This privacy notice relates to Neura’s publicly accessible Website, developer tools and all Services provided by Neura. Section 3 summarizes basic aspects of Neura’s data collection practices as they apply to different groups.
Neura enables products and service providers to deliver personalized experiences to their users based on an End User’s behavior, habits, and activity.
Neura collects End User’s data from different sensors after a Neura Account is created for the End User.
Collected data is transformed to information regarding the End User’s real-life behavior. This information may be provided to a product or a service provider via APIs to allow the delivery of personalized experiences to the End User.
We share End Users’ data with those outside of Neura if they are a service provider for Neura (and provide equivalent protection), in cases we are legally required to share it with someone outside of Neura, or to provide our services as detailed in this policy.
Neura has implemented appropriate technical and organizational measures to protect End Users’ information.
If you would like to access your data, or restrict or delete your Neura Account, email us at email@example.com
The Company controls and manages the information collected on its Website and through its Services. The Company is committed to ensuring that End Users’ or Visitors’ Personal Information shared over our Website and/or Services is protected and kept confidential.
WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
This section outlines data collection and usage by identified groups. They are:
Visitors of Neura’s Website or Devsite
Data Collected: Cookies (read more about cookies below), IP address, email address (only for registered uses on the devsite), and geolocation information that is used to confirm compliance with Export Control regulations.
Why is the data collected and for what purposes? To determine if the information provided on the website and developer site is of value to our visitors.
Legal basis: Our legitimate interests, including our interests in improving the Website and the Services.
Third Parties with whom we Share Data: Analytics tools.
Consequences of not providing data: May not be able to find the most relevant information on the Neura Website or Devsite.
Data Collected: Name, Surname, Email, Phone number, IP address, Country, and Company.
Why is the data collected and for what purposes? To identify the developer, offer secure services, and for contact details.
Legal basis: We process your Information as necessary to conduct pre-contractual discussions, or consistent with your consent.
Third Parties with whom we Share Data: Hosting companies such as Amazon Web Services and CRM and marketing automation platforms
Consequences of not providing data: Developer will not be able to add Neura’s functionality to their product or service.
Data Collected: Name, Surname, Email, Phone number, Position, and Company.
Why is the data collected and for what purposes? To communicate with customers and provide the Services.
Legal basis: We process your Information as necessary to conduct pre-contractual discussions and to fulfil our contractual obligations, or consistent with your consent.
Third Parties with whom we Share Data: CRM and marketing automation platforms.
Consequences of not providing data: Developer will not be able to add Neura’s functionality to their product or service or communicate with Neura’s team.
Potential Customers (aka Leads)
Data Collected: Name, Surname, Email, Phone number, Position, and Company.
Why is the data collected and for what purposes? To respond to requests and to provide ongoing communication with potential customers who have requested information and for direct marketing (see below).
Legal Basis: Pre-contractual discussions and legitimate interest. Direct marketing is done with consent.
Third Parties with whom we Share Data: Analytics tools such as Google Analytics (read more below), and CRM and marketing automation platforms (i.e., Salesforce, Hubspot, Drift, and Zendesk).
Consequences of not providing data: We will not be able to respond to requests and communicate with the potential customers. Potential Customers will not be able to learn the full capabilities of Neura Product and Services and how they related to the potential customer.
Data Collected: Device id, Location data, Wifi mac address, and sensory data. Data is collected through Neura’s SDK that is integrated in mobile applications.
Why is the data collected and for what purposes? Authenticating and identifying users and providing services in a secure manner.
Legal Basis: consent and contractual relationship.
Third Parties with whom we Share Data: Hosting companies such as Amazon Web Services, Consultants performing services on our behalf, Neura Customers when an End user uses one of its Neura-enabled products (Neura customers may receive only User insights and are not exposed to the raw data). Aggregated data can be shared with business Partners.
Consequences of not providing data: Neura’s customer (mobile app) will not be able to provide the entire Neura-enabled personalization capabilities to the End User.
Additional information is provided below.
In the following paragraphs, we provide you with more details about the information we currently collect about users of our Website and of our Services (collectively, “Users’ Data”).
We analyze your use of the Website with third party software that allows us to monitor and record visitors’ navigation and usage activities, in order to better customize and improve our Website, Services and other products. Tracking of IP addresses also assists in keeping within compliance of US export regulations in relationship to restricted use in certain geo-locations.
