Effective as of July 03, 2020.
This Privacy Policy describes the privacy practices of Neural Reader in connection with the Neural Reader mobile application (the “App”).
Individuals located in the European Economic Area should also read our Notice to European Users below.
When you use the App, we may collect information about you, including:
We may use data you provide for the following purposes:
To operate and improve the App:
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 Service; 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.
We do not disclose user data to third parties (with the exception of uploading to our cloud providers Google Cloud Platform and Amazon Web Services to provide features of the App). We may share your information in the following circumstances:
Affiliates. 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 services 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.
Third-party platforms and social media networks. If you have enabled features or functionality that connect the App to a third-party platform or social media network (such as by logging into Neural Reader using your account with the third-party, providing your API key or similar access token for the App to a third-party, or otherwise linking your account with the App to a third-party’s services), we may disclose the personal information that you authorized us to share. We do not control the third-party platforms’ use of your personal information, which is governed by that third party’s privacy policy and terms and conditions.
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.
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.
In this section, we describe the rights and choices available to all users. Users who are located within European 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.
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.
Third-party platforms or social media networks. If you choose to connect to the App via a third-party platform or social media network, such as by using Facebook login, you may have the ability to limit the information that we may obtain from the third-party at the time you login to the App using the third-party’s authentication service or otherwise connect your account. Subsequently, you may be able to control your settings through the third-party’s platform or service. For example, you may access and change your settings through the Facebook settings page for Apps and Websites. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.
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.
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. Your privacy settings may also be affected by changes the social media services you connect to Neural Reader make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.
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.
We store the information we collect in connection with the App on Amazon Web Services and Google Cloud Platform. For Amazon Web Services, we specify the US as the data storage location. Your personal information may be accessed by our service providers in other locations outside of your state, province, or country. Your device ID (and general App usage information) may also be accessed by the Company’s technical support team in other locations outside of your state, province, or country. We rely on the Privacy Shield, as described below, for transfers of data from the EU and Switzerland to Neural Reader in the United States.
Neural Reader is the US entity that publishes and hosts the App. Neural Reader complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. Neural Reader has submitted its certification to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.
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 restricting their access, use and disclosure of personal information in compliance with our Privacy Shield obligations. Neural Reader may be liable if these third parties fail to meet those obligations and we are responsible for the event giving rise to the damage.
In compliance with the Privacy Shield Principles, 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 . Neural Reader has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither Neural Reader nor JAMS resolves your complaint, you may have the ability to engage in binding arbitration through the Privacy Shield Panel. Additional information on the arbitration process is available on the Privacy Shield website at www.privacyshield.gov.
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. The Federal Trade Commission has jurisdiction over Neural Reader’s compliance with the Privacy Shield. Neural Reader’s commitments under the Privacy Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.
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 of a child under the age of 4, we will delete it. We encourage parents with concerns to contact us.
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.
Please direct any questions or comments about this Policy or privacy practices to support@neuralreader.com.
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.
|
Processing purpose Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”. |
Legal basis |
|---|---|
| To operate and improve the App | Processing is necessary to perform the contract governing our provision of services in connection with the App, or to take steps that you request prior to signing up for the App. If we have not entered into a contract with you, we process your personal information based on our legitimate interest in providing the services you access and request in connection with the App. |
| To send you marketing and promotional communications To display advertisements to you For compliance, fraud prevention and safety To create anonymous, aggregated or de-identified data |
These activities constitute our legitimate interests. We do not use your personal information for these activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). |
| Compliance with Law | Processing is necessary to comply with our legal obligations. |
| With your consent | Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the App. |
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:
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 or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
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.
| Personal information we collect | CCPA-defined categories | Sources of personal information | Purposes for which we may collect and use the personal information | Data Sharing |
|---|---|---|---|---|
| App usage information |
Online identifiers Internet or network information Inferences |
You Automatic collection |
To operate and improve the App To send you marketing and promotional communications |
Shared with affiliates that provide services to us |
| Purchase history |
Commercial information Online identifiers |
The app store provider through which you purchased your subscription (i.e., Google or Apple) | To operate and improve the App | None |
| Social media information |
Identifiers Online identifiers |
Third-party platforms | To operate and improve the App | Shared with third-party platforms (e.g., social media networks) at your direction |
|
Device data Online activity data |
Online identifiers Internet or network information Inferences |
You Automatic collection |
To display advertisements to you | Collected directly by advertising partners |
Except as excluded from the scope of this notice above, the CCPA grants California residents the following rights.
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.
To request access to or deletion of personal information:
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.