Privacy Policy

Individuals located in the European Economic Area should also read our Notice to European Users below.

Personal Information We Collect

When you use the App, we may collect information about you, including:

• App usage information, such as information about how you use the App and interact with us, including your preferred language, the date and time when you first installed the App and the date and time you last used the App.
• Account information, such as your email address and authentication-related identifiers when you create an account or sign in.
• Content you provide, such as documents, text, images, or other content you upload to or create in the App.
• Purchase history, if you choose to purchase an App subscription, such as confirmation that you are a paid subscriber to the App.
• Device data, such as operating system type and version number, manufacturer and model, device identifiers (including advertising identifiers where enabled), push notification tokens, screen resolution, IP address (and the associated country/region), and App version.
• Online activity and diagnostics, such as information about your use of and actions within the App (including pages or screens you viewed, access times, and session duration) as well as crash reports and performance logs. We may collect this information directly or through third-party software development kits (“SDKs”) integrated into the App.

How We Use Your Personal Information

We may use data you provide for the following purposes:

To operate and improve the App:

• Enable you to use the App’s features;
• Establish and maintain your account and authenticate you;
• Provide and manage subscriptions and purchases, including verifying subscription status;
• Communicate with you about the App, including by sending you announcements, updates, and security alerts, which we may send through a push notification, and responding to your requests, questions and feedback;
• Provide technical support and maintenance for the App; and
• Perform statistical analysis about use of the App (including through analytics and attribution tools such as AppsFlyer).

For compliance, fraud prevention, and safety. We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create anonymous, aggregated or de-identified data. We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes.

How We Share Your Personal Information

We share personal information with third parties only as described below (for example, to operate the App, process subscriptions, provide customer support, and measure App performance). We do not sell your personal information.

Affiliates (if any). We may share App usage information with our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. We may share your personal information with service providers that perform services on our behalf or help us operate the App (such as customer support, hosting, analytics, email delivery, marketing, and database management services). These third parties may use your personal information only as directed or authorized by us and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.

App stores and subscription management. If you purchase a subscription, the app store (Apple or Google) and our subscription management provider may provide us with purchase and subscription status information so we can enable your access.

Analytics and attribution providers. We may share device and usage information with analytics and attribution providers (such as AppsFlyer) to understand App performance and marketing attribution.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

Compliance with Law

We may be required to use and share your personal information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

Your Choices

In this section, we describe the rights and choices available to all users. Users who are located within European countries can find additional information about their rights below.

Opt out of marketing communications and other push notifications. You may opt out of marketing-related communications and other notifications we may send you via push notification by changing the settings on your mobile device.

Device permissions. You may revoke any permissions you previously granted to us, such as permission to access your camera, camera roll, or microphone through the settings on your mobile device.

Cloud processing. You may request that we remove your information from the cloud by contacting us.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information in order to provide the App to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with our services. We will tell you what information you must provide to use the App by designating it as required at the time of collection or through other appropriate means.

Other Sites, Mobile Applications and Services

The App may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and online services follow different rules regarding the collection, use and sharing of your personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Security Practices

We use commercially reasonable security practices to help keep the information collected through the App secure and take reasonable steps to verify your identity before granting you access to your account (if you have an account with us). However, Neural Reader cannot ensure the security of any information you transmit to Neural Reader or guarantee that information on the App may not be accessed, disclosed, altered, or destroyed.

Please do your part to help us. You are responsible for maintaining the confidentiality of your login information and device identifiers, and for controlling access to communications between you and Neural Reader, at all times. We are not responsible for the functionality, privacy, or security measures of any third-party services you may choose to use in connection with the App.

Retention

With respect to information that we may collect, we will retain such information in a personally identifiable format only for as long as necessary to fulfill the purposes we have set out in this Privacy Policy. You may also ask that we delete your information by contacting us.

Cross-Border Data Transfers

We and our service providers may store and process information in the United States and other countries. As a result, your personal information may be transferred to, and processed in, jurisdictions that may not provide the same level of data protection as your jurisdiction.

International Data Transfers

When we transfer personal information from the European Economic Area, United Kingdom, or Switzerland to countries that have not been deemed to provide an adequate level of data protection, we rely on appropriate legal mechanisms to ensure the lawful transfer of your data, including Standard Contractual Clauses approved by the European Commission and other applicable safeguards.

Neural Reader may transfer your personal information to third parties as described in this Privacy Policy. Neural Reader maintains contracts with its third-party service providers that include appropriate data protection provisions restricting their access, use, and disclosure of personal information.

Neural Reader commits to resolve complaints about our collection or use of your personal information. European individuals with inquiries or complaints regarding our Privacy Policy should first contact Neural Reader at support@neuralreader.com. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint to your satisfaction, you may submit a complaint to the data protection authority in your jurisdiction.

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

Children

The App is not directed at children under the age of 4, and our Terms of Use do not allow children under 4 years of age to use the App. If we learn that we have collected personal information from a child under 4, we will delete it. We encourage parents with concerns to contact us.

Changes to the Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the App. We may, and if required by law, will, provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the App.

Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on the App (or as otherwise indicated at the time of posting). In all cases, your continued use of the App after the posting of any modified Privacy Policy indicates your acceptance of the terms of the modified Privacy Policy.

How to Contact Us

Please direct any questions or comments about this Policy or privacy practices to support@neuralreader.com.

Notice to European Users

The information provided in this “Notice to European Users” section applies only to individuals who reside in Europe.

Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.

Controller and EU Representative. Neural Reader is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.

Legal bases for processing. We use your personal information only as permitted by law. Our legal bases for processing the personal information described in this Privacy Policy are described in the table below.

Your rights

European data protection laws give you certain rights regarding your personal information. If you are located within the European Union, you may ask us to take the following actions in relation to your personal information that we hold:

• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You may submit these requests by email provided above.

If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.

Notice to California Residents

We are required by the California Consumer Privacy Act of 2018 (“CCPA”) to provide to California residents an explanation of how we collect, use and share their personal information, and of the rights and choices we offer California residents regarding our handling of their personal information.

We do not sell personal information. In addition to disclosures of personal information to our service providers and professional advisors, for compliance, fraud prevention and safety, and in connection with a business transfer, as described in the “How We Share Your Personal Information” section of the Privacy Policy, the following chart further describes our privacy practices with respect to the personal information of our California consumers.

California Residents’ Privacy Rights

Except as excluded from the scope of this notice above, the CCPA grants California residents the following rights.

• Information. You can request information about how we have collected, used and shared your personal information during the past 12 months. We have made this information available to California residents without having to request it by including it in this notice, in the above chart.
• Access. You can request a copy of the personal information that we maintain about you.
• Deletion. You can ask us to delete the personal information that we collected or maintain about you.

Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.

You are entitled to exercise the rights described above free from discrimination.

How to Submit a Request

To request access to or deletion of personal information:

• email: support@neuralreader.com

Identity verification. The CCPA requires us to verify the identity of the individual submitting a request to access or delete personal information before providing a substantive response to the request. We may attempt to verify your identity by asking you to confirm information that we have on file about you or your interactions with us. Where we ask for additional personal information to verify your identity, we will only use it to verify your identity or your authority to make the request on behalf of another consumer.

Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have written authorization confirming such authority.