Website and Developer Site forms (Personal Information Provided by Users/Developers) – Neura uses forms on both its Website and Developer Site for Visitors to voluntarily submit identifying information (first name, last name, company, job title, telephone number, and email address) so they can begin a relationship with Neura. The Personal Information provided shall be used for the purposes of providing company collateral, creating a developer account, providing integration and other support assistance, connecting you with a sales person regarding the Neura Product capabilities, 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 Services, we will collect such information into a file specific to you. Be informed that we may use your Personal Information to contact you as provided herein.
Data collected and analyzed through our SDK (Data collected automatically) – Neura independently collects, stores, and analyzes End Users’ data through its SDK.
By using a Neura-enabled product, be informed that Neura collects and processes information about your activities, location, and behavior in order to allow the product or service that you are using to be personalized and contextually-aware.
To do this Neura collects information about you through your devices and accesses the following device sensors and services:
Raw data from the various data channels, including the iOS or Android channels listed above, is uploaded from an End User’s 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 situations and moments, predict future moments, and compose behavioral profiles and user personas. Personas are machine learning generated user profiles that represent each user’s real-world behavioral traits.
Neura’s customers are able to consume the data generated by Neura in two predominant ways:
Insights dashboard – A dashboard showing aggregated data about users’ real-world behavior and how they interact with the customer’s application in their real lives.
Neura Actions – Insights from the data analysis are sent to the customers via APIs or through integrations with MEPs and CRMs, allowing them to deliver contextually-relevant, real-time interactions and personalized customer experiences, at scale.
We will generally retain information collected for direct marketing purposes for a period of three years from their date of collection or our last contact with you, and information collected for performance of our contractual obligations for a period of five years following the end of the commercial relationship. In some circumstances we may store your Personal Information for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax, or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.
HOW WE SHARE YOUR PERSONAL INFORMATION
Personal Information that is collected will be shared only with the following:
We use third party service providers and consultants to facilitate or outsource one or more aspects of our business and therefore we provide some of your Personal Information directly to such service providers and consultants working on our behalf. They 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 Neura-related operations. For example, we share your Personal Information with hosting companies, with CRM companies, and with companies for ETL-data processing and queue management purposes. Some of these recipients are in the EU, the US, or Israel. We have obtained contractual commitments from them to protect your Personal Information. Some of these assurances are well recognized certification schemes like the EU-U.S. and Swiss-U.S. Privacy Shield for the protection of Personal Information transferred from within the EU to the United States or have executed Standard Contractual Clauses.
We share aggregated, 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, we have obligated them to treat it at least as protectively as they treat information they obtain from their other users.
We disclose Personal Information to third parties as follows: (1) To the extent necessary, with regulators and other governmental agencies, to comply with all applicable laws, regulations, rules, and requests of law enforcement, or if required to do so by court order; enforce our Developer Terms and Conditions, including investigations of potential violations thereof; detect, prevent, or otherwise address fraud or security issues; or protect against harm to the rights, property or safety of Neura, yourself or the public; or (2) If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets.
Information that is generated by Neura after the processing of the raw data will be shared with third parties that are Neura’s Customers in order to provide End Users with enhanced personalized experiences. Neura Customers will be notified regarding specific situations and moments in the End User’s life, or behavioral profiles of the End Users according to the services they have subscribed to. The connection between the product/service provider and Neura is made via APIs or through MEPs and CRMs.
In order to receive Neura Services that include information that Neura considers as more sensitive Personal Information, Neura’s Customers are required to receive permission from the End Users and state their pre-defined value proposition that they plan on providing the End User in exchange for the information. Only after End Users’ consent to share that information with the Customer, will Neura provide this specific kind of information 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 learn more about which information is shared with our Customers only after receiving your permission, please contact us at firstname.lastname@example.org.
Other Data Usage:
We use aggregated data over several End 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 End Users can be recognized. Furthermore, our developer team needs to occasionally review raw data and the results for recognized activities/routes/places to improve the system. If this review is necessary, they will only see the unique identifier number with the data.
HOW WE PROTECT AND STORE YOUR PERSONAL INFORMATION
The security of handling Personal Information 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.
Among other measures:
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.
All mobile-server communication and server-server communication that involves personal data are encrypted (SSL). Data in rest that is considered personal is encrypted.
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 customer’s data.
In accordance with Section 3, we will use your Personal Information to let you know about our Products and Services that we believe will be of interest to you. We will contact you, after having obtained your consent where legally required, by email or telephone or through other communication channels. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.
