Neura Privacy Policy

Updated 05.24.2018

SUMMARY

For a detailed review of Neura’s Privacy Policy please read the full version below.

  • 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 a personalized experience and functionality based on an End User’s behavior, habits and activity.
  • Neura collects an End User’s data from different sensors and APIs, after a Neura Account is created for the End User.
  • Neura collects End 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 a Neura Account was created for the user.
  • Collected data is distilled to information regarding End User’s behavior in real life. 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’ non-personal data with those outside of Neura if they are a service provider for Neura (and provide equivalent protection) or in cases we are legally required to share it with someone outside of Neura.
  • Neura has implemented appropriate technical and organizational measures to protect End Users’ information.
  • If you would like to access your data, or restrict your Neura Account, email us at privacy@theneura.com

GENERAL

Neura, Inc., a Delaware corporation (the “Company”, “we”, “us” or “our”) respects your privacy and is the “data controller” with respect to the information collected as described in this Privacy Policy. This Privacy Policy describes our privacy practices regarding the collection, use, and disclosure of your information through Neura’s website (the “Website”), developer tools, SDK, API services and other services (collectively, the “Services”).

This Privacy Policy (“Privacy Policy”) applies to the Services and describes the information we collect, how we use it, with whom we share it, our compliance with the U.S. – EU and U.S. – Swiss Privacy Shield, and other related matters.

This Privacy Policy covers both Neura Customers (“Customer” or “Customers”) who integrate the Neura SDK into their products, Neura End Users (“End User” or ”End Users”) who use products enabled by the Neura SDK and visitors to the Neura Website or Developer site (“Visitors”).

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.

This Privacy Policy is adhered by Neura Inc. and its subsidiary Neura Labs, Ltd.

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 Website or Devsite

  • Data Collected: Cookies (read more about cookies below), IP address, email address (only for registered uses on the devsite) as well as geolocation information that is used to confirm compliance with EULA restrictions.
  • 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
  • Third Parties with whom we Share Data:  Analytics tools such as Google Analytics (read more below)
  • Consequences of not providing data: May not be able to find the most relevant information on the Neura Website or Developer site

Developer Accounts

  • Data Collected: Name, Surname, Email, Phone number, IP address, Country, Company
  • Why is the data collected and for what purposes?: To identify the developer and offer secure service and for contact details
  • Third Parties with whom we Share Data:  Hosting companies such as Amazon Web Services
  • Consequences of not providing data: Developer will not be able to create Neura-enabled product or service

Customers

  • Data Collected: Name, Surname, Email, Phone number, Position, Company
  • Why is the data collected and for what purposes?: To communicate with customers and provide the Services
  • Third Parties with whom we Share Data:  CRM and marketing automation platforms (e.i., Salesforce or HubSpot)
  • Consequences of not providing data: User will not be able to create Neura-enabled product or service

Potential Customers (aka Leads)

  • Data Collected: Name, Surname, Email, Phone number, Position, 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 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), CRM and marketing automation platforms (e.i., Salesforce or HubSpot)
  • Consequences of not providing data: Will not be able to respond to requests and communicate with the potential customers. Will not be able to learn the full capabilities of Neura Product and Services and how they related to the potential customer.

End Users

  • Data Collected: Device id, Phone number, Location Data, Wifi mac address
  • Why is the data collected and for what purposes?: authenticating and identifying user and providing services In a secure manner.
  • Legal Basis: consent
  • Third Parties with whom we Share Data:  Hosting companies such as Amazon Web Services; Consultants performing services on our behalf, Neura Customers that an End – user uses one of its Neura enabled products, Aggregated data can be shared with business Partners
  • Consequences of not providing data: User will not be able to experience the personalization of a Neura-enabled product or service

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”).

  • Navigation and Website information – Browsing the Neura Websites does not require you to register for an Account or provide any Personal Information. Generally, Neura will gather some generic non-personally identifiable information automatically through the use of cookies. This generic information includes the number and frequency of visitors to the Website, the URL from which you just came (whether this URL is on the Website or not), your existing URL (whether this URL is on the Website 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, but will be associated with a user if a Website or Developer form is submitted (See Website and Developer Form section below). This type of aggregate data may enable us to figure out how often visitors use parts of the Services, help us determine customer service and Website needs, as well as for internal analytics on visitors’ 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 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 receiving company collateral, creating a developer account, receiving integration and other support assistance, speaking 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. You agree 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, you allow Neura to collect and process information about your activities, location and behavior in order to make a product or a service that you are using more personalized and contextually aware. Neura-enabled products and services access specific moments in an End Users day through API calls. Neura does not share End Users’ raw data.

To do this Neura collects information about you through your devices and accesses the following device sensors and services:

  • iOS – WiFi, Bluetooth, accelerometer, gyroscope, magnetometer, GPS.
  • Android – WiFi, Bluetooth, accelerometer, gyroscope, magnetometer (where available), GPS, barometer (where available).

