Privacy Policy

Welcome to Newrons. We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our mobile application (collectively, the "Platform").

This Privacy Policy applies to information we collect:

• On our website
• Through our mobile application
• When you interact with our blockchain-based services
• Through email, text, and other electronic communications

Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access the Platform.

We collect several types of information from and about users of our Platform:

2.1 Personal Data

Personal data refers to information that identifies or can be used to identify you:

• Contact Information: Email address, name, phone number
• Account Information: Username, password, profile information
• Blockchain Information: Wallet addresses, transaction history
• Technical Data: IP address, browser type, device information
• Usage Data: How you interact with our Platform

2.2 Blockchain-Specific Data

Due to the public nature of blockchain technology:

• Wallet addresses and transactions on public blockchains are visible to anyone
• Smart contract interactions are recorded on the blockchain
• NFT ownership is publicly verifiable

We implement additional privacy measures where possible, including zero-knowledge proofs for certain transactions to enhance privacy.

2.3 Information You Provide

• Information provided when creating an account
• Content submitted when using our services
• Communications with us
• Survey or contest participation

2.4 Automatically Collected Information

We automatically collect certain information when you visit, use, or navigate our Platform:

• Device and connection information (device model, operating system version, unique device identifiers)
• Browsing actions and patterns (pages visited, time spent on pages, click-through patterns)
• Platform usage details (features used, interaction frequency, performance data)
• Diagnostic data (crash logs, performance metrics, app functionality issues)
• Location data (approximate location based on IP address; precise location only with explicit permission)

2.5 App Tracking Transparency

In accordance with Apple's App Tracking Transparency framework, we will request permission before tracking your activity across other companies' apps and websites. This includes:

• Displaying targeted advertisements based on data collected from other companies' apps and websites
• Sharing device identifiers with data brokers
• Sharing your data with third-party advertising networks
• Using third-party analytics tools that combine your data from our app with data from other sources

You can change your tracking preferences at any time in your device's privacy settings. If you choose to opt out of tracking, we will still collect data about your activity within our app for purposes such as analytics, but this data will not be linked with third-party data for advertising purposes.

2.6 Third-Party Services and SDKs

Our app integrates the following third-party services that may collect data:

• Analytics: Google Analytics, Firebase Analytics
• Crash Reporting: Firebase Crashlytics
• Authentication: Auth0, Web3 wallet providers
• Payment Processing: Stripe, Apple Pay
• Cloud Services: AWS, Google Cloud
• Blockchain Infrastructure: Infura, Alchemy

Each of these services collects and processes data according to their own privacy policies, which we encourage you to review.

We use your information for the following purposes:

• To provide and maintain our Platform
• To process and complete transactions
• To manage your account and provide customer support
• To improve and personalize your experience
• To develop new products and services
• To communicate with you
• To protect our Platform and users
• To comply with legal obligations

3.1 Blockchain-Specific Uses

We use blockchain data to:

• Verify digital asset ownership
• Process transactions
• Authenticate users through wallet connections
• Enable smart contract interactions
• Provide proof of authenticity for digital assets

We may share your information in the following situations:

4.1 With Service Providers

We may share your information with third-party vendors, service providers, and other business partners who perform services on our behalf.

4.2 For Business Transfers

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.

4.3 For Legal Purposes

We may disclose your information where required by law or if we believe disclosure will protect our rights, your safety, or the safety of others.

4.4 With Your Consent

We may disclose your information for any other purpose with your consent.

4.5 Blockchain Disclosures

Please note that information recorded on public blockchains is inherently public and cannot be deleted or modified. This includes wallet addresses and transaction details.

We implement appropriate technical and organizational security measures to protect your personal data. However, no electronic transmission or storage system is 100% secure, and we cannot guarantee absolute security.

Our security measures include:

• 256-bit encryption for data at rest and in transit
• Multi-factor authentication
• Regular security audits and penetration testing
• Continuous monitoring systems with real-time threat detection
• Regular third-party security assessments
• Secure development practices and code reviews
• Employee security training and access controls
• Secure data storage with redundancy and backup systems
• Compliance with industry security standards and best practices

We regularly review and update our security practices to address new threats and vulnerabilities. In the event of a data breach that affects your personal information, we will notify you in accordance with applicable laws.

