Privacy Policy

1. Who We Are

Neuraspark, LLC is a limited liability company registered in Delaware, United States.

For privacy-related questions or requests, contact us at: office@neuraspark.com

2. Personal Information We Collect

The personal information we collect depends on how you interact with us. The table below maps the categories we collect to the categories defined under the California Consumer Privacy Act (as amended by the CPRA), for the preceding 12 months.

Information you provide directly

When you contact us by email, submit a contact form, schedule a meeting, request information about our services, or communicate with us about a potential project, we may collect:

• first and last name;
• business email address;
• job title;
• company name;
• information you include in your message or inquiry;
• information about your company, project, business requirements, or potential engagement;
• meeting and communication information;
• other information you voluntarily provide to us.

If you become a client, we may also process business and project information necessary to provide our services, manage the engagement, communicate with your team, prepare invoices, and maintain project documentation.

Business contact information obtained from third-party sources

For business development purposes, we may obtain professional contact information through business intelligence and prospecting services such as Apollo. This information may include:

• first and last name;
• business email address;
• job title;
• company name;
• LinkedIn profile URL.

We use this information for B2B sales outreach and related follow-up communications.

Information collected automatically

When you visit our website, we and our technology providers may automatically collect certain information about your device and use of the website, such as:

• IP address;
• browser and device information;
• operating system;
• pages viewed;
• referring and exit pages;
• approximate location derived from IP address;
• date and time of visits;
• interactions with the website;
• clicks and similar website activity;
• cookie and device identifiers;
• advertising and campaign attribution information.

We may collect this information through cookies, pixels, tags, analytics technologies, and similar tools.

California (CCPA/CPRA) category mapping

Legal bases for processing (GDPR)

For each purpose described in Section 3, we rely on one of the following legal bases under Article 6 GDPR:

• Legitimate interests — for B2B prospecting and marketing outreach, responding to inquiries, website analytics, and security. We balance this interest against your rights before relying on it, and you may object at any time (see Section 13).
• Performance of a contract — for processing necessary to provide services to clients, manage an engagement, and issue invoices.
• Legal obligation — for accounting, tax, and regulatory recordkeeping.
• Consent — for non-essential cookies and similar tracking technologies (see Section 5), which you may withdraw at any time without affecting the lawfulness of processing before withdrawal.

3. How We Use Personal Information

We may use personal information to:

• respond to inquiries and communications;
• understand your business needs;
• prepare proposals and estimates;
• conduct B2B business development and sales outreach;
• send appropriate follow-up communications;
• schedule and conduct meetings;
• evaluate potential engagements;
• provide and manage our services;
• communicate with clients and their teams;
• maintain internal project documentation;
• manage our business relationships;
• issue invoices and maintain financial and accounting records;
• operate, maintain, secure, and improve our website;
• measure website traffic and usage;
• understand the effectiveness of our marketing activities;
• measure interactions with marketing campaigns;
• conduct advertising and remarketing activities where applicable;
• detect misuse, fraud, or security incidents;
• comply with legal, tax, accounting, and regulatory obligations;
• establish, exercise, or defend legal claims.

We may also use aggregated or de-identified information that does not reasonably identify an individual for analytics, business planning, and service improvement.

4. Business Development and Email Communications

Neuraspark may use professional business contact information to contact representatives of companies that we believe may have an interest in our services.

We currently source certain business contact information through Apollo and conduct outreach manually.

We may track interactions with business communications, including link clicks, replies, and subsequent communications and activity relating to the potential business relationship.

Recipients may ask us to stop sending marketing or sales communications at any time by replying to the message or contacting office@neuraspark.com.

When someone opts out, we may retain limited information, such as their email address and opt-out status, on a suppression or “do not contact” list to ensure that we respect the request in the future.

Commercial emails sent from the U.S. are subject to the CAN-SPAM Act, which applies to B2B messages as well as consumer messages. Among other requirements, recipients must be given a clear method of opting out, and an opt-out request must be honored within 10 business days. We do not use false or misleading header information or deceptive subject lines, and every commercial email identifies itself as an advertisement where required and includes our valid physical postal address.

5. Cookies, Analytics, and Advertising Technologies

We use or may use cookies and similar technologies to operate our website, understand how visitors use it, measure marketing performance, and support advertising activities.

Essential technologies — required for website functionality, security, network management, and similar operational purposes.

Analytics technologies — we may use analytics services to understand how visitors interact with our website, including page views, traffic sources, interactions, devices, and general usage patterns. These services may include technologies provided by Google, such as Google Analytics and Google Tag Manager.

Advertising and measurement technologies — we may use advertising pixels, tags, or similar technologies to measure campaign performance and, where applicable, support advertising or remarketing. Providers may include Google, Meta, LinkedIn, and other advertising and analytics providers. These providers may receive device identifiers, IP addresses, website activity, cookie identifiers, and similar online information in accordance with their own privacy practices.

“Sale” and “sharing” of personal information. We do not sell personal information for money. However, under California law and the laws of several other states, allowing advertising partners (such as Google, Meta, or LinkedIn) to use cookies or pixels for cross-context behavioral advertising may be considered a “sale” or “sharing” of personal information, even without a monetary exchange. To the extent we engage in such activity, you may opt out using the mechanism described in Section 13 below (“Your Privacy Choices”).

