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Effective Date: July 31, 2025
Neuroiam Inc.
1. Who We Are & Scope
Neuroiam Inc. (“we,” “our,” or “us”) provides services that analyze user inputs (including text and voice) to identify strengths and deliver individual and team recommendations. This Privacy Policy describes how we collect, use, disclose, and protect personal data for individual users and organization customers (B2B), including their employees and contractors who participate in assessments (“Authorized Users”).
Age Restriction: Our services are intended for users 18+ only.
2. Categories of Personal Data We Process
Depending on how you interact with the Service (individual or B2B), we process:
Identifiers & Contact Data: name, email, phone, role/title, team, organization, contract owner contact details.
Interview & Communication Data: messages with our AI companion, interview transcripts, audio and video recordings, and annotations.
Calendar & Task Integrations (optional): events, attendees, task names/metadata necessary to provide recommendations.
Usage & Device Data: IP address, device/browser type, OS, app version, log data, telemetry and interaction events.
Payment/Subscription Data: limited billing metadata processed via payment processors (e.g., Stripe); we do not store full payment-card numbers.
Inferences & Profiles: strengths assessment outputs, team readiness indicators, and other insights derived from your inputs and usage.
Organizational Inputs (B2B): team roster, goals for using the Service, mission/objectives of the team/business unit, and role information provided by the Customer.
Do not submit special-category or highly sensitive data. We do not seek to collect special categories under GDPR (e.g., health, biometric, religious, sexual orientation), government IDs, payment card numbers, precise geolocation, internal disciplinary/sanctions records, or confidential business secrets.
3. Sources of Personal Data
Directly from you (registration, interviews, messages, uploads, settings)
From your organization (B2B) — contract owner, HR/people ops, or team lead
From integrations you authorize (e.g., calendars/task tools)
From service providers (e.g., analytics, payment processors, hosting)
3A. B2B Customer Responsibilities: No Confidential or Unnecessary Disclosures
Organization Customers must ensure participants do not disclose:
Special category personal data
Government IDs, payment data, or precise location
Third party personal data without lawful basis
Confidential business information
Internal disciplinary/sanctions records
Prohibited data will be treated confidentially but cannot be removed once submitted. Customers are responsible for proper instructions and anonymization.
4. How We Use Personal Data (Purposes)
We process personal data to:
Provide the Service (assessments, reports)
Deliver team reports (within 10 business days)
Operate integrations
Improve quality and safety (including Human Review)
Product analytics and research
Security, fraud prevention, and incident response
Business operations (billing, compliance)
Communications and marketing (see §12)
5. Legal Bases (GDPR/UK GDPR)
Depending on the context:
Contract necessity
Legitimate interests (balanced against your rights)
Consent (where required)
Legal obligation
For B2B, we act as processor or independent controller as permitted by law.
6. Human Review & Model-Assisted Processing
We may use trained specialists (under confidentiality obligations) to:
Verify outputs
Contextualize recommendations
Address appeals and perform quality checks
Human Review is not medical/psychological advice and does not replace HR/legal processes.
7. Audio/Video Recording (Mandatory for Assessments)
Recording is required for assessments and interviews.
Notice & Consent: Participating affirms consent to recording and processing.
Two-Party Consent (US): Express consent is mandatory where required.
Use of Recordings: To generate insights, refine outputs, ensure quality and security.
8. Sharing & Disclosures
We share data with:
Service providers / subprocessors (e.g., hosting, Stripe, AI providers)
Organization Customers (B2B)
Legal & safety authorities when required
We do not sell personal data. We also do not “share” it for cross-context behavioral advertising as defined by CPRA.
9. International Data Transfers
We use safeguards like:
Standard Contractual Clauses (EU/EEA)
UK Addendum / IDTA
Swiss equivalents
Transfer risk assessments
10. Data Retention
Data is retained:
Until requested for deletion
In line with legal requirements
Some data (e.g., logs, audio) may have shorter retention by default
Deletion or anonymization occurs within 30 days of request
11. Security
Measures include:
2FA
Access controls
Environment hardening
Monitoring
Encryption (planned)
No system is perfect; we strive for continuous improvement.
12. Your Privacy Choices
Access/Correction/Deletion: See §13
Marketing: Opt out via unsubscribe links or email
Cookies/Tracking: Consent obtained where required
Recordings: Required for assessments. No consent = no participation
13. Your Rights (EU/EEA, UK, Switzerland)
You may have the right to:
Access
Rectify
Erase
Restrict processing
Object (including to profiling)
Data portability
Withdraw consent
We respond within 1 month (extendable).
You may lodge complaints with your data protection authority.
Automated Decisions & Profiling You may request human review and explanations as required by law.
14. California Privacy (CCPA/CPRA)
California residents have rights to:
Know
Delete
Correct
Non-discrimination
We do not sell or “share” personal data for behavioral advertising.
Contact: info@neuroiam.com
15. Roles (B2B)
For B2B:
Customer = Controller
Neuroiam = Processor (assessment-related processing)
Neuroiam = Independent Controller (security, analytics, billing, etc.)
We comply with applicable laws and this Policy.
EU/UK Representatives: Contact info@neuroiam.com for current inquiries.
16. Changes to This Policy
We may update the Policy.
Material changes will be notified via the Service or email.
Continued use = acceptance of changes.
17. Contact Us
Neuroiam Inc.
Email: info@neuroiam.com
For privacy requests, email with subject line “Privacy Request” and include sufficient information for verification.