Learn how Propel protects your data and respects your choices, so you can feel safe and in control while using the app.
Last Updated: July 17, 2025
This Privacy Policy explains how Neuron Wizard Unipessoal Lda. ("Neuron Wizard," "we," or "us") complies with the General Data Protection Regulation ("GDPR"), the Health Insurance Portability and Accountability Act ("HIPAA"), and other applicable data protection laws and regulations. It outlines how we collect, store, use, transfer, and share personal data from users ("you") in connection with our platform, Propel, and any associated services or websites (collectively, the "Services").
Neuron Wizard is the data controller responsible for the Services.
We may update this Privacy Policy from time to time. If we make material changes, we will notify you via email, within the platform, or through other appropriate means. Where required by law, we will ask for your consent to those changes. If you continue to use the Services after an update, it indicates your acceptance of the revised policy. If you do not agree with the changes, please discontinue use of the Services.
The latest version of this policy is always available within our platform (app or website).
We collect personal data when you interact with Propel’s platform and related services. This may happen directly (when you provide it to us), automatically (through your use of the Services), or through third-party integrations. Certain types of data collection are subject to your explicit consent, which you can manage within the platform settings.
General information: When you create an account on Propel, we may collect personal data such as your name, email address, and password. We also store your sign-in method (e.g., Google, Apple, or email). In addition, we may collect technical data like your time zone and language settings to help provide a localized experience.
Well-being and mental health information: To personalize your experience, you may choose to share additional personal information such as your age range, gender, and whether you have been diagnosed with ADHD. You can also optionally share information related to your mental and cognitive health, including conditions such as anxiety, bipolar disorder, color blindness, depression, dyslexia, dyscalculia, hearing loss, sleep disorders, personality disorders, or substance use disorders. Providing this information is completely optional.
Your consent for processing this sensitive health data is required, and this consent is specifically for the purpose of personalizing your daily workouts and the platform content. You can use most core features of Propel without entering any well-being or mental health data.
When you access or use the Services, we may automatically collect certain information to help us improve and personalize your experience, as well as for security and analytics purposes, only after obtaining your consent where required by law.
Device information: This may include your device model, operating system and version, unique device identifiers, enabled accessibility features (such as display, hearing, or motor settings), mobile operator and network details, and device storage or system version information.
Location information: We may collect your IP address to estimate an approximate location (not precise), your time zone, and information about your mobile service provider.
Usage data: We collect information about how you use the Services, including how often you use the platform, which features or sections you access, and payment transaction information (excluding full payment card details). This data helps us understand engagement and improve the platform functionality.
Cookies and similar technologies: We use cookies and related technologies to collect this information, subject to your consent.
Data from external sources: Occasionally, we may receive personal data about you from third-party sources to supplement or enhance our records. This may be used to customize your experience or for statistical and analytics purposes.
Depending on which features of the Services you use, we process your personal data based on one or more of the following legal bases:
Your explicit consent: For special categories of personal data (such as health data) and for marketing/advertising purposes, we process your data based on your explicit consent. You give us permission to process your personal and health-related data to provide and personalize the Services and to receive marketing communications.
To fulfill our contractual obligations to you: We process your personal data to fulfill our obligations to you, such as managing your platform’s account, subscription, and providing access to features in the platform.
Legitimate interests: We process personal data to manage and improve our Services while balancing your rights and interests. For example, we may use your data to:
- Identify and fix technical issues or bugs;
- Detect genuine user interactions and prevent abuse (e.g., bots);
- Monitor the performance and reliability of the platform;
- Send you notifications related to your subscription or platform updates;
- Conduct security scans to protect the Services;
- Analyze aggregated usage trends to improve the platform.
Legal obligations: We may process your personal data to comply with applicable laws and regulations (e.g., retaining certain data for tax purposes).
Below are some specific purposes and legal bases for processing your personal data:
Purpose: To support core platform functions, including personalized daily workouts and content.
Legal Basis: Consent & Contract.
Example: Use of your age range, mental health information (if you choose to provide it), and platform usage to tailor content and recommendations specifically for you.
Purpose: To communicate with you about your account, subscription, purchases, and to provide administrative support.
Legal Basis: Contract.
Example: Sending you subscription reminders, invoices, and confirmations.
Purpose: To analyze platform usage, monitor performance, and improve the user experience.
Legal Basis: Consent & Legitimate Interest.
Example: Monitoring how you interact with the platform, fixing bugs, and optimizing features.
Purpose: To send you marketing communications and promotions.
Legal Basis: Consent.
Example: Promotional emails, push notifications, and offers.
Purpose: To respond to your support requests and provide customer service.
Legal Basis: Legitimate Interest.