Consent for non-essential cookies. In line with our voluntary GDPR commitment (see introduction), we do not set analytics, advertising, or measurement cookies until you have given affirmative, opt-in consent through our cookie preferences banner, with the ability to accept or reject each category separately. Essential cookies are excluded from this requirement because they are necessary for the website to function. You may withdraw your consent at any time through the same cookie preferences interface.

Users may manage certain cookies and tracking technologies through our cookie preferences interface and through their browser settings.

6. Online Tracking Disclosures

Some browsers provide “Do Not Track” (“DNT”) signals. Because there is not currently a universally accepted technical standard for responding to DNT signals, our website may not respond to all DNT signals.

Third-party analytics, advertising, and technology providers may collect information about your online activities over time and across different websites or services when their technologies are enabled on our website.

Global Privacy Control (GPC). Where you access our website using a browser or extension that transmits an opt-out preference signal such as Global Privacy Control, we will treat that signal as a valid request to opt out of the sale/sharing of your personal information for that browser or device, to the extent required by applicable law (including the laws of California, Colorado, and Connecticut).

This disclosure is also made in connection with the California Online Privacy Protection Act (CalOPPA) and the Delaware Online Privacy and Protection Act (DOPPA), both of which require disclosure of our approach to DNT signals and whether third parties may track user activity over time and across different websites.

7. Scheduling, Video, and Embedded Content

Our website or communications may use third-party services to facilitate meetings, demonstrations, videos, or other content, including Calendly, Loom, YouTube, and similar communication or content providers. When you interact with these services, the relevant provider may collect information directly from you or receive information about your interaction in accordance with its own privacy practices.

8. Artificial Intelligence and Development Tools

We may use artificial intelligence, software development, and productivity tools to support our internal operations and delivery of services, including services such as ChatGPT, Claude, Gemini, Cursor, GitHub Copilot, and other similar AI and development tools.

Depending on the engagement, information relating to a project may be processed using these tools where appropriate.

We do not intentionally provide personal information to AI services for the purpose of training general-purpose artificial intelligence models. We aim to minimize the amount of personal information submitted to AI systems and, where available at no additional cost, use privacy and data-control settings offered by each provider (such as opting out of use of inputs for model training, where that option is built into the free or standard tier we use).

9. How We Share Personal Information

We may disclose personal information to service providers and contractors that help us operate our business and provide our services, including providers of: email and business productivity services; cloud storage; spreadsheets and internal CRM systems; website hosting and infrastructure; analytics; advertising and marketing; meeting scheduling; video hosting; project management; business intelligence and prospecting; AI and software development tools; accounting and financial services; and professional advisory services.

Our current operational tools may include Google Workspace, Google Drive, Google Sheets, Apollo, LinkedIn, Calendly, Loom, YouTube, ClickUp, and the AI or development tools described in Section 8.

We may also provide information to developers, contractors, accountants, professional advisers, or other service providers where reasonably necessary to operate our business or perform services for a client.

We may disclose information where required by law, legal process, court order, subpoena, or governmental request, or when reasonably necessary to protect our rights, users, business, or others.

If Neuraspark is involved in a merger, acquisition, financing, restructuring, sale of assets, or similar corporate transaction, personal information may be disclosed or transferred as part of that transaction.

As described in Section 5, certain disclosures to advertising partners for cross-context behavioral advertising may be considered a “sale” or “sharing” under California and other state laws. We do not otherwise sell personal information to third parties for money.

Data processing agreements. In line with our voluntary GDPR commitment, we enter into data processing agreements with service providers who process personal information on our behalf, requiring them to process it only on our instructions, keep it confidential, and apply appropriate security measures.

10. International Processing

Neuraspark is based in the United States, and our services are offered exclusively to businesses and business professionals located in the United States. We do not direct our website, marketing, or outreach activities toward individuals located in the European Union, United Kingdom, or Switzerland, and we do not knowingly target or monitor the behavior of individuals located there.

Members of our team and contractors supporting our operations may access information from Poland or other locations in order to provide services to our U.S. clients. Our technology service providers may also process information in the United States and other countries in which they or their service providers operate. Accordingly, personal information may be processed in jurisdictions other than the jurisdiction from which it was originally collected.

Our approach to GDPR. Because part of our team operates from Poland on an ongoing basis, whether this constitutes an “establishment” that triggers GDPR under Article 3(1) is a fact-specific legal question. Rather than resolve that question, we have chosen to apply GDPR-equivalent rights and safeguards to all personal information we process, as described throughout this Policy (see Sections 2, 5, 9, and 13).

International transfers. Where personal information is transferred between the United States and Poland, or to other service providers operating outside the European Economic Area, we rely on appropriate safeguards, such as the EU Standard Contractual Clauses, to protect that information in line with GDPR requirements.

11. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including business, contractual, legal, security, accounting, and compliance purposes.

