Last Changes to Privacy Policy: August 17, 2023
This Privacy Policy (“Policy”) describes how Neuralift (“we,” “us” or “our”) collects, uses,
and discloses personal data, and the choices you have related to this.
Please review this Policy carefully to understand our practices regarding your personal
data. If you do not agree with the practices described in this Policy, please do not
access or use our Websites or Services (defined below).
Privacy Policy Applicability
This Policy is applicable to data collected through neuralift.ai, the Neuralift Community,
and other websites managed by Neuralift (collectively, the “Websites”), through our
software products (the “Solution”) and through any other interactions you might have
with us, such as through email newsletters, online and in person events, and other
interactive features and communications.
This Policy does not apply to any third party websites, applications or businesses to
which we link or who may link to us. You should review the privacy policies of those
third parties to understand how they may collect and use your personal data.
Privacy Policy Updates
We may update the terms of this Policy at our discretion. We encourage visitors to
frequently check this page for any changes.
How We Collect
We may collect your personal data when you:
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Visit our Websites, through automated cookies
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Use our Websites or Solution
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Interact with us by communicating through the Solution, Websites, by email, by
social media, or by telephone
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Participate in our online communities, blogs or other forums
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Register for or attend an online or in person event sponsored by us
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Submit an application to work for us
What We Collect
The types of information we collect from you may differ depending on how you interact
with us.
Personal Data We May Collect from You
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Your name, username, email address, postal address, phone number, and other
contact information
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Your employer, job title and other employment related information
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Records of your correspondence with us or on our forums
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Information you provide through other types of interactions, such as surveys,
events, social media, or other communication with us
Personal Data You May Provide to Us
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Device and connection information, including IP address, unique device
identifiers, browser type, browser language, and other transactional information
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Approximate location information based on your IP address
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Cookies and tracking technologies that analyze your interaction with our emails,
use of the Websites, show traffic data, and log files such as time of access, date
of access, software crash reports, session identification number, access times,
and referring website addresses (see our Cookie Policy for more information)
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User Metrics: When you use the SaaS version of the Solution, we may
automatically collect and analyze data about your usage of the Solution using our
User Activity Monitor. This data includes technical logs, frequency of logins,
number of models deployed, and feature usage and engagement. For a full list of
data points collected through the User Activity Monitor, please see User Activity
Monitor Report Types (collectively “User Metrics”). When you use the on-premise
version of the Solution, we can only analyze User Metrics if you provide those to
us or the organisation that you work for provides those to us. The User Activity
Monitor is also accessible to your admin user so that customers may review their
own User Metrics. For SaaS users, in addition to the data points collected
through our User Activity Monitor, we may collect user interaction and navigation
data, including clickstream and mouse tracking. When we use User Metrics for
any purposes other than those described below, it is anonymized of personal
data and Customer Data in accordance with applicable law.
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Metadata: When you use the SaaS version of the Solution, we may automatically
collect and analyze data that describes your Customer Data, models and projects.
This includes data points such as dataset summary statistics, dataset size,
project type, model accuracy metrics, run times, project and model flags or
errors, specific models and blueprints run, and the parameters of such models
and blueprints (collectively “Metadata”). When you use the on premise version of
the Solution, we can only analyze Metadata if you provide it to us or the
organisation you work for provides it to us. Metadata is always anonymized of
personal data and Customer Data.
Personal Data We May Receive from Third Parties
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Business contact information from third party providers, such as event co-hosts,
B2B intelligence platforms, or your company, if the Solution is provided to you via
your company
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Publically available data from third party sources, like social media
Personal Data Required by Contract
When you sign up for a Neuralift account to access the Solution, we require certain
minimum personal information from you. This includes your name and email address.
This personal data is contractually required under our MSA, which you must agree to in
order to access the Solution. If you do not provide this data, you will not be granted
access.
