Neuraan, privacy notice

Neuraan, S.A.P.I. de C.V. (hereinafter “Neuraan®”) is committed to the proper handling of personal data. For this reason, we want you to become familiar with how we collect, use and transfer your personal data under this Privacy Notice, in accordance with the Federal Law on the Protection of Personal Data Held by Private Parties (hereinafter the “Law”), its Regulations and the Privacy Notice Guidelines published in the Official Gazette of the Federation on January 17, 2013.

Neuraan® adheres at all times to the principles of trust, lawfulness, information, fairness, quality, accountability and transparency.

Neuraan® collects information:

Through the website: https://www.neuraan.com
Through the website: https://app.neuraan.com/onboarding/register
Through social media pages (Facebook, Twitter, YouTube, LinkedIn).
Through email.
Through printed media such as surveys and personal consultations.
From any publicly accessible source permitted by the Law.

When you provide personal information to Neuraan®, you accept the terms and conditions of this Privacy Notice.

If you apply for a job opening through the email address hiring@neuraan.com, the use of the personal information you provide will be governed by the Employee and Candidate Privacy Notice.

The services provided by Neuraan® are not directed at minors; therefore, we do not knowingly collect personal data from persons residing in Mexico under 18 (eighteen) years of age.

If you believe your personal data protection rights have been violated in any way, you may go to the National Institute for Transparency, Access to Information and Personal Data Protection (INAI) to request protection.

For more information, you can visit: http://inicio.ifai.org.mx.

I. Personal data

“Personal data” is information that identifies you as an individual or relates to you as an identifiable person. To fulfill the purposes set out in this Privacy Notice, Neuraan® may request, collect, use, store and transfer the following personal data:

First name
Federal Taxpayer Registry number (RFC)
Unique Population Registry Code (CURP)
Address
Landline phone
Mobile phone
Email
Social media profiles authorized by the data subject
Date of birth
Social media username
Passwords and security questions/answers
Purchase history

Neuraan® never uses deceptive or fraudulent means to collect personal data; therefore, data is always collected lawfully and with your prior consent, except for the exceptions permitted by the Law.

Neuraan® does not request sensitive personal data under any circumstances. Sensitive personal data is data that may reveal aspects such as racial or ethnic origin, present and future health status, genetic information, religious, philosophical and moral beliefs, union membership, political opinions or sexual preference. However, if for any reason Neuraan® were to process any sensitive personal data, even if it was not requested, it will be handled with strict confidentiality and will not be transferred to third parties.

II. Financial data

Neuraan® collects your financial data in order to process payments for the services offered. This data consists of:

Credit and debit card numbers
Banking information, such as account numbers

The express consent of the data subject will be required to process this type of data.

III. Identity and address of Neuraan®

Neuraan, S.A.P.I. de C.V., has its address at Calle 18 (eighteen), number 246 (two hundred forty-six), letter “C”, between 43 (forty-three) and 45 (forty-five), Col. Leandro Valle, Zip Code 97143, Mérida, Yucatán, Mexico.

IV. Purposes of personal data processing

Personal data will be processed for the following purposes:

To provide computer products, software and services directly or indirectly related or connected to the services requested from Neuraan® by the data subject.
To create user accounts and profiles generated by the data subject, through the web or mobile applications of the technology platform called “Neuraan”.
To carry out the operations set forth in the contracts to be entered into between the data subject and Neuraan®.
To prepare and maintain a backup copy of the information entered by users and provided by data subjects, so that users can make use of it when they deem necessary.
To authenticate and verify the existence of the data subject, as well as the information provided, in order to transfer any amount arising from the execution of contracts between the data subject and Neuraan®.
To verify data for the performance and fulfillment of any of the contractual obligations between the data subject and Neuraan®.
To create databases for the provision of the service.
To send information related to the services requested by the data subject.
To contact the data subject to inform them of changes to the products and services provided by Neuraan®.
To comply with applicable laws and regulations.
To cooperate with public and government authorities.
To carry out the operations described in the contracts entered into with the data subject.
To provide the services offered by Neuraan® through the web or mobile applications of the technology platform called “Neuraan”.