• Outbound and prospecting leads: generally up to 12 months following the last outreach or meaningful activity, unless there is an ongoing business conversation or another legitimate reason to retain it.
• Opt-out records: we may retain the minimum information necessary to maintain your opt-out preference and prevent future unwanted outreach.
• Inquiries and proposals that do not result in an engagement: generally up to 12 months following the last substantive interaction.
• Client and project information: generally for the duration of the engagement and for up to 3 years following completion, unless a longer period is necessary for contractual, legal, dispute-resolution, or other legitimate business requirements.
• Accounting and tax records: for the period required under applicable tax, accounting, and legal requirements.
• Website analytics and technical information: for periods determined by our analytics settings, security requirements, and legitimate operational needs.

We may retain information for longer where reasonably necessary to comply with law, respond to disputes, enforce agreements, or protect legal rights.

12. Data Security

We use reasonable administrative, organizational, and technical measures designed to protect personal information against unauthorized access, disclosure, alteration, loss, or misuse. However, no method of transmitting or storing information electronically is completely secure, and we cannot guarantee absolute security.

13. Your Privacy Rights and Choices

Depending on where you live, you may have rights relating to your personal information under applicable state privacy laws.

General rights. Subject to certain exceptions, you may have the right to request:

• access to personal information we maintain about you;
• correction of inaccurate information;
• deletion of certain information;
• information about how we use or disclose personal information;
• withdrawal from marketing communications;
• to opt out of the sale/sharing of personal information or targeted advertising;
• other rights provided by applicable law.

California residents. Based on Neuraspark's current size and data volumes, Neuraspark does not currently meet the applicability thresholds under the CCPA/CPRA (revenue under $25,000,000, and well under 100,000 California consumer/household records processed annually). As a matter of good practice — and in case that changes as the business grows — we nonetheless extend the following to California residents who contact us: the ability to request access to, correction of, or deletion of personal information we hold about you, and to opt out of any use of cookies/pixels for cross-context behavioral advertising. Contact office@neuraspark.com to make such a request.

Colorado, Connecticut, Virginia, Utah, Texas, Oregon, and other states with comprehensive privacy laws. If you are a resident of a state with a comprehensive consumer privacy law, you may have similar rights to those described above. Where required by Colorado or Connecticut law, if we deny your request, you may appeal the decision by contacting us at office@neuraspark.com; if your appeal is denied, we will provide information about further steps available to you, which may include contacting your state Attorney General.

Your Privacy Choices / opt-out of sale or sharing. To opt out of the sale or sharing of your personal information for cross-context behavioral advertising, you may: (a) use our cookie preferences banner; (b) enable a recognized opt-out preference signal such as Global Privacy Control (see Section 6); or (c) contact us directly at office@neuraspark.com.

How to submit a request. You may submit a privacy request by contacting office@neuraspark.com. We may need to verify your identity before completing certain requests. If applicable law provides additional privacy rights or an appeal process, we will handle eligible requests in accordance with that law.

Rights under GDPR (applied voluntarily, as described in Section 10). In addition to the rights above, and regardless of where you are located, you have the right to:

• access the personal information we hold about you and receive a copy of it;
• rectification of inaccurate or incomplete personal information;
• erasure (“right to be forgotten”) of your personal information, subject to legal or contractual exceptions;
• restriction of processing in certain circumstances;
• data portability — to receive personal information you provided to us in a structured, commonly used, machine-readable format;
• object to processing based on our legitimate interests, including an unconditional right to object to direct marketing at any time;
• withdraw consent at any time, where processing is based on consent (such as non-essential cookies), without affecting the lawfulness of processing before withdrawal.

We do not make decisions about you based solely on automated processing, including profiling, that produce legal or similarly significant effects.

Providing personal information to us is generally voluntary; however, where we need certain information to respond to your inquiry, provide services, or comply with a legal obligation, we will let you know if that information is required and what happens if you choose not to provide it.

We aim to respond to rights requests within one month of receipt. This period may be extended by a further two months where necessary, taking into account the complexity and number of requests; we will inform you of any such extension within one month of your request.

Right to lodge a complaint. You have the right to lodge a complaint with a data protection supervisory authority. If you are in Poland, this is the Polish Data Protection Authority (Urząd Ochrony Danych Osobowych, uodo.gov.pl); if you are located elsewhere in the EU/EEA, you may contact your local supervisory authority instead.

14. Third-Party Websites and Services

Our website may contain links to third-party websites and services, including LinkedIn, YouTube, Loom, or other platforms. We are not responsible for the privacy practices of websites or services that we do not control. We encourage you to review their privacy policies before providing personal information.

15. Children's Privacy

Our website and services are intended for businesses and adult business professionals and are not directed to children. We do not knowingly collect personal information from individuals under the age of 18. If we learn that personal information of a person under 18 has been provided to us inappropriately, we may take reasonable steps to delete it.

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes to our services, technology, business practices, or legal requirements. When we make changes, we will post the updated Privacy Policy on our website and update the “Effective Date” at the top of the policy. If we make material changes, we may provide additional notice through our website or another appropriate communication method.

17. Contact Us

If you have questions about this Privacy Policy, our privacy practices, or personal information we maintain about you, contact:

Email: office@neuraspark.com