Neura Privacy Policy

Updated 10.16.2017


  • 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.
  • Neura enables products and service providers to deliver a personalized experience and functionality based on End User’s behavior, habits and activity.
  • Neura collects End User’s data from different sensors and APIs, after a Neura account was created for the 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 delivering personalized experiences to the End User.
  • We may share End Users’ non-personally identifiable data with those outside of Neura if they are a service provider for Neura (and have to follow our privacy policy) 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


  • Neura, Inc., a Delaware corporation (the “Company”, “we”, “us” or “our”) respects your privacy. 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 features enabled by the Neura SDK in a product they use that’s installed on their mobile device and visitors to the Neura Website or Developer site (“Visitors”) and forms an integral part of the Developer Terms and Conditions available at:
  • The Company controls, owns, and manages the information collected on the Website and through the 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.


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 Website 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 number and frequency of visitors to the Website, the URL that you just came from (whether this URL is on the Website or not), which URL you next go to (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. 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, and do 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 may 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.
  • Personal information provided by users/developers – Personal information is information that identifies individual End 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 Customers or End Users to provide personal information such as an e-mail address and/or 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 Services, 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) – 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 such as your activities, location and behavior in order to make a product or a service that you are using more personalized and contextually aware.
  • To do this Neura collects information about you through your devices, primarily, but not limited to, your mobile phone. 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).
  • We consider the raw data that is collected to be the property of Neura’s 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.
  • Data that is not collected by Neura –
  • Neura does not collect or hold any medical or health care related data and therefore does not handle any “protected health information” (PHI).


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


The raw data that is collected may be shared only with the following:

  • 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 Neura-related 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, we will obligate them to treat it at least as protectively as they treat information they obtain from their other users.
  • We do not disclose End Users personal data to third parties unless: (1) we are required to comply with a legal obligation or if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; 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 our business or assets, or parts of them, are acquired by a third party. Third parties will be bound by applicable data protection legislation and/or this privacy policy concerning the disclosed data.
  • Information that is generated by Neura may 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

Other Data Usage:

  • We may 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. They will only see the unique identifier number with the data.


  • 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.
  • 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.


  • To collect information about use of the Services Google Analytics collects 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 Services. 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, and the Google Privacy Policy, available at You may learn more about how Google collects and processes data specifically in connection with Google Analytics at 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


  • We may 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, and we do not combine information collected through cookies with other personal information.


  • You may delete your Neura account at any time to immediately stop any collection of data. You may also opt-out from any use of your personal information, including the disclosing to third parties or any of the purposed usages detailed in this privacy policy.
  • You may also opt-out from collection of your real-time location data through the OS settings of your device.
  • You have the right to access your personal data.
  • If you would like to do any of the actions described, you may submit a request by sending an email to Your email should include adequate details of your request.
  • 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 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 us (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 that you choose to use or interact with.


  • We regularly review our compliance with this Privacy Policy. We will disclose any security breach that has affected personal data within 24 hours. The information will be announced on our website:
  • 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 data that cannot be resolved between the Company and an individual or entity.


  • 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


  • 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.


  • 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: 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 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, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.


  • 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.


  • In the event that we are 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.


  • 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: or Neura Inc., 102 Persian Drive, Suite 203, Sunnyvale CA 94089, Attn: Legal.


  • We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Service.


  • 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


For any questions pertaining our privacy policy, please contact us:

Email –

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