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Privacy Policy

Last Updated: June 20, 2025

1. Introduction

Welcome to NeiryLab ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website https://app.neiry.ai (the "Service") operated by NeiryLab.

Please read this Privacy Policy carefully. By accessing or using our Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access the Service.

2. Important Disclaimers

Age Restriction

Our Service is intended for users who are 18 years of age or older. We do not knowingly collect personal information from individuals under 18 years of age. If you are under 18, please do not use our Service or provide any personal information.

Cryptocurrency and Regulatory Notice

Our platform discusses and involves cryptocurrency technologies, including Solana blockchain integration. Please be aware that cryptocurrency regulations vary significantly by jurisdiction, and cryptocurrencies may be restricted or prohibited in certain countries.

Countries including but not limited to China, Algeria, Bangladesh, Nepal, Afghanistan, and others have imposed complete or partial bans on cryptocurrency activities. Some jurisdictions may restrict cryptocurrency trading, ownership, or use as payment methods.

Before using our Service or engaging with cryptocurrency-related features, you are responsible for:

  • Verifying the legal status of cryptocurrencies in your jurisdiction
  • Ensuring compliance with all applicable local laws and regulations
  • Understanding that cryptocurrency transactions may be prohibited or restricted in your country

We do not provide legal advice regarding cryptocurrency regulations. If you are unsure about the legal status of cryptocurrencies in your jurisdiction, please consult with qualified legal counsel before using our Service.

Wallet Connection Security

When connecting your cryptocurrency wallet to our Service:

  • Wallet Responsibility: You are solely responsible for the security of your wallet and private keys
  • Public Information Only: We only access your wallet's public key and public transaction history
  • No Private Key Access: We never request, access, or store your private keys or seed phrases
  • Connection Consent: By connecting your wallet, you consent to our access of your public wallet information
  • Wallet Provider Terms: Your use of wallet connection features is also subject to your wallet provider's terms of service and privacy policy

3. Information We Collect

Personal Information You Provide

We collect the following personal information when you voluntarily provide it to us:

  • Email Address: Used for communication and application processing
  • Solana Wallet Public Key: Used for blockchain-related operations and user identification
  • Twitter Handle: Used for social media integration and verification through Twitter login

Wallet Connection and Identification

We use wallet-based identification as a primary method of user authentication:

  • Wallet Connection: Users connect their cryptocurrency wallets through our wallet selection module
  • Public Key Collection: When you connect your wallet, we collect your wallet's public key for identification purposes
  • Authentication Process: Your connected wallet serves as your unique identifier within our system
  • Wallet Interaction Data: We may collect information about wallet connection attempts, successful connections, and associated blockchain transactions related to our Service

Automatically Collected Information

We may automatically collect certain information about your device and usage of our Service through third-party analytics tools:

  • Analytics Data: We use Umami Analytics to collect anonymous usage statistics, including pages visited, time spent on the Service, and general geographic location
  • Technical Information: Device type, browser type, operating system, and IP address (anonymized)

Third-Party Services

We integrate with the following third-party services that may collect additional information:

  • Tally Forms: Used for form submissions and data collection
  • Twitter Login: Used for authentication and social media integration
  • Umami Analytics: Used for website analytics and performance monitoring

4. How We Use Your Information

We use the collected information for the following purposes:

  • Application Processing: To review and process applications submitted through our neurotechnology accelerator program
  • Communication: To contact you regarding your application status, program updates, and related communications
  • Service Improvement: To analyze usage patterns and improve our Service through Umami Analytics
  • User Identification and Authentication: To identify and authenticate users through connected cryptocurrency wallets and Twitter login integration
  • Wallet-Based Operations: To facilitate wallet connections, verify wallet ownership, and enable blockchain-related features
  • Technical Operations: To ensure proper functioning of our wallet selection module and blockchain-related features using your Solana wallet information

5. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), our legal basis for processing your personal information includes:

  • Legitimate Interest: For analytics, service improvement, and technical operations
  • Consent: For optional social media integration and marketing communications
  • Contract Performance: For processing applications and providing our accelerator services

6. Information Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your information only in the following circumstances:

  • Service Providers: With trusted third-party service providers (Tally Forms, Umami Analytics, Twitter) who assist in operating our Service
  • Legal Requirements: When required by law, court order, or government investigation
  • Business Protection: To protect our rights, property, or safety, or that of our users
  • Business Transfer: In connection with any merger, acquisition, or sale of company assets

We ensure that all third-party service providers maintain appropriate data protection standards and use your information only for the specific purposes we authorize.

7. Data Security

We implement appropriate technical and organizational security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

  • Encryption of data in transit and at rest
  • Access controls and authentication procedures
  • Regular security assessments and updates
  • Secure hosting infrastructure

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

  • Access: Request access to your personal information we hold
  • Correction: Request correction of inaccurate or incomplete information
  • Deletion: Request deletion of your personal information (subject to legal obligations)
  • Portability: Request a copy of your information in a portable format
  • Objection: Object to processing based on legitimate interests
  • Withdrawal: Withdraw consent for processing based on consent

To exercise these rights, please contact us at gm@neiry.ai with your request and proof of identity.

9. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

  • Application Data: Retained for the duration of the accelerator program and up to 3 years afterward for program evaluation and alumni relations
  • Analytics Data: Anonymized analytics data may be retained indefinitely for service improvement
  • Communication Records: Retained for up to 2 years after the conclusion of our business relationship

10. International Data Transfers

Our Service may involve transferring your information to countries outside your jurisdiction. When we transfer personal information internationally, we ensure appropriate safeguards are in place, including:

  • Adequacy decisions by relevant data protection authorities
  • Standard contractual clauses approved by competent authorities
  • Other legally recognized transfer mechanisms

11. Cookies and Tracking Technologies

Currently, our Service does not use cookies for tracking purposes. We use Umami Analytics, which is a privacy-focused analytics platform that operates without traditional tracking cookies. However, third-party services integrated into our platform (such as Twitter login) may use their own cookies and tracking technologies governed by their respective privacy policies.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

  • Posting the updated Privacy Policy on our Service with a new "Last Updated" date
  • Sending an email notification to registered users (if applicable)
  • Displaying a prominent notice on our Service

Your continued use of the Service after any changes constitutes your acceptance of the updated Privacy Policy.

13. Children's Privacy

Our Service is not directed to individuals under 18 years of age, and we do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take steps to delete such information promptly.

If you are a parent or guardian and believe that your child has provided us with personal information, please contact us immediately at gm@neiry.ai.

14. California Privacy Rights

California residents may have additional rights under the California Consumer Privacy Act (CCPA), including:

  • The right to know what personal information we collect and how it is used
  • The right to delete personal information we have collected
  • The right to opt-out of the sale of personal information (we do not sell personal information)
  • The right to non-discrimination for exercising privacy rights

To exercise these rights, please contact us at gm@neiry.ai.

15. Contact Information

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Email: gm@neiry.ai
Website: https://app.neiry.ai

We will respond to your inquiry within a reasonable timeframe, typically within 30 days of receipt.

16. Governing Law

This Privacy Policy is governed by and construed in accordance with applicable data protection laws and regulations. Any disputes arising from this Privacy Policy will be resolved according to the jurisdiction's relevant legal framework.