Legal

Terms and Conditions of Use

Last updated: 27/10/2025

1. General Information

This website (www.connectoma.com) is owned by Connectoma Neurotech S.L., with registered office at Calle Padilla 26, 28006 Madrid, registered in the Madrid Commercial Registry, with tax ID (NIF) B70752795.

You can contact us at info@connectoma.com.

2. Purpose

Accessing and using this website grants user status and implies full acceptance of these Terms and Conditions. Connectoma reserves the right to modify the content, design and access conditions of the website at any time.

3. Use of the Website

The user agrees to use the content and services appropriately, in accordance with the law, morality, public order and these conditions.

The use of this website for unlawful purposes or purposes that may cause harm to Connectoma or third parties is expressly prohibited.

4. Intellectual and Industrial Property

All website content (texts, images, graphics, logos, videos, software, structure and design) is the exclusive property of Connectoma or its licensors. Reproduction, distribution, public communication or modification without express authorization is prohibited.

5. Liability

Connectoma does not guarantee permanent availability or the absence of errors. It is not responsible for indirect damages arising from the use of the website or information published by third parties, except where applicable legislation provides otherwise, and in particular without prejudice to liability for fraud, gross negligence or in relation to consumers pursuant to Royal Legislative Decree 1/2007.

6. External Links

The site may include links to third-party websites. Connectoma assumes no responsibility for the content or policies of such sites.

7. Applicable Law

These conditions are governed by Spanish and European legislation. In case of dispute, the parties shall submit to the courts of Madrid, unless otherwise provided by law.

Privacy Policy

Last updated: 27/10/2025

1. Data Controller

Connectoma Neurotech S.L. (hereinafter, "Connectoma") is the data controller responsible for processing personal data collected through this website and official communication channels.

  • Tax ID (NIF): B70752795
  • Registered office: Calle Padilla 26, 28006 Madrid
  • Contact email: info@connectoma.com

You may contact our data protection officer at info@connectoma.com for any matter related to the processing of your personal data.

2. Categories of Data We Process

Connectoma may collect the following categories of personal data:

  • Identification data: first and last name.
  • Contact data: email, phone number, postal code or city.
  • Communication data: messages and files you provide through the contact form, email, phone or WhatsApp, together with associated metadata (date, time, sender number/identifier) and, where applicable, transcripts of those conversations when they are recorded in our CRM to provide continuity of care.
  • Interaction data from our corporate accounts on social media and professional platforms (e.g., Meta —Facebook/Instagram—, LinkedIn), limited to what those platforms make available to us when you interact with our profiles or ads.
  • Browsing data: IP address, cookie identifiers and other technical data, only if you consent to their use through the cookie banner.

During phone communications, Connectoma may request general information to provide you with appropriate assistance.

Health-related data (Art. 9 GDPR)

If you share health-related information with us through any channel (form, email, phone or WhatsApp), Connectoma will process such data with the following reinforced safeguards:

  • Legal basis: processing is based on Article 9(2)(h) GDPR (processing necessary for the purposes of preventive medicine, medical diagnosis, the provision of health care and the management of health-care systems and services), in connection with Article 9(3) GDPR and with Spanish Law 41/2002, of 14 November, on patient autonomy and rights and obligations regarding clinical information and documentation.
  • Professional secrecy: health data is processed under the responsibility of professionals bound by an obligation of secrecy, or by persons subject to an equivalent obligation of confidentiality under Article 9(3) GDPR and the applicable healthcare legislation.
  • Exclusive purpose: it is used solely to handle your request, guide you regarding our services and, where appropriate, coordinate referral to a clinical centre. It is never used for advertising, commercial profiling, nor shared with third parties beyond the staff and processors strictly needed for that purpose.
  • Data minimization: we will process only the health data strictly necessary to handle your request. Please do not include detailed clinical information in open web forms; if you need to share sensitive data, we will indicate a secure channel.

We will not share your health data with social networks, advertising platforms or analytics tools. Health data categories are never sent to Meta, LinkedIn, Google or other third-party platforms.

3. Purposes of Processing

Your data is used for the following purposes:

  • Handling and managing information or contact requests.
  • Communications arising from the request or the established relationship.
  • Sending information about services or activities (only with your consent).
  • Site improvement and anonymous statistical analysis, through cookies and analytics tools (all with your consent).
  • Compliance with legal obligations and maintaining site security.

4. Legal Basis

The legal bases that allow processing are:

  • Consent of the data subject (Art. 6.1.a GDPR) for the use of forms, non-essential cookies and informational communications.
  • Legitimate interest of Connectoma (Art. 6.1.f GDPR) in managing necessary communications with users and ensuring site security.
  • Compliance with legal obligations (Art. 6.1.c GDPR) applicable to Connectoma.

5. Data Retention

Data will be retained for the following periods according to the purpose of processing:

  • Contact requests: up to 12 months after the last interaction.
  • Commercial communications (newsletter): until you withdraw your consent.
  • Cookies: as indicated in the Cookie Policy.