V. Cookies and web beacons

“Cookies” are data stored directly on the computer you use, through which we receive certain information. We may use cookies and similar tracking technologies on our sites and applications, as well as in HTML-formatted email messages we send you. Cookies and similar technologies allow us to collect information such as browser type, time spent on the services, pages visited, language preferences and other traffic data. We use the information collected for various purposes, including analytics, measuring the effectiveness of our marketing campaigns and displaying ads for products and services we believe may interest you.

The data subject has the right at any time to enable or disable cookies on the site https://www.neuraan.com. To disable or re-enable them, the user can do so through the browser used to access the site. Below we provide information on how to enable and disable cookies in the main web browsers:

If you use Microsoft Edge, under the menu option Settings > Cookies and site permissions.
If you use Firefox, under the menu option Tools > Options > Privacy & Security > Cookies.
If you use Google Chrome, under the menu option Settings > Privacy and security.
If you use Safari, under the menu option Preferences > Security.

Web beacons, on the other hand, are images embedded in a web page or email that can be used to monitor a visitor's behavior, such as storing information about the user's IP address, browsing time, length of interaction on the site, sections viewed, web pages visited before ours and the type of browser used.

Users can change their options through their computer and browsers to stop accepting “web beacons” or to confirm whether or not they accept them.

VI. Limiting and revoking the use or disclosure of personal data

Neuraan® safeguards the data subject's personal data in computer programs with access limited by passwords, and in files in the case of personal data contained in physical documents. The latter are only available to Neuraan® personnel and to third-party recipients with whom confidentiality agreements have been signed and who, by reason of their duties, are authorized to access them.

Neuraan® signs confidentiality agreements with all its personnel and with third-party recipients who use the technology platform called “Neuraan”, which stipulate that the personal data they access in the performance of their duties is considered confidential information and, therefore, if they disclose such confidential information, they will be subject to the corresponding penalty.

Neuraan® has implemented internal policies and processes applicable to its personnel and third-party recipients, under which personal data is used by a minimum number of people, the use of reproduction media is limited, and there is an obligation to destroy all copies or reproductions of documents containing personal data that are not strictly necessary.

Regarding the security measures implemented to protect your personal data and sensitive personal data, we inform you that, for your protection, we have implemented administrative, physical and technical security measures to prevent the loss, misuse or alteration of your information.

You may revoke or limit the consent you granted to Neuraan® for the processing of your personal data, bearing in mind that this will not be immediate in all cases, since Neuraan® may need to continue processing your personal data due to a legal obligation.

To revoke or limit your consent, you must submit a written request addressed to Neuraan®, to the attention of the Personal Data Protection Department, either at Neuraan®'s address or by email to: privacidad@neuraan.com.

This request must contain the following:

The data subject's name and address or another means of communicating the response to your request.
Official documents proving the identity of the holder of the personal data (for example, voter ID card, passport, driver's license or professional license).
Where applicable, documents proving the identity and legal representation of the data subject.
A statement that the sole purpose of this request is to revoke or limit your consent to the processing of your personal data.
Any other element or document that makes it easier to locate the personal data.

This request will be handled within a maximum of 20 (twenty) business days from the date the request is received with acknowledgment of receipt.

For more information, you can visit: http://inicio.ifai.org.mx.

VII. What are ARCO rights?

These are the rights every holder of personal data has to: Access, Rectify, Cancel and, where applicable, Oppose the processing or transmission of their personal data.

Access: to review in detail the data subject's personal data and sensitive personal data held by Neuraan®.

Rectification: the data subject's right to rectify their personal data and sensitive data when it is inaccurate or incomplete.

Cancellation: the data subject has the right to cancel their personal data. This consists of deleting the data provided by the data subject to Neuraan®. Please note that after the request to cancel personal data is received, there will be a blocking period, after which the data will be deleted.

Opposition: that is, to object to the disclosure or transfer of your personal data and sensitive personal data.

Neuraan® has mechanisms that physically and electronically safeguard the personal data and sensitive personal data it has access to.

