Privacy Policy

last updated:

May 10, 2026

1. INTRODUCTION

This Privacy Policy (the “Policy”) explains how The Neuron Holdings, Inc. (“Company”, “The Neuron”, “we”, “us”, or “our”) collects, uses, and discloses personal information through its website (www.theneuron.com) (the “Website”) and its online proprietary self-serve demand side platform (the “Platform”, and collectively with the Website, the “Service”). Any capitalized terms that are not defined in this Policy are defined in our Terms of Service.

2. INFORMATION COLLECTED AND HOW WE USE IT

As explained further in this section, you will have the opportunity to provide us with certain personal information. In addition, we may collect certain personal information automatically through your use of the Service. The rest of this section provides a more detailed explanation of the personal information we collect, how we use that personal information, and our lawful bases for processing that personal information.

2.1. Voluntarily Disclosed Information. The following table identifies the specific purposes for which you may voluntarily disclose personal information to us, along with our lawful bases for processing that personal information.

Purpose for Collection	Type of Personal Information	How we collect that information	Lawful Basis for Processing
Account Creation	Real name, Email Address	Directly from you	Your consent; Performance of a contract with you; Legal compliance; Necessary to protect your (or someone else’s) vital interests; Public interest;
Marketing communications	Real name, email address	Directly from you	Your consent

2.2. Automatically Collected Information. Whenever you interact with the Service, we automatically receive and record information on our server logs from your browser or device, which may include your IP address, geolocation data, device identification, “cookie” and pixel tag information, the type of device you’re using to access the Service, the amount of time spent on the Service, and the page or feature you requested. You can learn more about our use of cookies and related technologies in our Cookie Policy. We use the data we automatically collect from you to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Service – for example, this data can tell us how often users use a particular feature of the Service, and we can use that knowledge to make the Service interesting to as many users as possible. We collect this information with your consent, to perform our contract with you, and for our legitimate interest of providing a smooth user experience on the Service. If we rely on your consent for the use of cookies (for example, for cookies from third-party advertisers, you can remove your consent as follows:

• If you are a resident of the European Economic Area (EEA) please contact Prighter Group via the portal found at: https://app.prighter.com/portal/15434280780

• Residents of any other jurisdictions can email The Neuron at hello@theneuron.com.

3. DISCLOSURE OF PERSONAL INFORMATION.

We may disclose your personal information as detailed in this section.

3.1. Personnel and Third Party Service Providers. We employ personnel and engage other companies and people to perform tasks on our behalf and need to share your personal information with them to provide products or services to you. For example, we use a third party payment processor to process payments on our behalf, so the payment processor will have access to your real name, postal address, and billing information.

3.2. Third Party Applications. If you or the entity you represent (your “Organization”) use third party applications (the “Third Party Apps”) within the Platform, Company will allow the providers of those Third Party Apps (the “Third Party Providers”) to access or use your personal information as required for the interoperation of the Third Party Apps and the Platform. Any Third Party Provider’s use of your personal information is subject to the applicable agreement between either (i) your Organization and such Third Party Provider, or (ii) you and the Third Party Provider. Company is not responsible for any access to or use of your personal information by Third Party Providers. You and your Organization are solely responsible for the decision to permit any Third Party Provider to use your personal information.

3.3. Facebook Marketing. Through a pixel tag placed on our website, we may measure, optimize and build audiences for our advertising campaigns on Facebook. In particular, we will be able to see how our users move between devices when accessing our website and Facebook, to ensure that our Facebook advertising is seen by our users most likely to be interested in such advertising by analyzing which content a user has viewed and interacted with on the website. Your email address may be shared with Facebook as part of this functionality, but it will be “hashed” in your browser so that it is not viewable by Facebook.

3.4. Analytics Services. We use Google Analytics to understand how visitors engage with our Service. You can learn more about the information that Google has access to at the following website: https://policies.google.com/technologies/partner-sites.