Once these periods have elapsed, your data will be securely deleted or anonymized for statistical purposes, unless it must be kept blocked due to a legal obligation.

6. Recipients and Data Processors

Personal data will not be shared with third parties except where legally required or where necessary to provide the service you have requested.

The following service providers, acting as data processors, may have access to your data under contracts in compliance with Article 28 GDPR:

  • Hosting: Vercel Inc. (USA) — website hosting.
  • Analytics and advertising: Google Ireland Ltd. (Google Analytics, Google Ads, Google Tag Manager).
  • Social media advertising and audiences: Meta Platforms Ireland Ltd. (Facebook, Instagram, Meta Pixel / Conversions API) and LinkedIn Ireland Unlimited Company (LinkedIn Ads and Insight Tag). These providers may act as joint controllers for certain operations (e.g., page insights or ad measurement); in those cases we rely on the joint-controller arrangements made available by those platforms.
  • CRM and internal management: Notion Labs, Inc. (USA) — recording and follow-up of communications and requests received through our channels (forms, email and WhatsApp) so that we can assist you.
  • Messaging channel: WhatsApp Ireland Ltd. / Meta Platforms Ireland Ltd. — when you contact us via WhatsApp, the content and metadata of the conversation (phone number, date, time and messages) are processed by Meta/WhatsApp under their own privacy policy and may be stored in our CRM to provide continuity of care.
  • Email marketing: MailerLite Ltd. (Ireland) — sending commercial communications where you have provided consent.

We recommend reviewing the privacy policies of Meta (facebook.com/privacy/policy), WhatsApp (whatsapp.com/legal/privacy-policy-eea), LinkedIn (linkedin.com/legal/privacy-policy), Google (policies.google.com/privacy) and Notion (notion.so/Privacy-Policy) for full details of their processing activities.

7. International Transfers

Some technology providers (e.g., Vercel Inc., Google LLC, Meta Platforms, Inc., LinkedIn Corporation or Notion Labs, Inc.) may carry out international transfers outside the European Economic Area.

Such transfers are covered by Standard Contractual Clauses approved by the European Commission and/or the EU-US Data Privacy Framework, which guarantee a level of protection equivalent to the European standard. You may request a copy of the applicable safeguards by writing to info@connectoma.com.

8. User Rights

You may exercise your rights of access, rectification, erasure, objection, restriction and portability at any time by writing to info@connectoma.com. To verify your identity we will preferably use less intrusive means; only where there is reasonable doubt may we request an identity document, which will be deleted immediately after verification.

You have the right to withdraw your consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal. Providing your data is voluntary; however, not doing so may prevent us from handling your request.

If you believe that the processing does not comply with regulations or we have not properly addressed your request, you may file a complaint with the Spanish Data Protection Agency (AEPD: www.aepd.es).

9. Minors

Our services are not directed at minors under 16 years of age.

If we detect that we have received data from a minor without proper authorization, we will delete it immediately.

10. Data Security

Connectoma applies appropriate technical and organizational measures to ensure the confidentiality, integrity and availability of personal data, in compliance with the GDPR and Organic Law 3/2018 (LOPDGDD).

11. Changes to the Privacy Policy

Connectoma may update this policy when necessary to adapt it to regulatory, technical or service changes.

The current version will always be available on this website with its update date.

Cookie Policy

Last updated: 17/08/2026

At Connectoma Neurotech, S.L. (hereinafter, “Connectoma”), with Spanish tax ID B70752795 and registered office at Calle Padilla 26, 2.º, 28006 Madrid (Spain), we use cookies and storage technologies of similar functionality (hereinafter, “cookies”) on our corporate website and on the web Clinical Portal.

The purpose of this policy is to inform you transparently and in detail, in accordance with Regulation (EU) 2016/679 (GDPR), Spanish Organic Law 3/2018 (LOPDGDD), Spanish Law 34/2002 (LSSI-CE) and the guidelines in force from the Spanish Data Protection Agency (AEPD), about what a cookie is, what its purpose is on our platforms, which categories we use and how you can configure, accept or reject them.

Clinical safety clarification on data collection

Connectoma is a neurotechnology company focused on precision medicine in mental health. For IT and legal security reasons, we inform you that special category health data (Art. 9 GDPR) is NEVER collected, transmitted or stored through the cookies on this website. The cookies we use are limited exclusively to the technical management of the session, interface optimization, aggregated web performance metrics and, if you give your consent, the measurement and personalization of our advertising campaigns.

1. What are cookies?

A cookie is a small text file that websites download onto your terminal device (computer, smartphone or tablet) when you browse them. Cookies make it possible to remember information about your visit, such as your preferred language and technical options, in order to optimize the performance of the website, guarantee security and offer a personalized user experience.

Under the term “cookies” we also include other storage technologies of equivalent functionality that we use in the browser, such as local storage (localStorage) and session storage (sessionStorage), as well as third-party pixels or tags that set cookies on your device.

