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Privacy Policy

This Privacy Policy applies to the end users (“End Users”) on the platform (“Platform”) operated and owned by Neurion, company registration no. --- (“Neurion”).

This Privacy Policy explains Neurion’s online practices for collection of personal data about the End User when providing the services available on the Platform as part of the subscription to the End User and the rights the End User has to rectify or delete the personal data collected.

By using or accessing the Platform the End User is agreeing to this Privacy Policy. If the End User does not agree with this Privacy Policy, the End User may not use or access the Platform.

1. Controller of personal data

1.1 For the purpose of compliance with the data protection legislation, the data controller is Neurion, Frederiksgade 78, 8000 Aarhus C.

2. Purpose of the collection of personal data

2.1 Neurion will ensure that personal data is collected and processed only in accordance with one of the following purposes:

a) to deliver the services on the Platform;

b) to answer the End User’s questions or complaints about the Platform;

c) to communicate with the End User about the Platform, including but not limited to notify the End User about changes on the Platform;

d) to facilitate Neurion’s understanding of how to improve the Platform, develop new products and services provided on the Platform and to enable and promote the Platform;

e) to analyze the use of the Platform, including but not limited to interaction with applications, advertising, products and services made available on the Platform, linked to or offered on the Platform;

f) to ensure technical functioning of the Platform;

g) to provide, personalize and improve the End User’s experience with the Platform;

h) to provide the End User with information on current activities on the Platform, general announcements, upcoming products and changes to the Platform;

i) to facilitate the provision of services ordered from Neurion, including for cookies to identify End Users and remember their preferences;

j) to enforce this Privacy Policy, including but not limited to protect the rights, property or safety of Neurion.

3. Legal basis for processing

3.1 The personal data is collected and processed in order for Neurion to provide the Platform as a subscription to the End Users in accordance with Neurion’s terms of use which the End Users has agreed to when subscribing to the platform. Consequently, the legal basis for processing the personal data is that the processing is necessary for the performance of a contract to which the End User is a party or that the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, where such interests are not overridden by the interests or fundamental rights and freedoms of the data subject.

4. What kind of personal data is collected

4.1 As the data controller, Neurion will collect, store, and/or use personal data about the End User such as name, email address, and IP address.

5. Processing of personal data

5.1 Neurion collects personal data in various ways, including:

a) Personal data that the End User provides to Neurion through the Platform by filling in forms on the Platform, including information the End User provides when it register to use the Platform;

b) Personal data provided to Neurion through corresponding with Neurion by phone, email or otherwise;

c) Collecting personal data through social media sites, e.g. when the End User connects to the Platform from the End User’s Facebook/Google account, loyalty schemes or contest created by Neurion.

5.2 When the End User ends its subscription to use the Platform, Neurion will anonymise or erase the End User’s personal data from the Platform to ensure the privacy of the End User.

5.3 Notwithstanding section 5.2, Neurion will store the personal data for as long as it is relevant for the purposes set out in section 2 above and as required by law. Notwithstanding the aforementioned, Neurion will at maximum store the End User’s personal data for a period of five (5) years after the End User ends it subscription to the Platform.

6. Processing of traffic data

6.1 Neurion also collects aggregate or non-personal identifiable information to track data such as the total number of visits to the Platform, how the End Users found the Platform, clicks on advertising, products and services offered, linked to or made available on the Platform, the details of the queries and content posted by the End Users. Neurion uses this information to understand how the End User uses the Platform so that Neurion can improve them. Neurion may also share this information with its affiliates, its partners, or other outside companies. No personally identifiable information is collected, stored or disclosed in this process.

7. Transfer of personal data

7.1 Neurion may transfer personal data to affiliate or subsidiary companies, as well as professional advisors. Furthermore, Neurion may transfer personal data to employees, agents, business partners, vendors and suppliers in order to deliver a service to Neurion or on Neurion’s behalf.

7.2 Neurion will transfer personal data in order to comply with legal requirements, hereunder when necessary to investigate fraud.

7.3 The transfer of personal data is conducted in compliance with legal requirements, hereunder that transfers are guarded by data processor agreements, to ensure that data is not processed for other purposes than clearly stated and to ensure adequate security measures.

7.4 The personal data that Neurion collects from the End User may be transferred to and stored at a destination outside the European Economic Area (“EEA”). If personal data is transferred outside of the EEA, Neurion ensures an adequate level of security by transferring to countries approved by the EU Commission as having an adequate level of protection, or by entering into an appropriately-drafted contract between Neurion and the non-EEA entity receiving the data, e.g. the EU Commission’s Standard Contractual Clauses for the transfer of personal data to third country.

8. Third party websites and third party collection of information

8.1 The Platform or emails sent to the End User from Neurion may link to third party websites. It is also possible that the websites and/or emails of third parties may link to Neurion’s website. Neurion is not responsible for the content or the privacy policy employed by third parties. Neurion encourages the End User to read the privacy policies of these third parties before transmitting any personal information to them.

9. Securing the End User’s personal data

9.1 Neurion will ensure appropriate security measures to protect data against accidental or unlawful destruction, loss or alteration and against unauthorized disclosure, abuse, etc. Neurion applies technical security measures such as 2-step authentication. Furthermore, Neurion applies organizational security measures to protect your personal data.

9.2 While Neurion takes reasonable data protection precautions, no security measures are completely secure, and Neurion does not guarantee the security of the End User’s data at any time. The End User can access and amend some of the information Neurion keeps on the Platform, and Neurion encourages the End User to always update his or her personal subscriber information.

10. Right to access and rectify the End User’s personal data

10.1 If the End User has any questions regarding Neurion’s processing of its personal data, the End User can contact Neurion using the contact details described below under Section 12.

10.2 Upon the End User’s request, Neurion will provide the End User with a summary of the personal data that relates to the End User and is being processed by Neurion. This summary can include what kind of personal data is being processed, the purpose of the processing, how the personal data was collected and the category of recipients. Neurion will endeavour to provide this summary within four (4) weeks after the request.

10.3 The End User can request to receive personal data regarding the End User in a format which is structured, commonly recognized and readable for a computer, and the End User has the right to pass this personal data to other data controllers. The End User can request that Neurion passes the personal data directly to another data controller, if this is technically possible.

10.4 The End User can request that any false or misleading personal data processed by Neurion is changed, rectified or erased by Neurion.

10.5 The End User can request to have the processing restricted or to object to the processing, and the End User can withdraw the End User’s consent at any time.

10.6 If Neurion does not comply with their legal obligations, the End User can file a complaint with the Danish Data Protection Agency (“Datatilsynet”), who will consider if the complaint is legitimate.

10.7 Notwithstanding the above, the End User has the right to obtain the erasure of its personal data from Neurion in accordance with the General Data Protection Regulation (Regulation (EU) 2016/679 of 27 April 2016). If the End User wants to know more about its rights to erasure, the End User can contact Neurion at the address set out in Section 12.

11. Updates to this Privacy Policy

11.1 Neurion will keep this Privacy Policy updated and Neurion reserves the right to change this Privacy Policy at any time without notice. Neurion encourages the End User to revisit this Privacy Policy regularly to ensure that the End User is at all times fully aware of it. Any changes will be effective immediately upon posting to Neurion’s website. The End User’s continued subscription, browsing or other use of the Platform constitutes the End User’s acceptance of this Privacy Policy as amended from time to time.

12. Contact details

12.1 If the End User has any questions about this Privacy Policy, its implementation, the accuracy of the End User’s personal information or the use of the information collected, the End User may contact Neurion using the below contact information:
Email address: privacy-policy@neurion.co