Neurun 

PRIVACY POLICY

Last Updated: March 21, 2019

Welcome to Neurun! We respect and value your privacy, and we are committed to protecting it through our compliance with this Privacy Policy (“Policy”). To make this Policy easier to read, we will sometimes refer to Neurun, Inc. (including our directors, officers, members, managers, employees, service providers, affiliates, successors and assigns) as “our”, “we”, or “us”; and we will refer to user(s) of the Service (including you) as “you” or “User(s)”. 


This Policy describes the types of information we may collect from you when you access or use the Neurun website located at www.neurun.com (the “Site”), access or use the Neurun mobile application (the “App,” part of the Service), or when you use or interact with any other products, applications, or features provided by us (collectively, the “Service”), as well as our practices for collecting, using, maintaining, protecting, and disclosing that information. Any capitalized terms used but not defined in this Policy shall be given the meaning defined in our Terms of Service. 


If you do not agree with this Policy, or our other policies and practices, you should not use the Service. This Policy may change from time to time. We will notify you of material changes, but it is your responsibility to check this Policy periodically for updates. 

Please read this privacy policy carefully as it will help you make informed decisions about sharing your personal information with us.  


TYPES OF INFORMATION WE COLLECT & HOW WE COLLECT IT


We collect both personal information and non-personal information from Users of the Service, but the information we collect from you depends on how you use the Service and what information you choose to provide to us. This section describes what types of personal and non-personal information we may collect, and how we collect information.


The personal information that we collect depends on the context of your interactions with us and the Site, the choices you make and the products and features you use. 


Personal Information. Personal information is generally any information that can be used to identify you individually, either by itself or in conjunction with other information. 


Personal information we collect may include, without limitation:

  • Contact Information, such as your name, email address, postal address;

  • Account credentials, such as your username, password, and similar security information used for authentication and account access;

  • Payment data, financial information and billing preferences if you make purchases through the Service (if any and when available), such as credit card number, security code, and expiration date; 

  • Online identifiers, such as your Internet Protocol (“IP address”), or other device information, when that information is linked to other personal Information or non-personal Information that allows that individual to be identified;

  • Demographic or location information, when that information is linked to other personal information or non-personal Information that allows an individual to be identified; and

  • Social Media Login Data, if you chose to create an account using one of your existing social media accounts. We provide you with the option to register using social media account details, like your Facebook, Google, or other social media account. If you choose to register in this way, we will collect the information described in the section called "Social Logins" below.


Non-Personal Information. Non-Personal Information includes information that is about you or about your use of the Service but does not identify you personally, such as:

  • IP addresses;

  • Anonymous usage data;

  • Referring/exit pages and URLs;

  • Browser or platform type;

  • Internet connection;

  • Equipment used to access the Service;

  • Language preference; 

  • Referring site; 

  • Preferences you submit and preferences that are generated based on data you submit; and

  • The date and time of User requests.


Special Types of Personal Information. We do not require you to provide any Special Category Personal Data in order to use the Service (Special Category Personal Data includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). However, we do allow Users to interact with other Users based on their interests, among other factors (“Interest Groups”). A User may choose to upload information that includes Special Category Data to the User’s Account, or to publicly post or share information that includes Special Category Data with other Users through the Service. If you upload Special Category Data to your Account, or if you join an Interest Group or otherwise choose to share or post information containing Special Category Data with other Users or in any public areas or features of the Service, you are giving us your explicit consent to process your data, including Special Category Data, in order to facilitate your participation in the Interest Group or as otherwise requested by you in connection with your Account or use of the Service. Participation in Interest Group(s), public posting, and any other interactions with other Users are all completely optional, and we will only process data that you specifically provide to make use of those features, and only as necessary for the functionality of such features.


How We Collect Personal Information. We may collect personal information when you: (1) register to use the Service and create an account; (2) provide it to us when you use the Service, such as by posting messages and interacting with other Users; (3) email us or send a message through the electronic forms provided on the Site or App; (4) enter a promotion sponsored by us; (5) report a problem with our Service; (6) respond to polls or surveys distributed for research purposes; or (7) in any other interactions between you and the Service or us in which you voluntarily provide your personal information.


If you use our App, we may also collect the following information:

  • Geo-Location Information. We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using our mobile application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

  • Mobile Device Access. We may request access or permission to certain features from your mobile device, which may include your mobile device’s camera, contacts, microphone, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

  • Mobile Device Data. We may automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and IP address.

  • Push Notifications. We may request to send you push notifications regarding your account or the mobile application. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.


*The preceding lists of personal information and non-personal Information we may collect are illustrative, not exhaustive. All information we collect from you depends on how you use and interact with us and the Service.


How We Collect Non-Personal Information. We generally collect non-personal information through automatic data collection technologies, which are described in more detail below. 


Automatic Data Collection and How We Use It

We may use automatic data collection technologies and analytics tools (such as Google Analytics) to collect information from your device or browser about your equipment, browsing actions, and patterns when you access, use, and interact with the Service. The information we collect automatically is statistical data, and generally does not include personal information. We use this information to maintain the security and operation of the Service, and to gain insights about the functionality and use of the Service in order to improve the Service. 


The technologies we use for the automatic data collection described above may include:


Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Service. 


Flash Cookies. Certain features of the Service may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash cookies are not managed by the same browser settings as are used for browser cookies.


Web Beacons. Components of the Service and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 


Location Information & Information From Other Sources

Location Information We may, from time to time, track use location through IP logging for security and fraud prevention purposes. Use location may also be tracked in connection with our use of automatic data collection technologies, such as Google Analytics.

Do Not Track Disclosure You may set your web browser to transmit a “Do Not Track” signal to websites and online services you visit. At this time, we do not respond to or alter our practices when our systems receive a Do Not Track signal from a user’s web browser. For more information on Do Not Track, please visit www.allaboutdnt.com.


Information collected from other sources. We may obtain information about you from other sources, such as public databases, joint marketing partners, as well as from other third parties. Examples of the information we receive from other sources include: social media profile information; marketing leads and search results and links, including paid listings (such as sponsored links).


SOCIAL LOGINS


Our Service offers you the ability to register and login using your third party social media account details (like your Facebook or Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture as well as other information you choose to make public. 


We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Site or App. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.


WE DO NOT COLLECT INFORMATION FROM MINORS


We do not knowingly solicit data from or market to children under 18 years of age. By using the Service, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Service. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at team_support@neurun.com.


HOW WE USE YOUR INFORMATION


We use personal information collected via the Site for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests ("Business Purposes"), in order to enter into or perform a contract with you ("Contractual"), with your consent ("Consent"), and/or for compliance with our legal obligations ("Legal Reasons"). We indicate the specific processing grounds we rely on next to each purpose listed below. 


We use the information we collect or receive:


  • To facilitate account creation and logon process with your Consent. We use the information you provide us, such as your contact information, to facilitate account creation and logon. 

  • To facilitate your use of the Service for Business Purposes and/or possibly for Contractual Purposes. We use the information you provide us to allow you to make full use of the Service, including by recommending events near you, for example. 

  • To enable user-to-user communications and/or post your Contributions with your Consent. We may use your information in order to enable user-to-user communications with each user's consent. We may also use your information to publish Contributions (as defined in our Terms of Service) that you choose to post in public areas throughout the Service. 

  • To send you marketing and promotional communications for Business Purposes. We and/or our third party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt­out of our marketing emails at any time by clicking the unsubscribe button at the bottom of the email.

  • To send administrative information to you for Business Purposes and/or possibly for Contractual Purposes. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

  • Fulfill and manage your orders for Contractual Purposes. We may use your information to fulfill and manage your orders, payments, and transactions made through the Site or App (if any and when available). 

  • Deliver targeted advertising to you for our Business Purposes. We may use your information to develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.

  • Request Feedback for our Business Purposes. We may use your information to request feedback and to contact you about your use of the Service.

  • To protect our Service for Business Purposes and/or for Legal Reasons. We may use your information as part of our efforts to keep the Service safe and secure (for example, for fraud monitoring and prevention).

  • To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and/or possibly Contractual.

  • To respond to legal requests and prevent harm for Legal Reasons. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

  • For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve the Service, our Site, our App, products, services, marketing and your experience.


HOW WE SHARE INFORMATION WITH OTHERS


We share and disclose your information in the following situations:


  • Interactions with Other Users; Public Contributions. When you share personal information (for example, by engaging discussions, posting comments, contributions or other content to the Site or App) or otherwise interact with public areas of the Site or App, such personal information may be viewed by all Users and may be publicly distributed outside the Site or App indefinitely. Similarly, other Users will be able to view descriptions of your activity, communicate with you within the Site or App, and view your profile. We may not be able to prevent Users from retaining such information or from exporting such information outside the Service, so your information may be publicly distributed outside the Service in perpetuity.


  • Compliance with Laws. We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).


  • Vital Interests and Legal Rights. We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. 


  • Vendors, Consultants and Other Third­Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Site or App, which will enable them to collect data about how you interact with the Site or App over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. 


  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.


  • With your Consent. We may disclose your personal information for any other purpose with your consent.


OUR DATA RETENTION PRACTICES 


In general, we will only retain personal information for as long as you are using the Service or as otherwise needed to provide you the Service or complete other purposes described in this Policy. We may also retain and use your personal information as necessary to satisfy any legal requirements, including enforcing our rights and agreements and resolving disputes. We will try to delete your information promptly consistent with these data retention practices. However, there might be some technical delay involved in deleting information from our servers, and backed-up versions might still exist after deletion. In addition, we do not delete any data that has been rendered completely anonymous or maintained in de-identified, aggregated form with data of other users (such as usage trend reports).


To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. 


OUR DATA SECURITY PRACTICES


We implement security measures designed to protect your information from unauthorized access, use, or disclosure. We protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure socket layer technology. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such firewalls and secure server software. By using our Service, you acknowledge that you understand and agree to assume these risks, and Neurun shall not be responsible for the circumvention of any of the Service’s privacy settings or security measures. If you have an account, we urge you to take steps to keep your account information (username and password) protected from unauthorized use by others. You should only access the services within a secure environment.


YOUR PRIVACY RIGHTS


Neurun aims to provide transparency, security, and accessibility when it comes to your personal data.


  • You May Request a Copy of Your Data. You may request a copy of your personal data from us at any time. If you request a copy of your data, we will provide you a copy in a structured, electronic format. 

  • You May Request Your Data Be Corrected, Completed, or Deleted. You may also request that your personal data be corrected if you believe it is incorrect or incomplete, or that it be deleted entirely. We will delete your personal data upon your request if you send us a request with a description of the basis for your request; however, we may first restrict processing of your data as permitted under applicable law in order to assess your request prior to any deletion of data.

  • You May Request Your Data Be Restricted From Certain Activities. Finally, you may object to our processing of your personal data, or request that we restrict the processing of your personal data. If you request that we restrict processing of your data, we will stop processing your data, but we may still store your data as permitted under applicable law pending an assessment of your request. 

  • You May Withdraw Your Consent. If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before you withdrew your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.


We may not be able to delete your personal data except by also deleting your Account, if applicable. We may not be able to accommodate a request to change or delete information if we the change would violate any law or legal requirement, or if such change would cause the information to be incorrect. We may not be able to delete the personal data of a User that was retained by a another User in duplicate form outside of the Site after it was shared with the other User in connection with interactions between the Users. 


If you are a resident of the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm


If you fail to provide personal information when it is required by law or necessary for us to perform our obligations under a contract with you, we may not be able to perform the contract. For example, if you fail to provide us with your billing information to pay for an order through your account, we may not be able to process the order.


How to Make Changes to Your Account and Personal Data


If you would at any time like to request, review or change the information in your account, or terminate your account, you can: log into your account settings and update your user account or send us an email. Please direct all requests related to your information to team_support@neurun.com.


Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.


Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site or App. To opt­ out of interest­based advertising by advertisers on our Site or App visit http://www.aboutads.info/choices/.


Opting out of email marketing: You can unsubscribe from our email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still need to send you service ­related emails that are necessary for the administration and use of your account. To otherwise opt­out, you may email us at neurunsupport@neurun.com.


CALIFORNIA RESIDENTS PRIVACY RIGHTS


California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.


If you are under 18 years of age, reside in California, and have a registered account with the Service, you have the right to request removal of unwanted data that you publicly post on the Service. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site or App, but please be aware that the data may not be completely or comprehensively removed from our systems.


LINKS TO OTHER WEBSITES AND SERVICES


As part of the Service, we may provide links to or compatibility with other websites or applications. However, we are not responsible for the privacy practices employed by those websites or the information or content they contain. This Policy applies solely to information collected by us through the Service. Therefore, this Policy does not apply to your use of a third party website accessed by selecting a link on our Site, or otherwise via our Service. To the extent that you access or use the Service through or on another website or application, then the privacy policy of that other website or application will apply to your access or use of that site or application. We encourage our users to read the privacy statements of other websites or integrations before proceeding to use them.


WE MAY UPDATE THIS PRIVACY POLICY


We may update this privacy policy from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy policy frequently to be informed of how we are protecting your information.


CONTACT US 


You have the right to make a complaint at any time to your local data protection authority if you have concerns regarding your rights under applicable law. We would, however, appreciate the chance to address your concerns so please contact us first so that we can discuss a resolution with you directly.


If you have questions or comments about the Service, this Policy, or any of our other policies, you may email us at team_support@neurun.com or by mail to the address below.


Our full details are:

Legal Entity: Neurun, Inc.

Postal Address: 131 Rantoul St. #409 Beverly, MA 01915