We will retain your personal data 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.

Blockchain data, by its nature, is permanent and immutable. Transactions recorded on the blockchain cannot be deleted.

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

• Right to Access: Request access to your personal data
• Right to Rectification: Request correction of inaccurate information
• Right to Erasure: Request deletion of your personal data where applicable
• Right to Restrict Processing: Request restriction of processing your data
• Right to Data Portability: Request transfer of your data
• Right to Object: Object to processing of your personal data
• Right to Withdraw Consent: Withdraw consent at any time

7.1 How to Exercise Your Rights

To exercise your privacy rights, you can:

• Account Settings: Access and update certain personal information directly through your account settings in the app
• Email Request: Send a detailed request to [email protected] with the subject line "Privacy Rights Request"
• In-App Tool: Use the "Privacy Request" feature in the app's settings menu

For verification purposes, we may need to request specific information to confirm your identity. We will respond to all legitimate requests within the timeframes required by applicable law (typically within 30 days).

7.2 Data Deletion Mechanism

You can request deletion of your account and personal data through the following methods:

• In-App Deletion: Go to Your Profile > Delete Account
• Email Request: Send an account deletion request to [email protected]
• Support Request: Contact our support team through the app

Upon receiving your deletion request, we will:

• Verify your identity
• Delete your account and personal information from our active systems
• De-identify or anonymize any data required for legitimate business purposes
• Ensure deletion from our backups according to our backup rotation schedule
• Send confirmation once the deletion process is complete

7.3 Ohio Privacy Laws

As a company based in Ohio, we comply with all applicable Ohio privacy laws and regulations. Ohio law provides various protections for personal information, including:

• The Ohio Data Protection Act, which provides a legal safe harbor to covered businesses that implement a specified cybersecurity program
• Requirements for notification of security breaches involving personal information
• Protections against identity theft and fraud

We maintain a comprehensive information security program designed to protect your personal information in accordance with Ohio law and industry best practices.

7.4 California Privacy Rights (CCPA)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information, including:

• The right to know what personal information we collect, use, disclose, and sell
• The right to request deletion of your personal information
• The right to opt-out of the sale of your personal information
• The right to non-discrimination for exercising your CCPA rights

To exercise your CCPA rights, please contact us using the methods described above. You may also designate an authorized agent to make a request on your behalf.

We do not sell personal information as defined by the CCPA. However, we do share certain information with third-party partners as described in this Privacy Policy.

7.5 Blockchain Limitations

Due to the immutable nature of blockchain technology, certain rights may be technically limited:

• Information recorded on public blockchains cannot be altered or deleted
• Wallet addresses and transaction histories remain on the blockchain permanently
• While we can delete personal information from our servers, corresponding blockchain data will remain public

Our Platform may contain links to third-party websites. We have no control over the content, privacy policies, or practices of these sites and assume no responsibility for them. We encourage you to review the privacy policies of any third-party sites you visit.

Our Platform is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13 in accordance with the Children's Online Privacy Protection Act (COPPA).

9.1 COPPA Compliance

We take specific steps to comply with COPPA requirements:

• We do not request or require children to disclose more information than is reasonably necessary to participate in an activity
• Parents can review their child's personal information, direct us to delete it, and refuse to allow any further collection or use of the child's information
• We maintain the confidentiality, security, and integrity of information we collect from children

9.2 Parental Rights

If you are a parent or guardian and believe your child under 13 has provided us with personal information without your consent, please contact us at [email protected]. If we learn we have collected personal information from a child under 13 without verification of parental consent, we will take steps to remove that information from our servers.

9.3 Age Restrictions

The App Store requires users to be at least 13 years old to download and use our app. Additionally, certain features of our Platform, particularly those involving blockchain transactions and digital asset ownership, are intended for users who are at least 18 years old or the age of majority in their jurisdiction.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated "Last Updated" date. We encourage you to review this Privacy Policy frequently to stay informed about how we are protecting your information.

Your information may be transferred to and processed in countries other than the country in which you reside. These countries may have data protection laws that differ from those in your country.

We have implemented appropriate safeguards to ensure your data receives an adequate level of protection in any country where it is processed.

If you have questions or comments about this Privacy Policy, please contact us at: