This privacy notice relates to Neura's publicly accessible website, developer tools and all services provided by Neura.
Neura collects user's data in two predominant ways: information that is given by end users directly and data that is collected independently by Neura through different sensors and APIs, after the user has created a Neura account and gave his explicit consent to this.
Collected data is distilled to information regarding users' behavior in real life (i.e. not the web). This information may be provided to a product/service provider via APIs only after the product/service providers state their intention to users and request granular permissions from the user based on a pre-defined value proposition that they plan on delivering the user in exchange for the information.
This authorization process is done via a dedicated Permission Layer that is provided by Neura.
We may share users' non-personally identifiable data with those outside of Neura if they are a service provider for Neura (and have to follow our instructions) or if we are legally required to share it with someone outside of Neura.
Neura has implemented appropriate technical and organizational measures to protect users' information.
If you want to ask how to delete or access your data, email email@example.com
Neura, Inc., a Delaware corporation (the "Company", "we", "us" or "our") respects your privacy.
In this section, we provide you with details about some of the information we currently collect about users of our Website and of our Services (collectively, "Users Data").
Navigation and Site information - Browsing the Neura websites does not require you to register for an account or provide any personal information to us. Generally, Neura will gather some generic non-personally identifiable information automatically. This generic information may include the Internet Protocol (IP) address assigned to your computer, the number and frequency of visitors to the Site, the URL that you just came from (whether this URL is on the Site or not), which URL you next go to (whether this URL is on the Site or not), your computer browser information, operating system, date/time stamps, click stream data and type of mobile device. Generic information does not reveal the identity of the visitor. This type of aggregate data may enable us to figure out how often users use parts of the Services, help us determine customer service and Site needs, and do internal analytics on users' demographics, interests, and behavior to better understand, protect and serve users and our community. Neura may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally.
We may analyze your use of the Website with third party software that allows us to monitor and record users' navigation and usage activities, in order to better customize and improve our Website, Services and other products.
Personal information provided by users/developers - Personal information is information that identifies individual users, whether directly or indirectly through the combination with other information held by Neura. In order for you to consume the Neura services, Neura may require you or your users to provide personal information such as an e-mail address and a phone number. The personal information provided may be used for such purposes as responding to your questions or requests, customizing the content you see, and communicating with you about new features. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities or postings on the Service, we may collect such information into a file specific to you. You agree that we may use your personal information to contact you as provided herein, though our intent is that email is the only channel we will use to contact you without your consent.
Data collected and analyzed through our SDK (Data collected automatically) - If you wish to become a Neura End User and by that make a product or a service that you are using more personalized and contextually aware, you would need to provide Neura explicit consent to collect and process information about your activities, location and behavior. Unless End Users provided Neura with explicit consent, we will not consume any personally identifiable information about the Neura End Users from the Neura Customers. Neura independently collects, stores and analyzes End Users data through its SDK.
We consider the data that is collected to be the property of Neura End Users. Neura operates on behalf of End Users to identify moments in the End Users' life via sensory activity from their smartphone or other connected devices in the event the End Users shared access to their data with Neura. All data collection is done through official APIs and mobile sensors, with the express permission of End Users.
Products and services that integrate Neura Services are required to directly seek permission from the End Users when they wish to employ the output from Neura Services and be notified regarding specific events, services or metrics in the End User's life. Only after End Users consent to share that information with the Customer, will Neura provide its events, services and metrics on behalf of the End User to the Customer so that the Customer's application can better serve the End User with a truly personalized experience.
To do this Neura accesses the following device sensors and services:
iOS – Wi-Fi, Bluetooth, accelerometer, gyroscope, magnetometer, GPS
Android – Wi-Fi, Bluetooth, accelerometer, gyroscope, magnetometer (where available), GPS, barometer (where available).
The Neura engine starts to collect data only after End Users have granted permissions through the Customer's mobile application. The data collection continues until the Neura Customer or End User proactively stops tracking from the phone or app settings.
Neura may store a pseudonymous Neura ID number on End Users devices that will be used for user profiling in order to provide a more personalized experience. For the avoidance of doubt, Neura defines pseudonymous data as personal data processed in such a manner that it can no longer be attributed to the End User without the use of additional information, which Neura keeps separately and subject to technical and organizational measures to this effect.
