“Visitors” that visit or interact with our company website or any of our websites, online ads and content, emails or communications under our control (“Sites”);
“Customers” who have engaged with us, or “Prospects” who might be interested in engaging with us;
Once you chose to use our Services, or our customer’s products powered by our SDK, you need to provide us with your personal data, as explained in this Policy. You may also choose to request to delete or opt-out of certain processing activities (see Section 8), but please keep in mind that limiting our processing may also result in us not being able to provide you with the full range of our Services or with the best user experience when using our Services.
1. Data Collection
We collect data regarding our Visitors and Prospects, as well as on our Customers, Developers and their End-users. Such data is typically collected and generated through their interaction with our Services, through automatic means, directly from them, from our Customers, or from other third parties.
Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, will be deemed as “Personal Data“):
a. Data automatically collected or generated: When you visit, interact with or use our Services, we may collect or generate certain technical data about you. We collect or generate such data either independently or with the help of our service providers (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below).
Such data mainly consists of connectivity, technical and aggregated usage data, such as IP addresses, non-identifying data regarding a device, operating system, browser version, date/time stamps, click stream data and type of mobile device, locale and language settings used, the cookies and pixels installed on such device and your activity (clicks and other interactions)
b. Data received when you contact us: you may contact us for support, learning more about our Services and offerings, or for any other reason. In doing so, you will provide us Personal Data such as your name, email, workplace and position and any other data you choose to provide or that we may require in order to properly review your inquiry. Similarly, you can provide us with your Personal Data when you attend our events or contact us via social media (such as LinkedIn, Twitter or Facebook).
c. Data received from Developers: When you create an account on our Services as a Developer, you will provide us with Personal Data such as your name, contact details (such as e-mail, phone and address), account login details (such as username and hashed passwords), workplace and position, geolocation and free-form description.
d. Data received from third parties: we may receive your Personal Data from other sources. For example, if you participate in an event or webinar that we sponsor or participate in, we may receive your Personal Data from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our service providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn.
e. Data received from End-users: when End-users are using a product powered by our SDK, we will collect Personal Data and raw sensory data from their devices – in real time at the physical environment around the device. This consists of the following types of data: device ID, geolocation (such as location changes and geofencing), Bluetooth, WiFi and other sensors (connection and devices), device state (i.e. power on / off, battery saver, charger status etc.), the End-users’ various engagements and other technical data such as device model and OS. The data will be collected and used only when needed based on our machine learning algorithm and as configured or instructed by our Customer, after which it is transformed to general insights regarding the Customer’s End-users’ real-life behaviors – which are made available to our Customer via an API.
f. Data received from Customer in the context of Virusafe: when a data subject is using Virusafe, the Customer will send us a request to provide COVID-related information from specific places. This consists of the following types of data: latitude and longitude coordinates. Please note that this data is non-identifiable information. In other words, we cannot recognize or identify you by receiving this data
2. Data Uses
We use Personal Data as necessary for the performance of our Services; to comply with applicable law; and to support our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, optimizing our marketing, advertising, customer service and support operations, and protecting and securing the data subjects, ourselves and our Services, as well as members of the general public.
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA).
Specifically, we use Personal Data for the following purposes:
To facilitate, operate, and provide our Services;
To authenticate the identity of our Developers, and to allow them access to our Services;
To provide our Developers, Visitors, Prospects and Customers with assistance and support;
To gain a better understanding on how individuals use and interact with our Services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
To contact our Customers, Developers and Prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section 6 below);
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
To facilitate, sponsor and offer certain events, contests and promotions;
To support and enhance our data security and content compliance measures, including for the purposes of preventing and mitigating the risks of fraud, abuse, error or any illegal or prohibited activity;
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
To comply with any applicable laws and regulations.
With respect to End-users, we use their Personal Data solely (some of which may be anonymized) for the following purposes, and solely on behalf of our Customer (see Section 9 below):
to measure and improve the performance of our Services;
to provide our Customers with insights regarding their End-users’ behaviors; and
to provide our Customers and their End-users with recommendations for real-time engagement and activities.
3. Data Location & Retention
Data Location: We and our authorized affiliates and Service Providers (defined below) maintain, store and process Personal Data in the United States of America, Europe, Israel, and other locations, as necessary for the proper performance and delivery of our Services, or as may be required by law.
Neura Labs Ltd is headquartered in Israel, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for processing the Personal Data of EU Member State residents.
Data Retention: We typically retain End-users’ Personal Data during our business relationship with the Customer whose product they were using, and for an additional period following the termination or expiration their subscription as long as this is necessary in order to provide the Services to the Customer or otherwise to comply with our obligations. In the event that an End-user has requested to delete their Personal Data, all Personal Data will be deleted or de-personalized.
