Neuro Divert Ltd (“Neuro Divert”, “we”, “us”, or “our”) is a private limited company registered in Ireland, with its registered office at 5 Avoncore Place, Midleton, Cork, Ireland, Company Number 752508, incorporated on 21 November 2023. We are the data controller for the personal data described in this Privacy Policy. This Policy explains how we collect, use, store, and protect personal data when you use our website and services, including IT consulting, cybersecurity consulting, IT support, and our Virtual Private Network (VPN) service. Please note: our VPN service is currently in development and coming soon. The VPN-related sections of this Policy (in particular Section 2) describe how the service will handle data from launch, so you can see our commitments before it becomes available.
We process personal data in accordance with the EU General Data Protection Regulation (GDPR) and the Data Protection Act 2018.
1. Data Controller and Contact
Data Controller: Neuro Divert Ltd, 5 Avoncore Place, Midleton, Cork, Ireland
Privacy contact: privacy@neurodivert.com. If we appoint a Data Protection Officer, their contact details will be published here.
2. Our No-Log VPN Commitment
Our VPN service is coming soon. The commitments in this Section will apply in full from launch.
Our VPN service is designed around data minimisation:
- We do not log your browsing history, traffic content, DNS queries, connection destinations, or data content.
- We do not log your originating IP address when you connect to our VPN servers.
- We do not sell, rent, or trade user activity data — we do not have it to sell.
The only connection-related data we may process is short-lived, in-memory technical data required to establish and maintain your session (e.g., active session count and bandwidth used), which is not written to persistent logs and is discarded when the session ends.
3. Personal Data We Collect
3.1 Account and billing data
When you register or purchase, we collect:
- Name and email address
- Billing address (for VAT and invoicing purposes)
- Payment transaction references (we do not store full payment card numbers; card data is processed directly by our payment processors)
Lawful basis: performance of a contract (Art. 6(1)(b) GDPR) and legal obligations relating to tax and accounting (Art. 6(1)(c) GDPR).
3.2 Website and support data
- Communications you send us (support requests, emails)
- Basic technical data needed to operate and secure the website, such as IP address, browser type and request logs. We do not currently use analytics cookies.
Lawful basis: legitimate interests in operating, securing, and improving our website and support (Art. 6(1)(f) GDPR), or consent where required (Art. 6(1)(a) GDPR).
3.3 Consulting and IT support engagements
For consulting, cybersecurity, and IT support clients, we may process business contact details, and — strictly as necessary for the engagement — data relating to your systems, networks, and personnel. Such processing is governed by the engagement contract and, where we act as processor on your behalf, by a data processing agreement.
Lawful basis: performance of a contract (Art. 6(1)(b) GDPR).
3.4 Marketing
With your consent, we may send you service updates and marketing communications. You may withdraw consent at any time via the unsubscribe link or by contacting us.
Lawful basis: consent (Art. 6(1)(a) GDPR).
4. How We Use Personal Data
We use personal data to:
- Create and manage your account and subscriptions
- Process payments and prevent fraud
- Deliver and support our Services
- Meet legal, tax, and accounting obligations
- Improve and secure our website and Services
- Communicate with you about your account and, with consent, marketing
We do not use personal data for automated decision-making or profiling that produces legal or similarly significant effects.
5. Payment Processors and Other Third Parties
We share personal data only with:
- Payment processors (e.g., card acquirers and payment gateways) who process payments on our behalf under their own privacy policies
- Service providers acting as our processors under written data processing agreements (e.g., hosting, email, accounting software)
- Professional advisers and authorities where required by law (e.g., Revenue Commissioners, regulators, or courts)
We require all processors to protect personal data and to process it only on our documented instructions.
6. International Transfers
Where personal data is transferred outside the EU/EEA (for example, to hosting or payment providers), we ensure an adequate level of protection through EU adequacy decisions, Standard Contractual Clauses, or equivalent safeguards.
7. Data Retention
- Account data: retained while your account is active and deleted or anonymised within 30 days of closure, unless a longer period is required by law.
- Billing and invoice records: retained for 6 years as required by Irish tax and company law.
- Support correspondence: retained for up to 12 months.
- VPN traffic/activity data: not collected (see Section 2).
8. Security
We apply appropriate technical and organisational measures, including encryption in transit and at rest, access controls, least-privilege access, and regular security reviews. No system can be guaranteed 100% secure, but we maintain incident-response procedures and will notify the Data Protection Commission and affected users of personal data breaches where required by law.
9. Your Rights Under GDPR
You have the right to:
- Access your personal data
- Rectify inaccurate data
- Erase your data (“right to be forgotten”), subject to legal retention requirements
- Restrict or object to processing
- Data portability
- Withdraw consent at any time (without affecting prior lawful processing)
- Lodge a complaint with the Irish Data Protection Commission (dataprotection.ie)
To exercise any of these rights, contact us at privacy@neurodivert.com. We respond within one month.
10. Cookies
NeuroDivert does not use analytics, advertising or social-media tracking cookies. Our hosting provider may use cookies that are strictly necessary to provide secure access and operate the website. These essential cookies cannot be used for advertising and do not require consent.
11. Children
Our Services are not directed at children under 18, and we do not knowingly collect their data. VPN account holders must be 18 or older.
12. Changes to This Policy
We may update this Policy from time to time. Material changes will be notified on our website or by email before taking effect. The “Last Updated” date shows the current version.
13. Contact
Neuro Divert Ltd, 5 Avoncore Place, Midleton, Cork, Ireland
Email: privacy@neurodivert.com