Privacy Policy

The Neural Factory d.o.o. (hereinafter: “we”, “us”, “our”) considers your privacy and its protection one of the highest priorities in our business operations.

Please read this Privacy Policy carefully to understand your privacy rights and the choices available to you with respect to personal information you share with us, as well as how we use, process, store, protect and disclose your data when we act as a data controller (or similar role under data protection laws), such as when you access our websites, create an account with a personal email address, or are otherwise using our services as an individual (collectively, our “Services”).

This Privacy Policy does not apply when we act as a data processor (or similar role under data protection laws) and process personal information on behalf of commercial customers (Enterprise package). In this case, our SaaS Master Service Agreement governs our processing of your information. To the extent of any conflict between that agreement and this Privacy Policy, that agreement controls.

All collected information is handled in accordance with the Law on Personal Data Protection (“ZZPL”) of the Republic of Serbia.

Personal data means any information that concerns a natural person who is identified or can be identified, either directly or indirectly. A person may be identifiable in particular through details such as their name, personal identification number, location information, online or network identifiers, or through characteristics related to their physical, physiological, genetic, psychological, economic, cultural, or social identity.

Questions, complaints, requests, and additional information regarding this Privacy Policy, personal data protection, or the exercise of your rights may be submitted via email to office@neuralfactory.ai

Information We Collect

Your personal data is required for displaying our website and ensuring its stability and security. You may choose to accept or decline providing your data; however, without certain personal data, we cannot and are not obligated to provide you with access to the Neural Factory platform (i.e. Software and Services).

We do not collect special categories of data - such as information relating to your race, gender, political opinions, religion, health, or sexual orientation - unless you choose to provide such data voluntarily.

We do not collect, access, or store your payment card details. Should you decide to purchase a paid subscription plan, all payment transactions are processed exclusively by Paddle.com, which acts as the merchant of record and an independent data controller for payment and billing purposes. Payment information is submitted directly through Paddle’s secure payment infrastructure and is processed in accordance with Paddle’s applicable privacy policy and legal obligations.

1. Information you provide directly to us

We collect information about you that you voluntarily provide to us when you access or use our Services or otherwise interact with us. This can include:

• Account Information: we collect identifying information, such as your email address and account credentials when you sign up for an account.
• Profile Information: we may also collect profile information, such as name, surname, company name, telephone number, and profile picture.
• Communication Information: If you choose to communicate with us by completing a form, participating in our surveys, subscribing to our mailing lists or other forms of marketing communications, downloading a document, asking for support, attending and/or interacting with us at our conferences or events, or by otherwise reaching out, we may collect your name, contact information, mailing address, and the contents of any messages you send.
• Inputs and Outputs: When you use our Services, we give you the opportunity to create prompts in a variety of formats, including but not limited to free text, files and documents, and images, which generate responses based on your inputs. If you include personal information in your inputs or otherwise as part of the data you share with us as you use the Services, we will collect that information and this information may be reproduced in your outputs. We also give you the ability to provide feedback by flagging outputs, which we will collect if you choose to provide this feedback.
• Other information you may provide to us: we may also collect any other information you choose to directly provide to us in connection with your use of the Software and our Services.

2. Information we collect automatically

We collect information about you automatically when you access or use our Software, Services or otherwise interact with us. This can include:

• Metadata: When you use our Software or Services, we automatically collect metadata, including, without limitation, usage data, trends, statistical data, performance information, analytics, or similar information related to your use of Services, our websites, and third-party integrations to better understand how you use and interact with Neural Factory platform.
• Device Information and log data: When you use our Services, we automatically collect certain information about your device, operating system, device identifiers, and the type of browser you use, consistent with your device and browser permissions. This includes your IP address, browser type, browser language, operating system, the state or country from which you accessed the Services, software and hardware attributes (including device IDs), referring and exit pages and URLs, platform type, the number of clicks, search terms, files you download, domain names, landing pages, pages and features viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, error logs, and other similar information. From your IP address, we may be able to infer your general location.
• Cookies and similar tracking technologies: We and our service providers (third parties with whom we have contractual relations and who perform specific actions on our behalf) use cookies for a variety of purposes, including for analytics and advertising purposes, to recognize you when you return to the Neural Factory platform, to deliver certain features of the Services, to help us understand how users engage with the Software and Services, and to improve your experience. You may set your web browser to notify you when you receive a cookie and to accept or refuse certain cookies. If you elect not to accept cookies, some functionality and areas of the Software or the Services may be restricted. To learn how to manage your cookies, please follow the instructions for your specific browser. Please also visit our Cookie Policy for more information about the types of information we collect via cookies, how we use that information, and how to opt out and/or otherwise manage your cookie settings. When you use the Software or our Services, you agree that our service providers or we may collect general location information (e.g., IP address, country, region, city, or postal code associated with the IP address).

