statutory retention obligation (such as invoices): 7 years

    9. Security

    We use encryption in transit (HTTPS/TLS) and at rest, hashed passwords, per-user row-level security, shielded API keys and need-to-know based access. Suspect a vulnerability or data breach? Email us immediately at info@neurotorq.com; we investigate reports as quickly as possible and report data breaches to the Dutch Data Protection Authority where required.

    10. Storage and transfer outside the EU

    Your account, profile and health data is stored in the Supabase database within the European Union (Ireland region). Only when you use the AI features are separate, minimal data processed by OpenAI in the United States; that transfer takes place under standard contractual clauses (SCCs) with additional safeguards. Other service providers outside the EU process data under an adequacy decision of the European Commission or SCCs.

    11. Your rights

    • Access to the data we hold about you
    • Correction of inaccurate data
    • Deletion of your account and data ("right to be forgotten")
    • Restriction of processing
    • Objection to processing based on legitimate interest
    • Portability: an export of your data in a common format
    • Withdrawing consent, without affecting prior processing

    You can arrange much of this yourself in your account. For anything else, email info@neurotorq.com. We may ask for additional verification before carrying out a request.

    12. Children

    NeuroTorq is intended for adults (16 years and older). We do not knowingly collect data from children under 16. If you find out this has happened anyway, let us know and we will delete the data.

    13. Changes

    We may amend this privacy policy if the website, the app or the legislation changes. The date at the top indicates the latest version; for major changes we will actively inform you.

    14. Contact and complaints

    NeuroTorq — info@neurotorq.com

    Can't reach a resolution with us? You can lodge a complaint with the Dutch Data Protection Authority (autoriteitpersoonsgegevens.nl).

    See also our medical disclaimer and terms.