Example: Using your name and email to reply to your queries and follow up on issues.
Purpose: To send you important platform updates, security alerts, and surveys.
Legal Basis: Legitimate Interest.
Example: Notifications about new features or security updates.
Purpose: To inform internal content and feature development (e.g., tone, scenarios).
Legal Basis: Consent & Legitimate Interest.
Example: Using aggregated or de-identified data related to optional demographics and conditions to refine user experience and content.
If you do not consent to certain uses, you may still use most features of Propel, though some personalized functionalities may be limited or unavailable.
Data minimization and purpose limitation: We only collect and process the personal data that is necessary to provide and improve Propel’s Services, and only for the purposes you have authorized or that are clearly stated in this Privacy Policy. We do not collect or use your data beyond what is needed to deliver the platform’s features and personalized experience.
No sale of personal data: We do not sell or rent your personal data for any monetary gain. Your information will only be shared with trusted service providers who help us operate and improve Propel, as outlined in this Privacy Policy. We will not use your health data for advertising purposes or share it with advertising platforms, data brokers, or information resellers.
Wherever you are in the world, we are committed to respecting your individual privacy rights under applicable data protection laws, including the GDPR and HIPAA.
Making a request: Only you, or someone legally authorized to act on your behalf, can make a verifiable request regarding your personal data. To protect your privacy, we may ask you for reasonable proof of identity or authorization before responding to such requests.
Correction of your personal data: If you believe any personal data we hold about you is inaccurate or incomplete, you can update or correct it directly within the platform's profile settings or contact us for assistance.
Restriction of processing: You can ask us to limit how we use your personal data in certain situations, for example, if you contest its accuracy while we verify it.
Access to your personal data: You have the right to request information about the personal data we process about you, access your personal data, and receive a copy in a structured, machine-readable format (such as JSON). Many of these options are available directly within the platform.
Right to data portability: You may request your personal data in a portable format that allows you to transfer or reuse it with other services safely and securely.
Erasure of your personal data: You can request deletion of your personal data at any time, either through the platform or by contacting us. Upon receiving a deletion request, we will initiate the process of removing your data from our systems and instructing all relevant third-party processors to delete your data. Please note that erasing certain data may affect your experience and access to some app features that rely on historical information.
Objection to processing: You have the right to object to certain uses of your personal data, such as processing for direct marketing purposes. You can submit your objection directly within the platform's consent settings or by contacting us.
To exercise your privacy rights, please contact us at support@neuronwizard.com.
We will respond to your request within one month of receiving it. In some cases, such as complete deletion of data from backup systems and from third-party processors, this may take up to 90 days. If more time is needed, we will inform you and explain the reasons for the delay.
We rely on your explicit consent to process your health data and to enable certain personalized Services. You can withdraw your consent at any time by adjusting your consent settings within the app or by deleting your account.
If your request is unclear, we may reach out to you for clarification. We also reserve the right to refuse or charge a reasonable fee for requests that are manifestly unfounded or excessive (e.g., repetitive requests).
To protect your privacy, we will ask you to verify your identity. Typically, this means confirming the request comes from the email you used to register. If you do not have a registered account, we may require additional verification steps to ensure we respond appropriately.
Subject to applicable law, you also have the right to lodge a complaint with your local data protection authority regarding our data processing practices. If you have any questions or concerns about your privacy, please email our support team at support@neuronwizard.com.
We will not share your personal data with third parties except as described in this Privacy Policy.
With your consent, we may share some of your non-health personal data with AppsFlyer to help promote the Services.
AppsFlyer is a mobile marketing platform that processes your personal data according to our instructions. Using AppsFlyer and its integrated partners allows us to reach you and users with similar interests on various platforms, helping spread the word about the platform. If we ever need to share your personal data with other platforms beyond what is explained here, we will ask for your consent.
How we work with AppsFlyer and its partners for marketing: When you become a platform user, and with your explicit consent, we share the following personal data with AppsFlyer and its integrated partners to promote the Services:
Technical identifiers such as IP address (which may indicate approximate location), user agent, advertising IDs (e.g., IDFA for iOS devices, Google advertising ID for Android), hashed email, age range, subscription status, and information about app launches. AppsFlyer analyzes this data and provides us with reports and insights to optimize our marketing campaigns.
AppsFlyer then shares your personal data with some of its integrated partners (for example, Snapchat, Google Ads, Apple Search Ads, Meta Ads, TikTok Ads, and others). These partners use the data to identify you or users with similar profiles on various platforms, including social media, and may show ads or reminders to encourage engagement with the platform.
For more information, you can read about how AppsFlyer works and how its integrated partners handle data. You can withdraw your consent or opt out of sharing your personal data with AppsFlyer for marketing purposes at any time by adjusting your device settings on iOS or Android, or within Propel's consent management settings.
