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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.

2.1. Voluntarily Disclosed Information

Purpose for CollectionType of Personal InformationHow we collect that informationLawful Basis for Processing
Account CreationReal name, Email AddressDirectly from youYour consent; Performance of a contract with you; Legal compliance; Necessary to protect your (or someone else's) vital interests; Public interest
Marketing communicationsReal name, email addressDirectly from youYour 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 Cookies 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. 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, 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

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. 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: to request access to your personal information; to request correction of your personal information; to request erasure of your personal information; to object to or restrict processing of your personal information; to request the transfer of your personal information to you or to a third party in a structured, commonly used and machine-readable format; and to withdraw consent where we are relying on consent to process your personal information (this will not affect the lawfulness of any processing carried out before 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.

Supervisory Authorities. 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 at edpb.europa.eu. For end users in the UK, you can find contact information for the Information Commissioner's Office (ICO) at ico.org.uk.

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

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

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 29549, Beaverton, 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. 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.

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