Privacy Policy

VANAYA NEUROLAB

DATA PRIVACY & NEUROMETRIC DATA GOVERNANCE POLICY

1. Purpose of the Policy

This policy establishes the foundational governance framework for the lawful and responsible collection, processing, storage, protection, and management of Neurometric® data generated through Vanaya NeuroLab research activities.

This policy defines the regulatory positioning of Neurometric® data governance within Vanaya’s technology architecture and research operations.

2. Scope of Application

This policy applies to Neurometric® research activities conducted through Vanaya NeuroLab and to affiliated entities within the Vanaya ecosystem that are formally authorized to support research, platform, or implementation activities.

This policy applies to Neurometric® research activities conducted through Vanaya NeuroLab and to affiliated entities within the Vanaya ecosystem that are officially authorized to support research activities, platforms, or implementation. 

3. Legal and Regulatory Compliance

Vanaya NeuroLab conducts its research activities in accordance with applicable data protection laws, lawful research governance requirements, and relevant cross-border data protection principles where applicable.

Compliance obligations may vary across jurisdictions and shall be implemented under Vanaya’s internal data governance framework in accordance with applicable law.

4.  Nature of Neurometric Data

Neurometric® data refers to analytical cognitive indicators derived from signal-based measurements processed through proprietary Neurometric® models developed within Vanaya research programs.

Signal-based data collected in Vanaya research activities are used exclusively for analytical and research purposes and are not intended for medical diagnosis, clinical evaluation, or healthcare decision-making.

5. EEG Device Classification

Devices used within Vanaya research activities are commercial signal measurement tools intended for cognitive analytics and research applications.

Such devices are not used for medical diagnosis, clinical care, or healthcare service purposes within Vanaya research programs.

6. Data Collection Principles

Neurometric® data collection is conducted based on informed consent, transparency principles, and lawful research governance requirements.

Participants are informed regarding the nature, purpose, and scope of data collection prior to participation.

7. Data Anonymization

Vanaya NeuroLab implements anonymization procedures to separate personally identifiable informationfrom neurometric datasets.

Neurometric datasets used for research analytics do not contain identifiable personal information.

Anonymization procedures are implemented to ensure that neurometric datasets used for analytics cannot reasonably identify individual participants.

8. Longitudinal Research Data

Vanaya NeuroLab may maintain anonymized datasets for longitudinal research aimed at understanding cognitive development and adaptive capacity over time.

Longitudinal datasets may include repeated neurometric measurements collected across multiple time periods.

Retention of anonymized longitudinal datasets shall be conducted in accordance with lawful research retention principles, scientific justification, and applicable governance requirements.

9.  Data Storage Infrastructure

Neurometric® datasets may be stored within secure cloud infrastructure that forms part of Vanaya’s technology architecture.

Data may be processed within secure infrastructure in accordance with applicable governance, security, and lawful processing requirements.

10. Neurometric® Dataset Ownership

All Neurometric® datasets generated through Vanaya NeuroLab research activities are legally owned by PT Vanaya IP Holder (Indonesia).

Ownership of Neurometric® datasets remains with PT Vanaya IP Holder (Indonesia) regardless of the location of collection, processing, or storage.

Ownership of Neurometric® datasets is established at the intellectual property governance level and remains independent of operational, research, or technical processing arrangements.

11. Data Security Measures

Vanaya NeuroLab implements technical and organizational measures to protect Neurometric® datasetsfrom unauthorized access.

Security measures may include encryption, access control mechanisms, monitoring systems, and role-based restrictions on access to Neurometric® datasets.

12. Ethical Use of Neurometric® Data

Neurometric® data collected through Vanaya NeuroLab research activities shall only be used for scientific, analytical, research, and organizational development purposes.

Neurometric® data shall not be used for purposes that violate ethical principles, participant rights, or the intended non-clinical scope of the Vanaya system.