3.5. Sale of Information. We do not sell your personal information to third parties.

3.6. Anonymous Information. We may de-identify your personal information so that you are not identified as an individual, and share that information with third parties. We may also provide aggregate usage information to third parties (or allow these third parties to collect aggregate information of activity on our Service), who may use that information to understand how often and in what ways people use our Service, so that they, too, can provide our users with an optimal online experience.

3.7. Business Transfers. If we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, personal information could be one of the assets transferred to or acquired by a third party.

3.8. Legal Compliance. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with governmental requests, law enforcement or court orders, or enforce or apply our Terms of Service and other agreements.

3.9. California Residents Under 16 Years of Age. California law requires us to confirm whether we have actual knowledge that we sell or “share” the personal information of users under 16 years of age, as those terms are defined under California law. Because we do not have users under the age of 18, we do not sell or share the personal information of users under 16 years of age.

4. INTERNATIONAL TRANSFERS.

We may transfer the personal information of users from the European Economic Area, Switzerland, or United Kingdom to the United States. When doing so, we rely on adequacy decisions, data transfer agreements, or other legally compliant mechanisms for such transfers, including standard contractual clauses. You can ask for a copy of these standard contractual clauses by contacting us as set out below.

5. SECURITY.

We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. In addition, we rely on the technical safeguards provided by the third party service providers we use to host, store, and process your personal information. We cannot, however, ensure or warrant that your personal information on the Service may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

6. YOUR RIGHTS.

Who To Exercise Your Rights With. You may have rights under data protection laws in relation to your personal information. You can learn more about your rights further down in this section. If we have collected your personal information as a result of our contractual relationship with you, we are a “controller” of that personal information and you can exercise your rights with respect to your personal information by following the instructions below. However, if we have collected your personal information as a result of agreements we have in place with our clients, we are a “processor” of your personal information and those clients control our use of your personal information and determine how and for what purpose we process your personal information.

If we are a processor of your personal information, and you have any questions or concerns about how your personal information is handled or would like to exercise your rights as a data subject, you should contact the client who has contracted with us to use the Service to process your personal information. That client’s privacy policy governs their use (and our processing) of your personal information. We will provide assistance to the client to address any concerns you may have, in accordance with the terms of our contract with them and applicable law.

Rights of Users in the EEA, Switzerland, and UK. If you reside in the EEA, Switzerland, or the UK and we are a controller of your personal information, you have the following rights:
- Request access to your personal information. You may request a copy of the personal information we hold about you and to check that we are lawfully processing it. Where we have good reason, and where applicable law permits, we can refuse your request for a copy of your personal information, or certain elements of the request. If we refuse your request or any element of it, we will provide you with our reason(s) for doing so.
- Request correction of your personal information. You may request that we correct any incomplete or inaccurate data we hold about you.
- Request erasure of your personal information. You may request that we delete or remove personal information where there is no good reason for us continuing to process it. You may also ask us to delete or remove your personal information where you have successfully exercised your right to object to processing (see below), where we may have processed your personal information unlawfully or where we are required to erase your personal information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.
- Right to Object to or Restrict Processing. In certain circumstances, you have the right to object to our processing of your personal information (for example, if we are processing your personal information on the basis of our legitimate interests but there are no longer any compelling legitimate grounds to justify our processing overriding your rights and interests). You may also restrict our processing of your personal information, for example during a period in which we are verifying the accuracy of your personal information in circumstances where you have challenged the accuracy of that personal information.
- Request the transfer of your personal information to you or to a third party. In certain instances, you have a right to receive the personal information that we hold about you (or a portion thereof) in a structured, commonly used and machine-readable format. In such circumstances, you can ask us to transmit your personal information to you or directly to a third-party organization on your behalf. While we are happy for such requests to be made, we are not able to guarantee technical compatibility with a third-party organization’s systems. We are also unable to comply with requests that relate to personal information of others without their consent.
- Withdraw consent. You may withdraw your consent for our processing of your personal information where we are relying on consent to process that personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw 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.
Rights of All Other Users. Regardless of where you reside, through your account settings, you may access, edit and delete your profile information. Please understand, however, that it may be impossible to delete this information completely, due to backups and records of deletions. In addition, we may deny a deletion request if (i) the denial is necessary for us to comply with applicable law, or (ii) the request pertains to content that you posted on a publicly available portion of the Service and that cannot be deleted without impacting the Service experience for other users. You may not request the removal of de-identified, anonymous, or aggregate data from our databases.