VIII. How to exercise the rights of Access, Rectification, Cancellation or Opposition (ARCO)

The data subject may exercise their rights of Access, Rectification, Cancellation or Opposition (“ARCO” rights) at any time by submitting a written request addressed to Neuraan®, to the attention of the Personal Data Protection Department, either at Neuraan®'s address or by email to: privacidad@neuraan.com.

This request must contain the following:

The data subject's name and address or another means of communicating the response to your request.
Official documents proving the identity of the holder of the personal data (for example, voter ID card, passport, driver's license or professional license).
Where applicable, documents proving the identity and legal representation of the data subject.
A clear and precise description of the personal data with respect to which the ARCO rights are to be exercised.
Any other element or document that makes it easier to locate the personal data.

This request will be handled within a maximum of 20 (twenty) business days from the date the request is received with acknowledgment of receipt.

IX. Transfer of personal data

Neuraan® may transfer the information provided by the data subject to third parties so that they may manage it for marketing purposes, requesting the data subject's express consent.

Third-party recipients of the information referred to in this section will assume the same obligations as Neuraan® set out in this Privacy Notice, in the Law and its Regulations regarding the processing of the data subject's personal data. Neuraan® will not be responsible for any mishandling of the data subject's personal data by third-party recipients, nor for any consequences of any kind that may arise from it.

Through this Privacy Notice, Neuraan® informs the data subject that it may transfer their personal data to domestic or foreign third parties in the following cases:

When it decides to assign to a third party, by any legal means, any right or action it has against the data subject.
When it requires a third party to provide services or advice regarding any matter with the data subject, including investigation of the data provided by the data subject through the Neuraan technology platform.

X. Changes to the Privacy Notice

When Neuraan® needs to modify the content of this Privacy Notice, it will inform the data subject by publishing the revised Privacy Notice at Neuraan®'s offices and on the website or mobile applications of the “Neuraan” technology platform. Where applicable, we will request your consent again.

If you do not agree with the terms of this Privacy Notice, you must express your objection in the manner indicated in sections V and VII of this notice; otherwise, you will be deemed to have given your consent; however, you may revoke your consent at any time. Neuraan® invites you to review this Privacy Notice periodically to stay informed about matters related to your personal data.

By accepting this Privacy Notice, you are deemed to have given your consent to the processing of your personal data in accordance with it.

XI. Contact information

If you have questions about this Privacy Notice, contact us:

Neuraan, S.A.P.I. de C.V.
Email: privacidad@neuraan.com
Responsible department: Personal Data Protection Department.

Neuraan® adheres at all times to the principles of trust, lawfulness, information, fairness, quality, accountability and transparency.

Neuraan® collects information:

Through the website: https://www.neuraan.com
Through the website: https://app.neuraan.com/onboarding/register
Through social media pages (Facebook, Twitter, YouTube, LinkedIn).
Through email.
Through printed media such as surveys and personal consultations.
From any publicly accessible source permitted by the Law.

When you provide personal information to Neuraan®, you accept the terms and conditions of this Privacy Notice.

If you apply for a job opening through the email address hiring@neuraan.com, the use of the personal information you provide will be governed by the Employee and Candidate Privacy Notice.

The services provided by Neuraan® are not directed at minors; therefore, we do not knowingly collect personal data from persons residing in Mexico under 18 (eighteen) years of age.

For more information, you can visit: http://inicio.ifai.org.mx.

I. Personal data

First name
Federal Taxpayer Registry number (RFC)
Unique Population Registry Code (CURP)
Address
Landline phone
Mobile phone
Email
Social media profiles authorized by the data subject
Date of birth
Social media username
Passwords and security questions/answers
Purchase history

Neuraan® never uses deceptive or fraudulent means to collect personal data; therefore, data is always collected lawfully and with your prior consent, except for the exceptions permitted by the Law.

II. Financial data

Neuraan® collects your financial data in order to process payments for the services offered. This data consists of:

Credit and debit card numbers
Banking information, such as account numbers

The express consent of the data subject will be required to process this type of data.

