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PRIVACY STATEMENT

Effective Date: May 25, 2018.

Why We Provide This Statement

Neocortix collects information about you when you use our mobile applications, websites, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us. We take privacy, security and complying with privacy and data protection laws seriously. This Privacy Statement (“Statement”) explains how we collect, use and share personal information. You have several rights concerning your information. Please read the Statement carefully to understand what we do and what your rights are.

Who We Are

The Services are provided by Neocortix, Inc. and its affiliates (collectively “Neocortix”), and the Statement applies to information collected and used by Neocortix. References to “we”, “us”, and “our” mean Neocortix. References to “third-party” mean someone who is not you or us.

We are located at 4633 Old Ironsides Drive, #418, Santa Clara, CA 95054 USA. Our Data Protection Officer (“DPO”) may be contacted at dpo@neocortix.com.

Scope and Application

The Statement applies to persons anywhere in the world who use the Services to provide computing services or complete paid assignments and/or to purchase computing services or commission paid assignments (“Users”).

Our Grounds for Collecting, Using and Sharing Personal Information

We process your information based on:

  • The performance of your contract or to enter into the contract and to take action on your requests. For example, our Terms of Service set out the contract between Neocortix and its Users. In certain circumstances, we need your information to comply with our contractual obligation to deliver the Services, to allow you to register the devices and make them available for compute jobs, to manage your account, and to pay you for renting your device’s processor to us and to our customers.
  • Our legitimate interests, such as fraud prevention, direct marketing, maintaining the security of our network, and improvement of our services. For example, we use identity, device and approximate location information to prevent fraud and abuse and to keep the Services secure. We may also send you promotional communications about the Services. We also analyze how Users interact with our website so we can understand better what elements of the design are working well and not working so well. This analysis allows us to improve and develop the quality of the online experience we offer all our Users. Whenever we rely on this lawful basis to process your data, we assess our business interests to make sure they do not override your rights. Additionally, in some cases, you have the right to object to this processing. For more information, visit the Your Rights section of the Statement.

Collection of Information

Information You Provide to Us

We collect information you provide directly to us, such as when you create or modify your account, request on-demand services, contact customer support, or otherwise communicate with us. This information may include: name, email, phone number, postal address, profile picture, payment method, items requested (for delivery services), and other information you choose to provide.

Information We Collect Through Your Use of Our Services

When you use our Services, we collect information about you in the following general categories:

  • Location Information: We may derive your approximate location from your IP address.
  • Transaction Information: We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged or received, and other related transaction details. Additionally, if someone uses your promo code, we may associate your name with that person.
  • Device Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, serial number, and mobile network information.
  • Log Information: When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.

Important Information About Platform Permissions

Most mobile platforms (e.g. iOS, Android) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the PhonePaycheck app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the PhonePaycheck app seeks before you first use the app, and your use of the app constitutes your consent. You have the right to withdraw your consent at any time. However, if you withdraw your consent, you will not be able to use the Services.

Information We Collect From Other Sources

We may also receive information from other sources and combine that with information we collect through our Services. For example:

  • If you choose to link, create, or log in to your Neocortix account with a payment provider (e.g., PayPal) or social media service (e.g., Facebook), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
  • We do not collect information from third-parties or from publicly available sources.

Use of Information

We may use the information we collect about you to:

  • Provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users and Drivers, develop safety features, authenticate users, and send product updates and administrative messages;
  • Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
  • Send or facilitate communications (i) between you and other Users.
  • Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Neocortix and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
  • Personalize and improve the Services, including to provide or recommend features, content, social connections, or referrals.

Sharing of Information

We may share the information we collect about you as follows:

Through The Services

We may share your information:

  • With other Users to enable them to provide the Services you request, or to enable them to request services from you.
  • With third-parties to provide you a service you requested through a partnership or promotional offering made by a third-party or us;
  • With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public;
  • With third-parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate; and

Other Important Sharing

We may share your information:

  • With Neocortix subsidiaries and affiliated entities that provide services or conduct data processing on our behalf, or for data centralization and / or logistics purposes;
  • With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
  • In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
  • With law enforcement officials, government authorities, or other third-parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of Neocortix or others;
  • In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
  • If we otherwise notify you and you consent to the sharing; and
  • In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

Social Sharing Features

The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.

Data Transfers

The information we collect from you in the EU are transferred from and kept outside the EU because our operations are located in the United States. We rely on [the EU-U.S. Privacy Shield] [contract between us and you] [individual consent] in order to transfer your information outside the EU.