How to Exercise Your Rights. Except for end users in the EEA (please see Section 7 “EU Representative” below), if you wish to exercise any of the rights set out above and we are the controller of your personal information, please contact us at hello@theneuron.com. If you have authorized an agent to exercise your rights on your behalf, the agent may contact us at hello@theneuron.com. Please note that to protect your personal information and the integrity of our Service, we may need to collect additional information to verify your identity (and, if applicable, the authority of your agent) before processing your request. If you are not satisfied with any decision we make with respect to your request, you can let us know the reasons for your concern, and we will review your appeal. If we are the processor of your personal information, please contact the organization through which you have access to our Service in order to exercise rights you may have with respect to your information.</p>

Supervisory Authorities. We welcome and appreciate the chance to address any concerns you may have about the Policy and our collection and use of your personal information. To the extent you feel like we have not addressed your concerns, and depending on your jurisdiction, you may have the right to make a complaint at any time to your data protection supervisory authority. For end users in the EEA, you can find contact information for each country’s supervisory authority here. For end users in the UK, you can find contact information for the Information Commissioner’s Office (ICO) on the ICO’s website here.

7. EU REPRESENTATIVE.

We value your privacy and your rights as a data subject. To help facilitate your privacy rights in the EEA, we have appointed Prighter Group as our EU GDPR representative. Prighter gives you an easy way to exercise your data subject rights, including access and erasure requests. To contact us through our representative, please visit: https://app.prighter.com/portal/15434280780

GDPR Certification: Art 27 representation by Prighter

8. RETENTION OF INFORMATION.

Subject to your right to request deletion of your personal information in accordance with Section 6, we will retain your personal information as long as needed for your use of the Service, your approved receipt of marketing communications from us, our compliance with legal obligations, and to protect our or other’s interests.

9. HOW WE RESPOND TO DO NOT TRACK SIGNALS.

We will honor your exercise of your rights with respect to your personal information in accordance with Section 6. Apart from those rights, we do not respond to “Do Not Track” signals.

10. AGE OF USERS.

Children under the age of 13 are not permitted to use, access or register for the Service in any way. We do not knowingly collect or solicit information from anyone under the age of 13. If we learn that we have collected personal information from a child under the age of 13, we will delete that information as quickly as possible.

11. CHANGES TO POLICY.

We’re constantly trying to improve the Service, so we may need to change this Policy from time to time as well. The date of the last modification will be posted at the beginning of this Policy. It is your responsibility to check from time to time for updates. By continuing to access or use the Service, you are indicating that you agree to be bound by the modified Policy.

12. CONTACT US.

1. If you have any questions or concerns regarding this Policy, please send us a detailed message to our data protection officer at hello@theneuron.com or by mail at: The Neuron Holdings Inc. ATTN: Data Protection Officer, 9450 SW Gemini Dr., PMB 29549Beaverton, Oregon 97008-7105, and we will try to resolve your concerns. In addition, please contact DPO@theneuron.com for all other inquiries.

From time to time, we may receive requests from government agencies to obtain information about our users. In handling such government requests, we greatly value the privacy of your information.

In handling such government requests, we greatly value the privacy of your information. While we may be required to turn over user information at times, we will strive to require a search warrant or subpoena, to the extent that we can reasonably demand such warrant or subpoena, before we turn over information about you and we will also strive to notify users when we receive government requests about their data.