III. Identity and address of Neuraan®

IV. Purposes of personal data processing

Personal data will be processed for the following purposes:

To provide computer products, software and services directly or indirectly related or connected to the services requested from Neuraan® by the data subject.
To create user accounts and profiles generated by the data subject, through the web or mobile applications of the technology platform called “Neuraan”.
To carry out the operations set forth in the contracts to be entered into between the data subject and Neuraan®.
To prepare and maintain a backup copy of the information entered by users and provided by data subjects, so that users can make use of it when they deem necessary.
To authenticate and verify the existence of the data subject, as well as the information provided, in order to transfer any amount arising from the execution of contracts between the data subject and Neuraan®.
To verify data for the performance and fulfillment of any of the contractual obligations between the data subject and Neuraan®.
To create databases for the provision of the service.
To send information related to the services requested by the data subject.
To contact the data subject to inform them of changes to the products and services provided by Neuraan®.
To comply with applicable laws and regulations.
To cooperate with public and government authorities.
To carry out the operations described in the contracts entered into with the data subject.
To provide the services offered by Neuraan® through the web or mobile applications of the technology platform called “Neuraan”.

V. Cookies and web beacons

If you use Microsoft Edge, under the menu option Settings > Cookies and site permissions.
If you use Firefox, under the menu option Tools > Options > Privacy & Security > Cookies.
If you use Google Chrome, under the menu option Settings > Privacy and security.
If you use Safari, under the menu option Preferences > Security.

Users can change their options through their computer and browsers to stop accepting “web beacons” or to confirm whether or not they accept them.

VI. Limiting and revoking the use or disclosure of personal data

This request must contain the following:

The data subject's name and address or another means of communicating the response to your request.
Official documents proving the identity of the holder of the personal data (for example, voter ID card, passport, driver's license or professional license).
Where applicable, documents proving the identity and legal representation of the data subject.
A statement that the sole purpose of this request is to revoke or limit your consent to the processing of your personal data.
Any other element or document that makes it easier to locate the personal data.

This request will be handled within a maximum of 20 (twenty) business days from the date the request is received with acknowledgment of receipt.

For more information, you can visit: http://inicio.ifai.org.mx.

VII. What are ARCO rights?

These are the rights every holder of personal data has to: Access, Rectify, Cancel and, where applicable, Oppose the processing or transmission of their personal data.

Access: to review in detail the data subject's personal data and sensitive personal data held by Neuraan®.

Rectification: the data subject's right to rectify their personal data and sensitive data when it is inaccurate or incomplete.

Opposition: that is, to object to the disclosure or transfer of your personal data and sensitive personal data.

Neuraan® has mechanisms that physically and electronically safeguard the personal data and sensitive personal data it has access to.

VIII. How to exercise the rights of Access, Rectification, Cancellation or Opposition (ARCO)

This request must contain the following:

The data subject's name and address or another means of communicating the response to your request.
Official documents proving the identity of the holder of the personal data (for example, voter ID card, passport, driver's license or professional license).
Where applicable, documents proving the identity and legal representation of the data subject.
A clear and precise description of the personal data with respect to which the ARCO rights are to be exercised.
Any other element or document that makes it easier to locate the personal data.

This request will be handled within a maximum of 20 (twenty) business days from the date the request is received with acknowledgment of receipt.

IX. Transfer of personal data

Neuraan® may transfer the information provided by the data subject to third parties so that they may manage it for marketing purposes, requesting the data subject's express consent.

Through this Privacy Notice, Neuraan® informs the data subject that it may transfer their personal data to domestic or foreign third parties in the following cases:

When it decides to assign to a third party, by any legal means, any right or action it has against the data subject.
When it requires a third party to provide services or advice regarding any matter with the data subject, including investigation of the data provided by the data subject through the Neuraan technology platform.

X. Changes to the Privacy Notice

By accepting this Privacy Notice, you are deemed to have given your consent to the processing of your personal data in accordance with it.

XI. Contact information

If you have questions about this Privacy Notice, contact us:

Neuraan, S.A.P.I. de C.V.
Email: privacidad@neuraan.com
Responsible department: Personal Data Protection Department.