2. Classification and types of cookies used

A. According to the entity that manages them

  • First-party cookies: sent to your terminal directly from equipment or a domain managed by Connectoma.
  • Third-party cookies: sent from equipment or a domain managed by external collaborating entities (for example, Google, Firebase, Meta or LinkedIn).

B. According to how long they remain active

  • Session cookies: they collect and store data only while you browse the website, and are deleted when you close the browser.
  • Persistent cookies: the information remains stored on the terminal for a period defined by the controller, after which they stop working.

C. According to their technical purpose and legal basis

  • Technical cookies (strictly necessary): they enable operational browsing through the website, control traffic, identify the session and allow secure authentication through tools such as Firebase (Google Cloud). As they are indispensable for providing the service you request, they do not require your consent.
  • Preference or personalization cookies: they make it possible to remember information that changes the behavior or appearance of the website (such as the selected language). Where you are the one actively interacting to set them, they are exempt from consent.
  • Analytics or measurement cookies: they make it possible to measure the number of users on an aggregated basis and to statistically analyze the use of the content through Google Analytics 4. Their use requires your prior express consent (opt-in).
  • Advertising and marketing cookies — measurement: they measure the effectiveness of our advertising campaigns and attribute conversions on Google Ads, Meta (Facebook/Instagram) and LinkedIn. They require prior express consent.
  • Behavioral advertising and marketing cookies — personalization: they store information about your browsing habits in order to create interest profiles and show advertising about neuromodulation and technological advances on external networks (Google, Meta and LinkedIn), as well as to build audiences. They require prior express consent.

3. Declaration and actual cookie inventory

The cookies and storage technologies we use are set out below, grouped by category. Analytics cookies and advertising and marketing cookies are only set if you give your consent from the settings panel.

NameProvider / OriginOwnershipPurposeDurationType
__session / firebase_token *Firebase (Google Cloud)Third-partyAuthentication management, user session control and security of the Clinical Portal.SessionTechnical (necessary)
cookieConsent_v2ConnectomaFirst-partyStores your consent preference by category and the date you gave it. Saved in your browser’s local storage (localStorage).12 monthsTechnical (necessary)
attribution_v1ConnectomaFirst-partyKeeps the origin of the visit (campaign or referring page) so we can attribute any form you choose to send us. Saved in session storage (sessionStorage).Session (deleted when you close the tab)Technical (necessary)
lang_pref *ConnectomaFirst-partyStores the preferred language selected by the user.1 yearPreferences
_gaGoogle Analytics 4Third-partyAnonymous identifier that distinguishes unique users in order to count visits to the platform.2 yearsAnalytics
_ga_<container_id>Google Analytics 4Third-partyPersists session state in order to analyze browsing patterns on an aggregated basis.2 yearsAnalytics
_gcl_auGoogle AdsThird-partyMeasures the effectiveness of and attributes conversions from our Google Ads advertising campaigns.3 monthsAdvertising and marketing — measurement
_fbpMeta (Facebook/Instagram)Third-partyIdentifies browsers in order to measure campaigns and conversions on Meta (Facebook/Instagram).3 monthsAdvertising and marketing — measurement
li_sugrLinkedIn InsightThird-partyMeasures interactions and attributes conversions on our LinkedIn B2B campaigns.3 monthsAdvertising and marketing — measurement
lidcLinkedIn InsightThird-partyLoad balancing and session measurement for the LinkedIn Insight Tag.1 dayAdvertising and marketing — measurement
_fbcMeta (Facebook/Instagram)Third-partyStores the click identifier in order to attribute conversions and build audiences on Meta.2 yearsAdvertising and marketing — personalization
bcookieLinkedIn InsightThird-partyIdentifies the browser in order to build audiences and show relevant ads on LinkedIn.1 yearAdvertising and marketing — personalization

* Only used in the web Clinical Portal, which is reserved for clinical professionals. They are not set while browsing the corporate website.

4. Consent management, rejection and settings

In accordance with the AEPD guidelines, on your first visit to the website you will be shown a settings banner that allows you to Accept all, Reject all or Configure the use of cookies granularly, at the same visual level and on equal terms.

You can also withdraw your consent or change your preferences at any time through the cookie settings panel, permanently accessible in the footer of our portal and from the following button:

Connectoma uses Google Consent Mode v2. Signals are sent with per-category granularity: analytics cookies control analytics_storage; advertising and marketing — measurement cookies control ad_storage and ad_user_data; and advertising and marketing — personalization cookies control ad_personalization and personalization_storage. All signals are denied by default until you give your explicit consent.

Your decision is kept for 12 months, together with the date on which you gave it. Once that period has elapsed it expires automatically, we will show you the banner again, and no non-essential cookie will be set until you renew your consent.

Some site features may become unavailable if you reject certain cookies.

In addition, you can manage or delete cookies directly from your browser settings:

5. Changes and specialized contact

Connectoma may update this Cookie Policy in line with legislative requirements or technical changes to the platform.

To resolve any questions related to cookie management or to exercise your data protection rights, you can contact our Data Protection Officer (DPO) by writing to dpd@connectoma.com.