At any time, you may request that direct marketing to you is stopped. This can be done in two ways, first, by clicking the ‘unsubscribe’ link found at the bottom of all marketing emails, your request will be immediately submitted. Alternatively, you can request to be removed from specific types of emails by contacting us at email@example.com. Please specify whether you would like us to stop all forms of communication from Neura or just a particular type (e.g., email).
Check your individual browsers to change the way your browsers manage cookies.
We recommend you routinely review the Privacy Policies and preference settings that are available to you on any social media platforms as well as your preferences within your Account.
You may choose not to receive future promotional, advertising, or other Service-related emails from us by selecting an unsubscribe link at the bottom of marketing emails that we send. You may also send an email to firstname.lastname@example.org requesting to opt out of specific communications. If you choose to opt out via this method, specify which types of communications to which you are requesting to opt out (i.e. emails). Please note that even if you opt out of receiving the foregoing emails, we will still send you a response to any “Contact Us” request as well as administrative emails (for example, in connection with a password reset request) that are necessary to facilitate your use of the Site and/or Service. Also note that if you use a new computer, upgrade, or change web browsers or take any action which results in the deletion of the “opt out” cookie, you will need to perform this opt-out process again upon any such change.
The following rights (which may be subject to certain exemptions or derogations), shall apply in addition to the above to users of the Website who are protected by the GDPR:
You have a right to access information held about you. Your right of access will normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
You have the right to revise your Personal Information by editing your Account details, or request that we amend any Personal Information we hold that it is inaccurate or misleading.
You have the right to request the erasure of the Personal Information that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise, or defense of legal claims;
You also have the right, in certain circumstances, to receive your Personal Information in a machine-readable format or to request transmission of those information to another controller;
You have the right to object to or to request restriction of the processing. However, there may be circumstances in which we are legally entitled to refuse your request;
You have the right to data portability;
You have the right to object to profiling in certain circumstances;
You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work, or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority.
You have the right to withdraw your consent when processing of your Personal Information is based on such consent. Neura will comply with your request to withdraw your consent unless it contradicts with a circumstance in which we are obligated to continue processing your data, such as if the processing is required to meet our legal and regulatory obligations.
You also have a right to request details of the basis on which your Personal Information is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
You can exercise your rights by contacting us at email@example.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes before disclosing the Personal Information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.
In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality owed to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS
U.S. – EU AND U.S. – SWISS PRIVACY SHIELD
ACCOUNTABILITY FOR ONWARD TRANSFER
We will not transfer Personal Information originating in the EU or Switzerland to third parties unless such third parties have entered into an agreement in writing with us requiring them to provide at least the same level of privacy protection to your Personal Information as required by the Principles of the EU-US and Swiss-US Privacy Shield Frameworks or via Standard Contractual Clauses. In cases of onward transfer to third parties of data of EU or Swiss individuals received pursuant to the EU-US and Swiss-US Privacy Shield, Neura is potentially liable.
PRIVACY SHIELD INDEPENDENT RECOURSE MECHANISM, FEDERAL TRADE COMMISSION JURISDICTION
binding arbitration when other dispute resolution procedures have been exhausted.
TRANSFERS TO OTHER THIRD COUNTRIES
Your Personal Information may be accessed from Israel on the basis of the Commission Adequation Decision of 31 January 2011 (2011/61/EU).
MERGER, SALE AND BANKRUPTCY
In the event that Neura is acquired by or merged with a third-party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Information and any other information you provided us in connection with the foregoing events.
YOUR CALIFORNIA PRIVACY RIGHTS
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 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.
OUR CALIFORNIA DO NOT TRACK NOTICE
Neura does not track consumers across third party websites and therefore do not respond to Do Not Track signals. We also do not use third parties to collect personally identifiable information about an individual consumer’s online activities across different websites when a consumer uses the Neura Services.
USERS UNDER THE AGE OF 18
The Neura Products and Services are not intended for use by children. If you are under the age of 18, you may use Neura only with the involvement and consent of a parent or a 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. If you believe that a child under 13 may have provided us personal information, please contact us at email@example.com.
Mail – Neura Inc. 102 Persian Drive, Suite 203, Sunnyvale 94089, CA, US
REPRESENTATIVE IN THE EU
VeraSafe has been appointed as Neura’s representative in the European Union for data protection matters, pursuant to Article 27 of the General Data Protection Regulation of the European Union. VeraSafe can be contacted only on matters related to the processing of personal data. To make such an inquiry, please contact VeraSafe using this contact form: https://www.verasafe.com/privacy-services/contact-article-27-representative or via telephone at: +420 228 881 031.