How We Use Your Data and Legal Basis for Processing
How we use your personal data depends on how you interact with us. The specific
purposes for which we use the data we collect about you are listed below. In some
jurisdictions, including those subject to the EU General Data Protection Regulation
(“GDPR”) or UK General Data Protection Regulation (“UK GDPR”), we may only process
your personal data when we have a legal basis to do so. Our legal basis for processing
your personal data is listed with each purpose for processing below.
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To provide and support the Solution and Websites. We use your personal data to
provide and support the Solution and Websites. As part of doing so, we may send
you service announcements, technical notices, security alerts, billing and
support-related messages related to your account or transactions with us,
through the Solution or by email. You may not opt out of these messages, as they
are considered part of the Solution.
Legal Basis for Processing: We may have a contractual obligation to you, or to
your company, to provide you with access to and support for the Solution, which
requires the processing of your personal contact data. Otherwise, we have a
legitimate interest in providing you access to and support for our Websites.
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To provide an individualized experience on the Solution and Websites. We use the
information we collect to personalize content and experiences on our Solution
and Websites, to better understand your interests and make personalized
recommendations based on your interests, and tailor your experience with us to
your preferences.
Legal Basis for Processing: We have a legitimate interest in processing your
personal data to improve your experience with us.
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To understand and manage our relationship with you. We use your personal data
to understand your use of the Solution and Websites so that we can monitor the
health of our relationship with you, and for our enterprise users, identify usage
trends and suggest new services or features based on your company’s usage of
the Solution. We also report this data back to our enterprise customers, so that
you can maximize your company’s use of our Solution.
Legal Basis for Processing: We have a legitimate interest in making sure that you
are getting the full value out of your use of the Solution and Websites, identifying
product champions, and making suggestions to optimize your usage or
subscriptions.
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To communicate with you. We will send you emails or otherwise communicate
with you in response to your questions, feedback or comments. For example, we
will respond to comments on our Community boards, and answer questions sent
to us through the Websites. We may also contact you with personalized
messages via email, telephone, or on social media if we identify that because of
your experience or background that our Solution might be of particular interest to
you. You can also opt into receiving emails about new product features and
services. You can always opt out of these communications by following the opt
out instructions in the message or by contacting us through the contact
information listed below.
Legal Basis for Processing: We have a legitimate interest in corresponding with
you when you have contacted us, or when we have identified you may have a
particular interest in the Solution (when not prohibited by law). Otherwise, when
processing your personal data for marketing communications, we rely on your
consent.
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To create anonymous data for use in product development. We may remove
personal identifiers from data containing personal information so that it cannot
be traced back to an individual, and aggregate it by combining it with the data
from multiple sources and/or individuals. We may use this data to understand
feature adoption and feature gaps, make product depreciation decisions, and
make product development decisions. When using collected data for product
development, we will always remove all personal data and Customer Data.
Legal Basis for Processing: We have a legitimate interest in creating anonymized
data so that we can use that data to improve the Solution.
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For security, compliance, fraud prevention and safety. We may use your personal
data as we believe appropriate to investigate or prevent violation of the law, our
MSA, our Terms of Service, to secure the Solution, to protect our, your or others’
rights, privacy, safety or property; and to protect, investigate and deter against
fraudulent, harmful, unauthorized, unethical or illegal activity. We may also use
the information we collect about your device to detect users violating our MSA or
Terms of Service and prevent further violations.
Legal Basis for Processing: We have a legitimate interest in protecting ourselves
and our users against unauthorized use of our Solution and Websites to ensure
the security of the data processed within them. We are also obligated to process
certain personal data to monitor compliance with our MSA and performance of
other agreements we may have with you.
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For compliance with law or to investigate legal claims. We may use your personal
data to comply with applicable laws, lawful requests and legal process, such as
to respond to subpoenas or requests from government authorities. We may also
use your personal data where permitted by law in connection with any legal
investigation and to prosecute or defend legal claims.
Legal Basis for Processing: In certain rare circumstances, we may rely on
compliance with a legal obligation or protection of vital interests in the event of a
legal investigation or request from a law enforcement or governmental entity. As
a global company, there are a wide variety of laws that might compel processing
of your data under this legal basis, but they may include the following types of
laws: civil and commercial laws, criminal laws, consumer laws, and corporate
and taxation laws.
