Privacy Notice
Last Updated: August 16, 2022
The website available at https://neuronfund.io (the “Website”) and the Neuron App available at https://neuronfund.io/app (the “App”, collectively with the Website, the “Platform”) are operated by Neuron Investments Ltd **** (“we”, “us”, “our”). With respect to personal data collected on the Platform we act as a data controller.
In this Privacy Notice we explain how we collect and process your personal data. Personal data or personal information means any information directly or indirectly identifies you as an individual.
We endeavour to process personal data in accordance with the applicable data protection legislation. If you have any questions regarding processing of your personal data, do not hesitate to contact us via the contact details provided below.
Contact details:
Name: Neuron Investments Ltd, a British Virgin Islands company
Address: Intershore Chambers, PO Box 4342, Road Town, Tortola, VG1110 British Virgin Islands
Email: hello@neuronfund.io
What information we collect
We always strive to comply with the data minimisation principle, meaning that we endeavour to process as little personal data as possible.
When you interact with the Platform, we collect the information in three (3) following cases:
- When you use the App — App Data
In order to enable you to use the App, we must receive your public address (starting with “0x”) in the Ethereum blockchain (the “Address”), and information about your blockchain transactions made with the Address (“Transactions”), which, in certain circumstances, may be considered personal data. If the Neuron Protocol is implemented on other blockchain networks, the references to “Address” and “Transaction” in this Privacy Notice shall apply to the Addresses and Transactions on all applicable blockchain networks.
For this purpose, we collect and process your Address when you connect your digital wallet to the Platform. When you make a Transaction through the Platform, we process information about such Transactions.
While processing the Address and Transactions we cannot identify you as an individual, therefore, this data is not personal. However, under the applicable data protection legislation, if such data is combined with certain other data, it may be considered personal information. We will update this Privacy Notice once and if we are able to identify you as an individual.
- Automatically via Mixpanel — Analytical Data
When you access and use the Platform, certain data may be collected automatically via the Mixpanel solution. More information regarding Mixpanel is available at https://mixpanel.com/home.
Mixpanel provides us with the analytics regarding how users visited the Platform, how long they stayed on the Platform, etc.
Mixpanel collects the following information:
| Data: | Description: |
|---|---|
| Anonymised ID | This is a random identification number automatically assigned by Mixpanel to each unique visitor of the Platform. The ID is used for internal purposes to count the Platform visitors; it does not identify you as a person and it is not used for cross-platform marketing or tracking. For better understanding, here is an example of an internal ID: “088f0704-f4d3-4eef-b54b-48c8a7851f7c”. |
| Country code and city | This allows us to see from which city and country you access the Platform. Unlike IP addresses, we cannot identify your precise location, only the city. |
| Browser details | This includes information about the browser type and its version. |
| Device details | This includes information about the type of the device (e.g., computer, tablet, or smartphone), device version, and screen diagonal. |
| Operating system | This means the information about the type and version of the operating system on your device. |
| Referrer’s URL | This means the information about the website where you clicked a link to access the Platform (i.e., the referrer’s website). |
| Clicks and cursor positions | This implies the information about your activities on the Platform (where you clicked and where you scrolled). |
- When you contact us — Contact Data
We may also collect certain data if you reach us via the contact details indicated on the Platform. In this case we may collect and process certain information related to your request, such as email address, name, or any other data you choose to provide us.
How we use and share the information
General:
We do not sell or rent out your data. However, we may pass your information to our third-party service providers and subcontractors for the purposes of and if it is necessary to provide the Platform and related services to you. These service providers may include, for instance, analytical solution providers, support teams, and hosting service providers. We may also disclose your data if we are under a duty to disclose or share your data in order to comply with a legal obligation. In addition, your data will be transferred to another entity if we sell or otherwise transfer the Platform or its part.
App Data:
We use the App Data to ensure the operation of the App and to enable you to use certain functionality of the App. If and to the extent that the Address and information about your Transactions are deemed personal data, the legal basis for the processing is the necessity for the performance of a contract between you and us.
Please also consider the features of the blockchain data processing described below in section “Your information and blockchain”.
Analytical Data:
The Analytical Data helps us to provide a better user experience by improving the Platform user flow and interface.
In order to collect the Analytical Data, we will ask your consent. You may opt-out from collecting the Analytical Data within the Platform and/or by blocking cookies and similar tracking technologies in your browser settings.
Contact Data:
The purpose for processing your personal data when you contact us is to respond to your inquiry and the legal basis is our legitimate interest to do the same.
Your information and blockchain
Please note that the App interacts with blockchain-based software (smart-contracts) and the App Data can be recorded in the respective blockchain or otherwise used within the blockchain. Ethereum blockchain and other blockchain networks are immutable due to their nature, and are out of our control. This means that due to the structure of the blockchain certain data protection rights or abilities may be limited. It also means that the App Data is publicly available to any person who has access to the respective blockchain. Please be aware that any transaction within a blockchain is irreversible and information entered into a blockchain cannot be deleted or changed.
How long we process your data
As a general rule, we keep the data as long as it is necessary for the purposes it was collected. If necessary under the applicable law or to protect our rights and interest or those of third parties, we may process the data longer.
App Data:
We process your App Data as long as you keep your digital wallet connected to the App. Please note that due to the nature of the blockchain, the App Data may be accessed by us or any third party at any time.
Analytical Data:
We process the Analytical Data for six (6) months from the date when it was collected.
Contact Data:
We store the contact data for one (1) year from the date when you contacted us. We set this retention period during the statutes of limitations established in our Terms of Service. In case of pending legal actions, we may process the Contact Data longer.
Third-party links
This Platform may include links and social media plugins to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and applications, and are not responsible for their privacy statements. When you leave the Platform, we encourage you to read the privacy policy/notice/statement of every website or application you visit.
Your rights
According to the applicable data protection legislation, you may have the following rights:
- request access to your personal data (commonly known as a “data subject access request”). This enables you to ask us whether we process your personal data and, if we do process your data, you may request certain information about the processing activity and/or a copy of the personal data we hold about you and to check that we are lawfully processing it;
- request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or technical reasons which will be notified to you, if applicable, at the time of your request;
- object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
- request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) if you want us to establish the data’s accuracy, (2) where our use of the data is unlawful but you do not want us to erase it, (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, (4) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
- withdraw consent at any time where we are relying on consent to process your personal data. 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;
- not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you;
- file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the applicable data protection legislation. The relevant supervisory authority will particularly depend on where you are located.
Please note that due to the nature of the processing operation, we may not be able to exercise certain rights that you may have pursuant to the applicable data protection legislation. When interacting with a blockchain we may not be able to ensure that your personal data is deleted, corrected, or restricted. This is because the blockchain is a public decentralised network and blockchain technology does not generally allow for data to be deleted or changed and certain rights cannot be enforced. In these circumstances, we will only be able to exercise your rights with respect to the information that is stored on our servers and not on a blockchain. If you want to ensure your privacy rights are not affected in any way, you should not transact on public blockchains (such as the Ethereum blockchain network) as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain.
In order to exercise your rights as a data subject, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.
Children personal data
The Platform is not intended for the use of children (under 16 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, or solicit data from children. We do not knowingly process, collect, or use personal data of children, and in case we receive such data, we will erase it within a reasonable timeframe.
Changes to this Privacy Notice
We keep our Privacy Notice under regular review and may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please review this Privacy Notice regularly.