Updates to Our Privacy Policy

We have updated our Privacy Policy effective March 27th, 2019. Learn More

Privacy Shield Notice

Updated 06.10.2020

Neura Inc. (“Neura Inc.”, “us“, “we” or “our”) has self-certified with the EU-US and Swiss-US Privacy Shield Frameworks with respect to the personal data of any individuals residing in the EU and Switzerland that we receive or process, including on behalf of any of our affiliated companies worldwide (collectively, “Neura Group”). To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov. Our Privacy Shield certification is available here.

Accordingly, Neura Inc. adheres to the principles of the EU-US and Swiss-US Privacy Shield Frameworks, as set forth by the US Department of Commerce regarding the collection, use, and retention of personal data transferred from the European Union and Switzerland to the United States (“Privacy Shield Principles”). If there is any conflict between this Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

1. Scope

Our participation in the Privacy Shield Frameworks applies to personal data that Neura Inc. receives from and processes on behalf of our customers, business partners or any other member of the Neura Group, which relates to data subjects residing in the EU or Switzerland.

In the event that the United Kingdom ceases being a Member State of the European Union, Neura Inc. will continue to adhere to the Privacy Shield Principles also with respect to the collection, use and retention of personal data transferred from the United Kingdom to the United States, or with any successor framework between the United Kingdom and the United States.

Neura Inc. acts as a sub-processor or processor of the personal data we process on behalf of our customers, business partners – who are each either the processor (where we act as sub-processor) or controller (where we act as processor) with respect to such personal data we process on their behalf.

2. Right to Access, Change or Delete Personal Data

EU and Swiss data subjects, as well as UK data subjects, have the right to access personal data about them, and in some cases to limit use and disclosure of their personal data. If you would like to request access to your personal data processed by us, or to limit use and disclosure of your personal data, please contact privacy@theneura.com and provide your name and contact information. If your request pertains to data processed on behalf of any of our customers, we will refer your request to them, and will support them as needed in responding to your request.

3. Onward Transfers of Personal Data 

We will not transfer personal data originating in the EU, Switzerland or UK to third parties unless such third parties have entered into a written agreement with us requiring them to provide at least the same level of privacy protection to such personal data as required by the Privacy Shield Principles. In cases of such onward transfer, Neura Inc. remains responsible and potentially liable, other than for events outside of its reasonable control.

Such third parties include selected companies and individuals that we have engaged to provide us with services complementary to our own, as further described in our Privacy Policy. These include cloud data hosting and delivery services, data and cyber security services, web analytics, content distribution and monitoring services, session or activity recording services, performance measurement, support and customer relation management systems, and our legal, financial and compliance advisors.

We may also engage in data transfers internally within the Neura Group, for the purposes described in our Privacy Policy.

4. Compelled Disclosures

Neura Inc. may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

5. Recourse Mechanism

In compliance with the Privacy Shield Principles, Neura Inc. is committed to resolve complaints about our collection or use of personal data. EU, Swiss and UK individuals with inquiries or complaints regarding our privacy practices should first contact Neura Inc. at privacy@theneura.com or by postal mail sent to:

Neura Inc.
Attn: Privacy Shield Inquiry
3101 Park Blvd.
Palo Alto, CA 94306,
USA

Neura Inc. has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles and the Swiss-U.S. 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. The services of JAMS are provided at no cost to you.

Neura further commits to cooperate with EU and UK data protection authorities (DPAs), and the Swiss Federal Data Protection and Information Commissioner (FDPIC), with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU, Switzerland and UK in the context of the employment relationship. Data Subjects with inquiries or complaints regarding this Privacy Shield Notice should first contact Neura at: privacy@theneura.com.

You may find the relevant contact details at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm or: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html

6. Enforcement

Neura Inc. is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) to ensure compliance with the Privacy Shield Principles outlined in this Notice.

7. Arbitration

Under certain conditions, more fully described on the Privacy Shield website, you may also be able to invoke binding arbitration when other dispute resolution procedures have been exhausted.