We keep Personal Data concerning our Visitors, Developers, Customers and Prospects for as long as reasonably necessary in order to maintain and expand our relationship, and to provide them with our Services.
We will also retain your Personal Data for as long as required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our internal data retention policy.
Please note that except as required by applicable law, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by email at email@example.com
4. Data Sharing
Legal Compliance: We may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
We may disclose insights that are based on anonymized and aggregative data to government and law enforcement officials as part of our COVID 19 products.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting services, data analytics services, ETL-data processing and queue management, marketing and advertising services, data and cyber security services, payment processing services, user engagement services, e-mail distribution and monitoring services, text messaging services, session recording, and our business, legal, compliance and financial advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes. We have obtained contractual commitments from our Service Providers to protect your Personal Data, where necessary. Some of these commitments include the EU-U.S. and Swiss-U.S. Privacy Shield for the protection of Personal Data transferred from within the EU-Switzerland to the United States, or have ensured that other lawful mechanisms are in place prior to initiating such transfers.
Sharing End-user Data with our Customers: We may share the Personal Data of End-users with the Customer whose SDK-powered product they are using, primarily in order to provide them with insights about their End-users’ activity and the best time during the day to approach them.
Protecting Rights and Safety: We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Neura, any of our Customers or data subjects, or any members of the general public.
For the avoidance of doubt, Neura may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
5. Cookies and Tracking Technologies
Our Services (including some of our Service Providers) utilize “cookies”, anonymous identifiers, container tags and other technologies in order for us to provide our Services and ensure that they perform properly, to analyze our performance and marketing activities, and to personalize your experience. Such cookies and similar files or tags may also be temporarily placed on your device. Certain cookies and other technologies serve to recall Personal Data, such as an IP address.
Service Communications: We may contact you with information regarding our Services. For example, we may notify you (through any of the means available to us, e.g. phone, mobile, web notifications or e-mail) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. Typically, you will not be able to opt-out of receiving such service communications while using our Services, as they are integral to such use.
Notifications and Promotional Communications: We may send you notifications, messages and other updates about new features, offerings, events and special opportunities or any other information we think you will find valuable. This also includes our newsletter and any other promotional materials. We may provide such notices through any of the contact means available to us, through the Services, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Neura at any time by changing your communications preferences in your account, by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive, or by sending an email to firstname.lastname@example.org. Please note that even if you unsubscribe or opt out of receiving our promotional communications, we will still send you a response to any “Contact Us” request.
7. Data Security
In order to protect your Personal Data, Neura has implemented numerous safeguards, including:
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;
We use 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;
Personal Data is kept for a 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.
That said, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
8. Data Subject Rights
If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as the right to request access to, and rectification or erasure of your Personal Data held with Neura, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or to opt-out of the sale of your personal information (each to the extent available to you under the laws which apply to you) – please contact us by email at email@example.com.
Please note that once you contact us, we may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 3 above.
If you would like to make any requests or queries regarding Personal Data that we process on our Customer’s behalf, please such Customer directly. For example, if you are an End-user of our Customer and wish to access, correct, or delete data processed by Neura on behalf of such Customer, please direct your request to them (as they are the “data controller” of such data – see Section 10 below). Note that if you do contact us, we may share your communications with our Customer and its representatives; and that we may also share the contact details of the Customer and its representatives with individuals who sent us such a request or query relating to their account.
9. Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Neura is typically the “data processor” of End-users’ Personal Data, which we process on behalf of our Customer (who is the “data controller” of such data), in accordance with its reasonable instructions, subject to our Terms, our Data Processing Agreement with such Customer (to the extent applicable) and other commercial agreements. In such case, our Service Providers who process such data on our -and- our Customer’s behalf are the “sub-processors” of such data.
Our Customer, as the controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control). Each Customer is solely responsible for providing adequate notice to their End-users whose data may be processed by Neura on their behalf; and to obtain all approvals and consents from such individuals as required under applicable laws.
If you would like to make any requests or queries regarding Personal Data we process on our Customer’s behalf, please contact such Customer directly.
10. Additional Notices
Children: Our Services are not designed to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by email at firstname.lastname@example.org.
EU Representative: VeraSafe has been designated as Neura’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. VeraSafe may be contacted only on matters related to the processing of Personal Data. To make such an inquiry, please contact VeraSafe through this contact form.
If you are a GDPR-protected individual, you also have the right to lodge a complaint with an EU supervisory authority.
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