Retention

We will retain your information as long as your account is active, as necessary to provide you with the Services or as otherwise set forth in the Statement. We will also retain and use this information as necessary for the purposes set out in this Policy and to the extent necessary to comply with our legal obligations, resolve disputes, enforce our agreements and protect our legal rights.

We also collect and maintain aggregated, anonymized or pseudonymized information which we may retain indefinitely to protect the safety and security of our Site, improve our Services or comply with legal obligations.

Your Rights

You have the right:

  • To know if we are collecting, using or sharing your information and to request access to this information.
  • To request that we correct your information if it is inaccurate or incomplete.
  • To ask us to erase your information if
    • Your information is no longer necessary for the purposes for which it was collected, used or shared
    • You withdraw the consent on which the collection, use or sharing is based
    • You object to the collection, use or sharing and there is no overriding legitimate interest for continuing the collection, use or sharing
    • You object to the collection, use or sharing of your information for direct marketing purposes
    • Your information was unlawfully collected, used or shared
    • Your information has to be erased in order to comply with a legal obligation
    • Your information was collected in order to offer online services to children
  • To obtain from us a restriction on the collection, use or sharing of your information if
    • You contest the accuracy of your information
    • You have objected to the collection, use or sharing based on legitimate interest and we are considering whether our or a third-party’s legitimate interest ground overrides your interest
    • The collection, use or sharing is unlawful, and you oppose erasure and request the use be restricted instead
    • We no longer need your information, but you require your information to establish, exercise or defend a legal claim
  • To be able to take with you the information you provided to us and to transmit that information to another organization where our collection, use or sharing of that information is carried out by automated means and is based on your consent or the performance of a contract
  • To object to collection, use or sharing based on the purposes of legitimate interest or performance of a legal task, direct marketing and scientific/historical research and statistics
  • Not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you
  • To lodge a complaint with a supervisory authority

How To Exercise Your Rights

You may correct your account information at any time by logging into your online or in-app account. If you wish to cancel your account, please email us at info@neocortix.com. Please note that in some cases we may retain certain information about you as required by law or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debit on your account, or if we believe you have committed fraud or violated our Terms of Service, we may seek to resolve the issue before deleting your information.

In order to access, correct or delete your information, please contact our DPO at dpo@neocortix.com. As long as you are a PhonePaycheck User, we cannot delete your information from our system since it is necessary to serve your account. However, if you are no longer a PhonePaycheck User, you may request to have your personal information deleted from our system by emailing our DPO.

You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or about our ongoing business relations.

Automated Decision-Making

We use Automated Decision-Making to build individual profiles about our Users in order to flag potential violations of our Terms of Service for resolution by our Security and Operations Teams. The significance and consequence of this activity is that accounts and devices may be blocked automatically. The logic we use in automatically blocking accounts and devices takes into account the ways to identify violations of our Terms of Service. If we detect that a PhonePaycheck User has more than one registered Google account, more than one PayPal account, or more than five activated devices, our system will automatically block the accounts and devices and advise the User to contact us at support@neocortix.com, to resolve the issue.

Your California Privacy Rights

California law permits residents of California to request certain details about how their information is shared with third-parties for direct marketing purposes. Neocortix does not share your personally identifiable information with third-parties for the third-parties’ direct marketing purposes unless you consent to our doing so.

Security

We take security seriously, and the security of your personal data is important to us. We follow industry-standard practices to protect the data we collect and maintain, including using Transport Layer Security (TLS) to encrypt information as it travels over the internet. No method of transmission over the internet or electronic storage is completely secure, so Neocortix cannot guarantee its absolute security. Your PhonePaycheck account information is protected by access through your Google account on your device.

We have a Security Incident Response Team (SIRT) and protocol in place in the event of a data breach. We encourage the responsible disclosure of vulnerabilities of our Services by emailing security@neocortix.com.

Children

People under the age of 18 (or the legal age in your jurisdiction) are not permitted to use PhonePaycheck, except as provided in our Terms of Service for Family Members who are at least 13 years old. Neocortix does not knowingly collect any personal information from children under the age of 13 and children under 13 are not permitted to register for an account or use our Services.

If you believe that a child has provided us with personal information, please contact us at support@neocortix.com. If we become aware that a child under age 13 has provided us with personally identifiable information, we will delete it.

Contact Us

If you have any questions about the Statement, please contact us at info@neocortix.com, via our Data Protection Officer at dpo@neocortix.com, or write us at Neocortix Inc., 4633 Old Ironsides Dr. #418, Santa Clara, CA 95054.