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With your consent. In some cases we may ask for your consent to collect, use or
share your personal data in ways we have not described here. When we do that,
we will always record your consent and you may change your mind and opt out
by contacting us via the methods listed in the Contact Us section
How We Share Your Data
Except for as mentioned below, we do not share your personal data with any other
companies. We will not sell or rent your personal data as part of a customer list or
similar transaction.
We may share your personal data as follows:
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With Affiliates. We may share your personal data with our subsidiaries, joint
ventures, or other companies under common control, in which case we will
require those entities to honor this Privacy Policy. As a global company, we have
employees employed by subsidiary companies across the world. We may share
any of the data listed above with any of these affiliated companies.
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With Business Partners. We may share your personal data with our business
partners with whom we develop product integrations for our users, or partners
who help us host our events. For our event partners, we will only share your
contact data, and only if you have consented to it at the time of registration. If
you would like to withdraw your consent you can contact us as provided in the
Contact Us section.
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With Third Party Agents and Service Providers. We have third party agents and
service providers that perform functions on our behalf, such as hosting, billing,
push notifications, storage, bandwidth, content management tools, analytics,
customer service, fraud protection, etc. These entities may have access to your
personal data to the extent needed to perform their services. All such third
parties are contractually obligated to maintain the confidentiality and security of
your personal data, and are restricted from using your personal data other than to
provide their services.
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With Social Media Widgets. Our Websites may include social media features,
such as Facebook, Twitter, Instagram and Tumblr widgets. These features may
collect your IP address, the pages you visit on the Websites, and set cookies to
enable the features. They are either hosted by a third party or directly on our
Websites. Your interactions with these features are governed by the privacy
policy of the company providing them, not this Policy.
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By Linking to Third Party Sites. Our Websites may link to other websites or
services operated by third parties, whose privacy practices may differ from ours
and are governed by their own privacy policies, not this Policy. We do not control
or endorse any of these third party websites or services, and we encourage you
to carefully review the privacy policy of any website you visit.
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With Law Enforcement, Government Entities, and Other Companies and
Organizations. In rare circumstances, we may share your personal data with law
enforcement or governmental entities for compliance with the law or to
investigate legal claims. In the event of confirmed fraudulent activity, we may
also exchange information with other companies and organizations for fraud
protection.
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Through Business Transfers. We may sell, transfer or otherwise share some or all
of our business or assets, including your personal data, in connection with a
business deal (or potential business deal) such as a merger, consolidation,
acquisition, reorganization, sale of assets or in the event of bankruptcy.
Our Products
The Solution may be used to process personal data on behalf of you, our customer. We
may not have any direct relationship with the individuals to whom the data belongs.
Individuals who would like to access, correct or delete personal data processed by us
on behalf of our customers should direct their questions to our customers, who are the
data controllers. We use and disclose this personal data as permitted by our customer
agreements and as required by law.
Data Retention
We will retain your personal data as needed to fulfill the purposes for which it was
collected. We may retain your information as needed to provide you services, comply
with our business requirements and legal obligations, resolve disputes and enforce our
rights and agreements.
Following termination or deactivation of your account, we will delete your Customer
Data, and anonymize your User Metrics, but may retain your contact information, user
profile, and other personal data in our records. When the purpose for which your
personal data was collected no longer exists and there is not a business or legal reason
to retain your personal data, Neuralift will securely delete or anonymize your data. To
request deletion of your personal data before the expiry of our retention period, please
see the Contact Us section.
Data Security
We take security very seriously. We take appropriate measures, including organizational,
technical, and physical precautions to help protect against unauthorized access to,
alteration of, or destruction of your personal data.
While we follow industry standards and best practices to protect your data, no
transmission of data over the Internet or any public network can be guaranteed to be
100% secure.
