Privacy policy

At Neural Earth Inc and its subsidiaries and affiliates (jointly, the “Company”), accessible from https://www.neural.io, other affiliated websites, or through its mobile applications (collectively, the “Platform”), one of our main priorities is the privacy of our visitors. This Privacy Policy contains types of information that are collected and recorded by Neural and how we use that information.

This Privacy Policy is applicable to any activities a visitor engages in while on the Platform (however, those applications, products and services may contain additional information regarding your privacy rights).

If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us; our contact information is on the Platform.

Consent

By using the Platform and/or making an account for any application, product, or service on the Platform, you consent to our Privacy Policy and agree to its terms.

Information we Collect

We may collect the following Personal Information about you:

Your name;
A copy of or information from your government-issued identification document;
Your address;
Your business’s name, address, website and phone number;
Your phone number;
Your email address;
Your date of birth;
Your Social Security or tax identification number;
Your IP address;
Your financial transaction history (including your bank account information);
“Protected health information” (as defined by our HIPAA Notice of Privacy Practices); and
Any other personal information you provide to us which we believe is necessary to maintain a customer account or provide a full experience of the Platform.

The Personal Information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your Personal Information or otherwise consent to.

If you contact us directly, we may receive additional information about you such as the contents of the message and/or attachments you may send us and any other information you may choose to provide.

Your Personal Information may be transmitted to other parties which we rely upon in order to provide our services to you who may retain it pursuant to their own privacy policies.

How we use your information

We use the information we collect in various ways, including to:

Provide, operate, and maintain our Platform
Improve, personalize, and expand our Platform
Provide functionality of our Platform to you and other users
Provide recommendations for other information, products, and services to you
Understand and analyze how you use our Platform
Collect anonymized data to understand trends in our customer base
Develop new products, services, features, and functionality
Communicate with you, including for customer service, to provide you with updates and other information relating to the website or our products, and for marketing and promotional purposes
Find and prevent fraud
As required for regulatory purposes
Respond to subpoenas, warrants, or other legal processes

Log files

The Company follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this as part of hosting services' analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

Advertising Partners’ Privacy Policies

Third-party ad servers or ad networks use technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Neural, which are sent directly to users' browsers. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

The Company has no access to or control over cookies that are used by third-party advertisers on the Platform.

This Privacy Policy does not apply to other advertisers or websites. Thus, we are advising you to consult the respective privacy policies of these third-parties for more detailed information. It may include their practices and instructions about how to opt-out of certain options.

You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers' respective websites.

California Residents

Under the California Consumer Privacy Act of 2018 (“CCPA”), among other rights, California consumers have the right to:

Request that a business that collects a consumer's personal data disclose the categories and specific pieces of personal data that a business has collected about consumers.
Request that a business delete any personal data about the consumer that a business has collected, pursuant to some exceptions.
Request that a business that sells a consumer's personal data, not sell the consumer's personal data.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us.

Please refer to our comprehensive CCPA Privacy Notice, attached to this Privacy Policy, for more information. If you are a California resident, by agreeing to this Privacy Policy, you are also agreeing to the CCPA Privacy Notice.

Children's Information

The Company does not expect that any Customer or User will be less than 18 years old. As such, the Company does not knowingly collect any Personal Information from children under the age of 13. However, if you think that your child provided this kind of information, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

Changes to this Policy

We reserve the right to amend this Privacy Policy at our discretion and at any time. The date this Privacy Notice was last updated is identified at the top of this page. You are responsible for periodically visiting the Platform and this Privacy Policy to check for any changes.

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us via email at support@neural.io.

CCPA privacy notice

This notice supplements the information contained in the Privacy Policy of the Company (all definitions are the same as in the Privacy Policy) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) when you visit the Platform. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

1. Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	Yes
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	No
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
G. Geolocation data.	Physical location or movements.	Yes
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	No
I. Professional or employment-related information.	Current or past job history or performance evaluations.	No
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, when you create an account, upload information about yourself to your account, or link a third-party service to your account and allow that service to share information to the Platform.
Directly and indirectly from you when using the Platform. For example, usage details collected automatically in the course of your interaction with the Platform.

2. Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

To fulfill or meet the reason for which the information is provided. For example, to submit this information to service providers for identity verification.
To provide you with email alerts and other notices from or about the Platform.
To improve our products, services, and applications for you.
To provide recommendations to you for additional services, products, or information within the Platform.
As necessary or appropriate to protect the rights, property or safety of us, our customers, or others.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we not have disclosed any category of personal information to a third party for a business purpose.

In the preceding twelve (12) months, we have not sold any personal information.

3. Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

4. Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to the registered email associated with the account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

5. Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you use of the Platform or any of the Company’s products, services or applications.

Provide you a different level or quality of products, services or applications.

6. Changes to this Privacy Notice

We reserve the right to amend this CCPA Privacy Notice at our discretion and at any time. The date this Privacy Notice was last updated is identified at the top of this page. You are responsible for periodically visiting the Website and this CCPA Privacy Notice to check for any changes.

7. Contact Information

If you have any questions or comments about this Privacy Notice, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, you may contact us privacy@neural.io.

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