The data is uploaded from End Users phone over a secured connection to our servers that analyze the data and identify metrics and contextual information. Our system is able to analyze the raw data gathered and identify real time events, predict future events to the extent technologically possible and compose different types of End Users profiles. The results are sent back to the End Users mobile phone over a secured connection and/or stored in our servers.
We may use third party service providers to facilitate or outsource one or more aspects of our business and therefore we may provide some of your personal information directly to these service providers. These service providers are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific operations.
We may share non personally identifiable data about End Users with our partners and joint ventures in furtherance of our business. To the extent that these entities have access to this information, they will treat it at least as protectively as they treat information they obtain from their other users. Our partners and joint ventures follow privacy practices no less protective of all users than our practices described in this document, to the extent allowed by applicable law.
The connection between the product/service provider and Neura is made via APIs, and is governed by Neura's Permission Layer, through which Neura Customers state their intention and request granular permissions from their End Users based on a pre-defined value proposition that they plan on providing the End User in exchange for the information. End Users get authenticated directly against Neura's servers, and therefore the Customer's host app cannot intercept or control Neura's data flow.
A crucial part of Neura's model is control over the Permission Layer the End User experiences when asked to transmit data to a third party. As we believe in user-ownership and informed consent, Neura controls the Permission Layer interaction, relying on its own permission screen designed to make the data exchange proposition as clear as possible to the user.
We may use aggregated data over several users to improve our algorithms, measure service usage, publish summaries online or offline, and to develop new features such as recognizing popular activity routes, areas and places. We will not display or otherwise disclose information where individual users can be recognized. Furthermore, our developer team need to occasionally review raw data and the results for recognized activities/routes/places to improve the system. They will only see the unique identifier number with the data.
We do not advertise or support any advertising activity on our Website or through the Services and do not provide any End User or Customer data to advertisers or otherwise to third parties for the purpose of advertising or marketing.
The security of handling End Users data is extremely important to us. Neura has implemented appropriate technical and organizational measures to protect information against accidental loss, unlawful destruction, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing.
Neura takes reasonable steps to ensure that any personal information in its possession is accurate, complete, current and reliable for its intended use.
Neura uses a hybrid analysis solution, prioritizing some of the analysis to our mobile engine located in the SDK, and off-loading other data for processing to Amazon's S3 infrastructure. Neura uses Amazon's Virtual Cloud and segmented network to prevent external access.
We store the data in multiple and different types of databases: S3, relational Database, No-SQL document database and Graph database. The data is distributed over multiple databases and each database holds only fragments of the data. Additionally sensitive data is hashed or encrypted in order to protect the data itself.
The data is kept for limited time in databases in order to reduce any large scale risks. All databases are protected by Amazon security countermeasures like any other Amazon customers data.
We use third party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to provide the Services. These are located outside our offices. We use commercially reasonable physical and technical safeguards to secure your data.
You may delete your Neura account at any time to immediately stop any collection of data. You may also opt-out from collection of your real-time location data through the OS settings of your device.
Neura will delete your personal information upon deletion of your account (unless a longer retention period is required by law). Non-personal information may be retained without limitation in time.
The Company complies with the U.S. – EU and U.S. – Swiss Safe Harbor frameworks as set forth by the United States Department of Commerce regarding the collection, use and retention of data from the European Union and Switzerland. The Company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view the Company's certification, please visit https://www.export.gov/safeharbor.
The Company has further committed to refer unresolved privacy complaints under the U.S. – EU and U.S. – Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgement of your complaint, or if your complaint is not satisfactorily addressed by the Company, please visit the BBB EU SAFE HARBOR website at https://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: firstname.lastname@example.org or Neura Inc., 102 Persian Drive, Suite 203. Sunnyvale CA 94089, Attn: Legal.
The Neura products and Services are not intended for use by children. If you are under 18, you may use Neura only with the involvement and consent of a parent or guardian. We do not knowingly or intentionally collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not attempt to register for any of the Neura services or products or send any personal information about yourself to us without the explicit consent of your parent or your legal guardian. If we learn that we have collected personal information from a child under age 13 without the above mentioned consent, we will permanently delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at email@example.com
Email - firstname.lastname@example.org
Mail - Neura Inc. 102 Persian Drive, Suite 203, Sunnyvale 94085, CA, USA