 

 

DATA ANALYSIS

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. The results are sent back to the End User’s mobile phone over a secured connection and/or stored in our servers.

RETENTION

Neura may retain Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy.

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 (like Amazon), with CRM companies (like Salesforce or HubSpot), and with companies for ETL-data processing and queue management purposes. Some of these recipients are in the EU, the US or Israel. We will obtain contractual commitments from them to protect your Personal Information. Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Information transferred from within the EU to the United States.
  • We 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, we will obligate 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, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies 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 personal 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.
  • 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 privacy@theneura.com.

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. 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.

 

Important Note: Neura Customers and End Users need to protect against unauthorized access to their passwords and to their computers or mobile phones by signing off once they have finished using a shared computer. You are responsible for all actions taken with your Customer and End User ID and password, if relevant. Therefore, we recommend that you do not disclose your passwords to any third parties. If you choose to share your ID and password or your Personal Information with third parties, you are responsible for all actions taken with your account and therefore you should review that third party’s Privacy Policy. If you lose control of your passwords, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf such as if someone used your User and ID passwords to forward libelous material through the Services. Therefore, if your passwords have been compromised for any reason, you should immediately change them.

GOOGLE ANALYTICS

To collect information about use of the Services, Google Analytics is used to collect information such as how often Visitors visit the Website, what pages they visit when they do so, and what other sites they used prior to coming to the Neura Website or Developer site. We use the information we get from Google Analytics to maintain and improve the Website and our Products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to and use of the Website is restricted by the Google Analytics Terms of Services, available at http://www.google.com/analytics/terms/us.html, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

COOKIES

We send one or more “cookies” to Visitors’ computers through the Web browser. A cookie is a small file containing a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Any use of cookies by us will be solely for the purposes of improving the quality of access to the Website by storing visitors’ preferences, and tracking visitors’ trends, such as how people use the Website, and their site access preferences. Cookies tell us how and when pages in our Website are visited and by how many people. We use cookies to allow Visitors to enter login information less frequently. To the extent Neura uses cookies, such cookies do not collect Personal Information but may be combined with Personal Information (first name, last name, company, job title, telephone number and email address) if a Website or Developer Registration form is submitted by the user. We are committed to giving you the opportunity to exercise your choice of opting out from our collection of such non-personal information. For removing cookies and other technologies used on our Website, please refer to the “Opting Out” section below.

DIRECT MARKETING

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 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, you 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 contact us at marketing@theneura.com. Please specify whether you would like us to stop all forms of communication from Neura or just a particular type (e.g., email); and

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.

OPTING OUT

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 marketing@theneura.com 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.

YOUR RIGHTS

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 is 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;
  • 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 object to profiling;
  • 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.
  • The right to withdraw your 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 privacy@theneura.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

The Website and/or Services may enable you to interact with, or contain links to, other third-party websites, mobile software applications, and services that are not owned or controlled by Neura (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services may collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and Privacy Policy of each Third Party Service with which you choose to use or interact.

ENFORCEMENT

We regularly review our compliance with this Privacy Policy. We will disclose any security breach that has affected Personal Information within 24 hours. The information will be announced on our website:  www.theneura.com.

Please let us know of any questions or concerns you may have regarding this Privacy Policy or our compliance with this Privacy Policy by contacting our Privacy Officer at the email address in the Contact Information section. When we receive formal written complaints, it is our policy to contact that complaining user regarding his/her concerns. We will cooperate with the appropriate regulatory authorities to resolve any complaints regarding the transfer of Personal Information that cannot be resolved between the Company and an individual or entity.

U.S. – EU AND U.S. – SWISS PRIVACY SHIELD

The Company complies with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union and Switzerland to the United States. The Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

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. 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

In compliance with the EU-US and Swiss-US Privacy Shield Principles, Neura commits to resolve complaints about your privacy and our collection or use of your personal information. European Union and Switzerland individuals with inquiries or complaints regarding this Privacy Policy should first contact Neura at: privacy@theneura.com. Neura has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to JAMS, a non-profit alternative dispute resolution provider located in the United States to assist with the complaint resolution process. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.jamsadr.com/eu-us-privacy-shield for more information and to file a complaint.

Neura is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) to ensure compliance with the EU-US and Swiss-EU Privacy Shield principles outlined in this Privacy Policy. Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

CHANGES TO OUR PRIVACY POLICY

We reserve the right to alter our Privacy Policy at any time. We will notify you of any alterations with at least a full calendar weeks’ notice using one or more of the following channels – through the service, by email or via our Twitter and Facebook accounts. If you do not agree to the altered Privacy Policy, you will not be bound by it if you stop using Neura before the alterations become effective.

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 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: privacy@theneura.com 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 privacy@theneura.com.

CONTACT

For any questions pertaining our Privacy Policy, please contact us:

Email – privacy@theneura.com

Mail – Neura Inc. 102 Persian Drive, Suite 203, Sunnyvale 94089, CA, US

Data Protection Officer – Gali Sokol Kamerman, gali@theneura.com