3. Information collected from other sources

We may receive information from third parties to whom you have given permission to share your data or from whom you have allowed us to request your data. For example, when registering by using third-party authentication (Google, Apple), you grant these parties permission to share specific information with us. The exact data received depends on the privacy settings of those third parties and your personal settings. We may also receive information from security, fraud detection, and prevention service providers.

We may collect information about you from other sources, including marketing vendors, survey providers, other websites and services, data enhancement services, social media, conferences, and other industry events, or for other purposes that we explain to you at the time of collection, to the extent permitted by applicable law. We use this information to supplement the information that we collect directly or automatically from you. We combine and use this information for the purposes explained further bellow, including to derive your possible interests and provide more relevant experiences for you and improve our Services, analytics, and advertising. If you have tagged or mentioned us on social media, we may collect the usernames of your social media accounts.

Additionally, your browser may independently collect certain information, governed by its own privacy policy.

4. Information we receive indirectly to train our models

Our models may be trained on a mix of publicly available data from the Internet and data licensed from third parties, each of which could include personal data. As a result, we take measures to safeguard individual privacy rights, including by obscuring, anonymizing, or removing personal identifiers during the training process.

How Do We Use the Collected Information?

We use your data to provide and improve our Services. We do not share your data with third parties without your consent, unless required by law.

Legal grounds for processing personal data, under the ZZPL, include:

1. Processing necessary for the performance of a contract
   Your data is processed when required to fulfil our contractual obligations - e.g. compliance with our Terms of Service accepted during registration.
2. Processing based on legitimate interests
   Your data may be processed to fulfil the legitimate interests of Neural Factory d.o.o. or third parties, provided these interests do not override your rights and freedoms.
3. Processing required by law
   We may process your data when required to comply with legal obligations.
4. Processing based on consent
   Where processing relies on your consent, it is performed only within the scope of that consent. You may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

For example, in order to communicate with you, we use your email address to send email notifications related to the Software or Services, your user account and activities on the Neural Factory platform, or regarding current benefits we offer you as a registered user (such as email address verification during registration, purchase confirmations, notifications about the availability period of a purchased product, password reset requests, etc.). Another example of use is when we use the information to provide you with the Services and operate, maintain, and administer the Services and the Software, secure the Services and resolve technical issues being reported, engage in analysis and research about use of the Software and Services, improve the Software and Services and develop new services.

If you have requested specific information, it is possible that such information will be sent to you via email.

In no event will we use any data you provide to us when you access or use our Software or Services to train our models, including any inputs or outputs.

We may use your email address to send you our newsletter or other marketing communications about our products, services, updates, and promotional offers. We will send such communications based on your prior consent, where required; or based on our legitimate interest, where you have previously purchased our products or services and we promote similar products or services, provided that you were given the opportunity to opt out at the time your email address was collected and in every subsequent message.

If you wish to receive promotional communications (including our newsletter) from us via email, you must actively opt in by selecting the appropriate checkbox. You may do so during registration or at any later time within your user account settings.

We process your personal data for marketing purposes exclusively based on your explicit consent, in accordance with Article 12, paragraph 1, item 1 of the ZZPL.

You may withdraw your consent or object to receiving marketing communications at any time by by clicking the “unsubscribe” link included in each marketing email. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

You agree that we may aggregate and/or de-identify any information we collect through our Software and Services so this information can no longer be linked to you or your device . We may use such de-identified information for any purpose, including, without limitation, research and marketing. We may also disclose such data to any third parties, including advertisers, promotional partners, or sponsors.

We may combine the information we collect through the Services with information that we receive from other sources, both online and offline. We may use this combined information subject to this Privacy Policy.

Data Retention

We store your personal data for as long as necessary to achieve the specific purpose (including compliance with legal, accounting, or reporting obligations), until you withdraw consent, or until the expiration of the consent period. After this period, data is deleted or de-identified.

Data collected during registration is stored until your user account is deactivated.

Exceptionally, data may be retained after consent withdrawal when required to comply with legal obligations or to establish, exercise, or defend legal claims.

Security Measures

We aim at taking reasonable technical, organizational, and personnel measures to protect your data from unauthorized access, according to ZZPL standards. Third parties who process data on our behalf are also bound to implement appropriate security measures.