Payment Information
Any payment card information you use to make a purchase with us is collected and
processed directly by our payment processor, Stripe, Inc. We will never receive or store
your full payment card information. You should review Stripe’s privacy policy prior to
making a purchase.
Children’s Data
The Services and Websites are not directed to anyone under the age of 18. A parent or
guardian who becomes aware that his or her child under the age of 18 has provided us
with personal data may Contact Us and we will attempt to delete the child’s data as
soon as possible.
Your Data Rights
We respect your control over your personal data and, upon request, we will confirm
whether we hold or are processing data that we have collected from you. You also have
the right to amend or update inaccurate or incomplete personal data, request deletion of
your personal data, or request that we no longer use it. Under certain circumstances we
will not be able to fulfill your request, such as if it interferes with our regulatory
obligations, affects legal matters, we cannot verify your identity, or fulfillment involves
disproportionate cost or effort, but in any event we will respond to your request within a
reasonable timeframe and provide you an explanation.
You can always contact us as provided in the Contact Us section to exercise these
rights. You may also be able to take action yourself through the methods listed below.
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View, correct and delete your account information. If you use the Solution or have
an account through our Websites, you can view, update and delete certain
information directly through your account.
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Opt out of communications. You can opt out of receiving future marketing
communications from us by clicking the unsubscribe link within a marketing
email, by responding to our emails with the subject line “Opt Out,” or by updating
your profile settings. Please note that you generally can’t opt out of service
related communications.
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Deactivate your account. If you would like to stop using our Solution, you or your
administrator may be able to deactivate your account. Please be aware that
depending on how you use our Solution and Websites, this may not delete all of
your information.
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Turn off cookies. See our Cookie Policy to learn how to control browser based
cookie controls.
International Transfers of Data
We are a global company headquartered in the United States, with entities, operations
and service providers situated around the world. Your personal data may be transferred
outside of your local jurisdiction, to countries without an adequacy decision by the
European Commission. We have put appropriate safeguards in place to ensure that your
personal data receives an adequate level of security regardless of the country in which it
is processed. This includes entering into agreements with written assurances from our
services providers, including, as required, standard contractual clauses for the transfer
of personal data as approved by the European Commission and the British Information
Commissioner’s Office. Depending on the particular circumstances of the transfer, we
may use the GDPR Standard Contractual Clauses Controller – Controller, Controller –
Processor, or Processor – Processor, and/or the UK Standard Contractual Clauses
Controller – Controller or Controller to Processor. Our standard contractual clauses can
be provided upon request.
European Residents
If you are located in the European Economic Area, Switzerland, or United Kingdom, you
have additional data privacy rights that include the right to:
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Access, correct update or request deletion of your personal information
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Object to the processing of your personal information, ask us to restrict
processing of your personal information, or request portability of your personal
information
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Opt out of marketing communications we send you at any time
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Withdraw your consent for processing, if we are processing your personal data
based on consent. Note that withdrawing consent does not affect the lawfulness
of processing based on consent before its withdrawal; and
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Make a complaint to a data protection authority about or collection and use of
your personal data.
To exercise these rights, please contact us as provided in the Contact Us section below.
California Residents
This Policy contains a list of the categories of personal data we collect, and have
collected for the past twelve months.
If you are a California resident, you may have additional rights under the California
Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”) that include
the right to:
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Request access, correction and deletion of your personal information;
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Opt out of the sale of your personal information; and
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Not be discriminated against for exercising one of your CCPA/CPRA privacy
rights.
Please note that we do not sell the personal data that we collect.
To exercise your rights, please contact us as provided in the Contact Us section. You will
not be discriminated against for exercising your privacy rights under the CCPA and
CPRA. In order to protect your personal data from unauthorized access or deletion, we
may require you to provide additional information for verification. If we can’t verify your
identity, we will not provide or delete your data.
Contact Us
If you have any questions about this Policy, or to exercise any of your data privacy rights,
please email us at help@dneuralift.ai. You can also contact us at our mailing address
below:
6 Highview Drive
Livingston, New Jersey 07039
USA
Attn: Data Protection Officer