In some situations, we engage other companies to process your personal data on our behalf. We refer to these companies or service providers as “processors.”
Processors are companies that help us run the Services, support our communication with you, or perform other app-related activities. They process certain personal data on our behalf to accomplish the goals related to the app functions and deliver the Services. We remain responsible for any acts or omissions of our processors, and we enter into Data Processing Agreements (DPAs) with them as required by GDPR and Business Associate Agreements (BAAs) as required by HIPAA, to ensure your data is protected.
Neuron Wizard’s team is based in Portugal, and we work with processors located in different countries to provide the Services effectively.
Here are some of the main processors we rely on and the data they process on our behalf:
AppsFlyer
Privacy Policy: AppsFlyer Privacy Policy
Data Processed: Technical identifiers, email hash, device data.
Purpose: For marketing attribution and integrating user onboarding.
Facebook App Events
Privacy Policy: Facebook Privacy Policy
Data Processed: Platform usage data.
Purpose: To support marketing analytics and promotional efforts.
Firebase Analytics
Privacy Policy: Firebase Privacy Policy
Data Processed: Platform usage data.
Purpose: To monitor platform performance and user behavior.
Firebase Crashlytics
Privacy Policy: Firebase Privacy Policy
Data Processed: Crash reports, device data.
Purpose: For debugging and reporting app crashes.
Mixpanel
Privacy Policy: Mixpanel Privacy Policy
Data Processed: Platform usage data.
Purpose: To track usage patterns and user cohorts, helping us improve the platform experience.
PostHog
Privacy Policy: PostHog Privacy Policy
Data Processed: Platform usage data, demographics (age range, gender).
Purpose: To analyze platform usage, understand engagement, and generate statistical reports.
RevenueCat
Privacy Policy: RevenueCat Privacy Policy
Data Processed: Purchase and subscription data.
Purpose: To manage subscriptions and payment processing.
Retool
Privacy Policy: Retool Privacy Policy
Data Processed: Internal tool data.
Purpose: For platform management and internal workflows.
SalesIQ (Zoho)
Privacy Policy: Zoho Privacy Policy
Data Processed: Email address, name.
Purpose: To provide live chat and email support.
Supabase
Privacy Policy: Supabase Privacy Policy
Data Processed: User ID, authentication data.
Purpose: To manage authentication and backend services.
Webflow
Privacy Policy: Webflow Privacy Policy
Data Processed: Email address, name.
Purpose: For email communications and website hosting.
We may aggregate, anonymize, or otherwise de-identify your personal data so that it can no longer reasonably be used to identify you.
We may use or share this type of data with third parties such as academic institutions for research, or for statistical and analytical purposes. For example, we might share general age ranges, demographic breakdowns, or aggregated patterns of in-app activity to contribute to articles, blog posts, or scientific publications that help advance understanding of cognitive health and ADHD.
For any targeted academic or user research studies that involve identifiable information or more specific participation, we will always contact you first and rely on your explicit consent. You can withdraw that consent at any time by emailing us at support@neuronwizard.com.
We may preserve or disclose certain personal data in limited circumstances, including:
- When required by law, such as in response to subpoenas, court orders, or other legal processes, including to meet national security or law enforcement requirements;
- To protect the security and integrity of the Propel app, our users, or others. For example, we may reset your password to prevent unauthorized access;
- To establish, exercise, or defend legal claims;
- When you provide consent or specifically direct us to share your data;
- As part of a business transaction, such as a merger, acquisition, or corporate reorganization.
Depending on the context, we may rely on our legal obligations or legitimate interests as the legal basis for these disclosures.
You can use Propel without creating an "Account." In this mode, we do not collect or store any personal identifiers like your name or email.
What this means:
- You remain anonymous while using the app (no name, email, or linked user ID);
- Your data stays local to your device unless you choose to sign in or create an account;
- Some features that rely on personal data, like cross-device syncing and email reminders, will not be available.
If you’ve previously created an account, you can always sign out to continue using the app anonymously.
As with any digital service, no system is completely immune to risks. But by not linking your identity to your data, the potential impact of any unauthorized access is significantly reduced.
We're here to help, though support may be limited for anonymous users since we can't look up your information without a linked identity.
We only keep your personal data for as long as needed to provide you with the Services or meet legal and operational requirements. The specific retention periods for different types of data are determined based on their purpose, legal obligations (such as HIPAA record retention requirements), and our legitimate business interests.
If you delete your account, we’ll begin removing your data and aim to complete this within 30 days. In some cases, it can take up to 90 days to fully erase data from backup systems and all third-party processors.
Anonymous users don’t create an account, so we don’t store any personal data tied to identity unless they later sign in.
Even after account deletion, we may retain certain information:
- If required to comply with laws (e.g. GDPR, HIPAA, tax laws);
- To defend legal claims;
- For public interest, scientific, or statistical purposes, where permitted and adequately anonymized/pseudonymized.
We follow industry-standard procedures to securely erase your data from all systems. This includes notifying trusted processors we work with, ensuring your information is no longer recoverable.
We take the security of your personal data seriously. We use a combination of technical, legal, and organizational safeguards to protect it from unauthorized access, loss, misuse, or disclosure.
Here’s how we help keep your data safe:
- We encrypt your personal data both in transit and at rest;
- We safeguard data integrity and restrict employee access based on role and necessity;
- Our team follows strict rules on data handling and accountability;
- If Propel is ever acquired or merged, we’ll carry out a privacy audit to protect your rights.
What you can do: Please use a secure password and don’t share it with anyone. Adding a passcode or Face ID to your device can provide an extra layer of protection for your app access.
In case of a breach: If a security issue affects your data, we’ll take quick action. This might include notifying you, logging you out of all devices, resetting your password, or other necessary steps as required by law.
Propel is designed for adults. We do not knowingly collect personal data from children under 13 years old. If you believe a child under 13 is using the app, please email us at support@neuronwizard.com so we can take appropriate action, including deleting the account and any associated data.
In line with local regulations:
- If you're in the EEA, UK, or Canada, you must be at least 16 years old to use the app.
- Some features in the platform might only be available to users who are 18 or older.
We’re committed to protecting children’s privacy. If you have concerns or questions, reach out to support@neuronwizard.com.
We may occasionally reach out to you by email, push notification, or in-app messages to share updates about the platform, like new features, promotions, rewards, or content we think you’ll enjoy. These messages may reflect how you use the app (for example, the features you engage with most).
Opting out: You can unsubscribe from marketing emails anytime by clicking the “Unsubscribe” link in the email. You can also turn off push notifications in your device settings. Please note that you’ll still receive essential service-related emails that help you use Propel (e.g., password resets or privacy notices), even if you opt out of marketing messages.
We may also share news about the platform, like promotions or events, on platforms such as social media. If you interact with us there, we may see public info like your username or profile picture. We only use that information to respond or engage with you.
Neuron Wizard is based in Portugal. Personal data we collect may be transferred to and processed in the United States and other countries where our processors are located. These transfers usually happen via cloud services when you use the platform and are governed by the laws of the countries where the data is processed. Please note that these laws might not offer the same level of protection as the laws in your country.
If you’re located in the European Economic Area (EEA) or the UK, your personal data is protected by GDPR. When we transfer your data outside of these regions, we put safeguards in place to keep your information safe. For example, we use data transfer agreements that include the European Commission’s approved Standard Contractual Clauses (SCCs)..
If you have any questions or want more details, please contact us at support@neuronwizard.com.
We do not sell your personal information for monetary gain.
Under some state laws (including California), sharing your personal information with a third party for certain benefits may legally be considered a “share” or "sale" for cross-context behavioral advertising.
Your Rights to Opt Out / Do Not Track: You have the right to opt out of sharing your personal information with our analytics and advertising partners. This includes opting out of what some laws broadly define as a “sale,” and any “Do Not Track” (DNT) signals your browser might send. Please note, none of this personal information includes your health data, and we do not share your health data with these partners under any circumstance. Currently, Propel does not respond to Do Not Track browser signals because no universal DNT standard exists. To exercise your rights or opt out, please contact us at support@neuronwizard.com or use the privacy settings within the app.
Limiting Use of Sensitive Personal Information: We only process sensitive personal information (including health data) as necessary to provide the Services to you, and always with your explicit consent where required.
Request to Know/Access: You have the right to request information about the personal and sensitive data we have collected about you and how we use it, including the categories, sources, and third parties involved in personal data we collected, shared, or disclosed in the last 12 months. You can make this request once per year at no charge.
“Shine the Light” (California residents only): You can request once per calendar year information about any personal data we have shared with third parties for their own direct marketing purposes. We do not share data for their independent marketing use, but if you have questions, please email support@neuronwizard.com with the subject line “California Privacy Rights Request” and include your full name and mailing address.
Note: When we say “personal data” here, it includes “sensitive personal information” as defined by California law.
If you have any privacy questions or concerns, you can reach us at:
Neuron Wizard Unipessoal Lda.
Caminho do Quitadouro 17, R/C Traseiras
9880-315 Santa Cruz da Graciosa, Portugal
Or by email at: support@neuronwizard.com.
You may also contact your local data protection authority if you have concerns about our data processing practices.