Despite our efforts, internet communication is not completely secure. Certain steps in the transmission of data cannot be fully protected, and users acknowledge performing such actions at their own risk.

Although our Software and Services are not intended for individuals under the age of 16, we are aware that a child under 16 may attempt to access our Software and Services. We do not knowingly collect personal data from children under the age of 16. If you are under 16, please do not use or provide any information through our platform. In the event that we determine that we have collected or received personal data from a child under the age of 16, such data will be deleted within a reasonable timeframe. Before deleting the data, we may request proof of identity in order to prevent misuse and unauthorized removal of account information. If you believe that we may hold information about a child under the age of 16, or data originating from such a child, please contact us at office@neuralfactory.ai. You acknowledge that we do not verify users’ age, nor are we responsible for doing so.

Sharing with External Data Processors

You agree we may disclose your information within the Neural Factory company group.

We might share your data in situations where it is necessary for us to comply with applicable laws or with requests from governmental authorities; for the purpose of enforcing our Terms of Service, Privacy Policy, and other agreements and rules; when we are required to protect the security and integrity of our Software or Services; or if we believe it is necessary to act in an emergency situation to prevent death or serious injury to persons or property.

With your consent, we may share your data with third parties. Consent can be withdrawn at any time via written request.

We collaborate with external service providers who support the development, hosting, maintenance, backup, storage, and operation of the Neural factory platform. These providers may access certain data only to the extent necessary to perform their tasks and are bound by contractual confidentiality obligations.

Data Transfer

Any transfer of your personal data shall be carried out in accordance with applicable laws and international agreements, with appropriate safeguards in place.

Online Analytics and Third-party tools

We may use third-party analytics tools (e.g., Google Analytics, HubSpot) to collect information via cookies and similar technologies, conduct audits, research, fraud prevention, and provide platform functionalities. To prevent Google Analytics from using your data, you may install the Google Analytics Opt-Out Browser Add-On by clicking here.

Third parties may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you, including your email address. These third parties (e.g., advertising networks and servers such as Google, Meta, and others) may display personalized ads to you while you use the internet and internet-connected applications, as well as access their own cookies or other tracking technologies on your device to support this activity. We do not have access to, nor does this Privacy Policy govern the use of cookies or other tracking technologies that may be placed by third parties that are not affiliated with us. We do not control the opt-out links or the participation of any company in such programs. We are not responsible for the decisions you make using these mechanisms, nor for the availability or accuracy of those mechanisms. Please note that if you choose to opt out, you will still see ads while using the Services, but they will not be tailored to your online behavior. The following websites provide more information about these online advertising activities, and how you can generally control cookies from being put on your computer to deliver tailored advertising: the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices.

If you would like to opt out of our online disclosure of your information through cookie and pixel technology, you may also enable Global Privacy Control within your browser.

Do Not Track is a privacy preference that users can set in certain web browsers. We do not currently recognize or respond to browser-initiated DNT signals. Please note that Do Not Track is a different functionality from the browser-based Global Privacy Control signal, which Neural Factory honors.

Notice to California Residents

If you are a California resident, we are hereby providing you with the following additional information about the purpose for which we use each category of personal information we collect (as defined by the California Consumer Privacy Act - CCPA) along with the categories of third parties to which we disclose personal information for a business purpose or for cross-context behavioral advertising, which includes our use of third-party analytics services and online advertising services. Your contact information (including email) or internet network and device information (including cookie data and IP address) may be disclosed to online advertising and analytics partners. For more information, please see our Privacy Policy. California residents may make certain requests about their personal information under the CCPA. We do not offer any financial incentives in exchange for your personal information. We do not disclose personal information to third parties for their own direct marketing purposes.

Your Rights Regarding personal data

In accordance with the ZZPL, you have the following rights:

1. Right of access
2. Right of rectification
3. Right of erasure (“right to be forgotten”)
4. Right of restriction of processing
5. Right of data portability
6. Right to object
7. Right to withdraw consent
8. Right of complaint with the supervisory authority

To exercise any of these rights, contact us via office@neuralfactory.ai.

We will respond within a reasonable timeframe in accordance with legal requirements.

If you’re accessing our platform as an Enterprise package user and you have questions about how your information is processed in connection with the Software and Services we provide to the Enterprise or want to exercise any of your rights regarding this information, please contact your account administrator.

Latest Version of the Document

This is an updated version of the Privacy Policy and may be amended according to business needs or legal obligations. All changes apply from the date they are published on the Neural Factory platform. By continuing to use the Software and the Services after publication, you acknowledge and accept the updated Privacy Policy.

This document forms an integral part of the Terms of Service.