Last Revised on 16th April 2019
We care about the protection and confidentiality of your data
We care about the protection and confidentiality of your data. We therefore only process your data to the extent that:
It is necessary to provide the Neurum services you are requesting,
You have given your consent to the processing, or
We are otherwise authorized to do so under the data protection laws.
If you have any questions, suggestions or comments, you are welcome to contact us at
Information we collect
We collect information you intentionally provide to us.
Through the registration process and account settings, you can provide information such as your email, name, age, gender and work information.
Within the app, you can do assessments and monitor self-reported emotional health symptoms of depression, anxiety, stress and other mental health detriments. We collect this information to allow you to monitor your progress and to provide you with useful feedback.
Within the app, you can track your mood and associated factors. We collect this information to allow you to understand your mood and factors influencing it.
Within the app, you can have conversations with the Neurum AI Assistant, Clara that generate text-based note entries. We collect this information to allow you to keep a log of your conversations and organize your mental notes.
Within the app, you can gain insights into how your behaviour and context influences your emotional health. To provide this feature, when you allow access and provide us with consent - we collect location, movement information from your device for behavioural data and calendar information for contextual data.
When you allow access and provide us with the consent, we collect information from Apple’s Health App and Google Fit.
We collect technical data that that tells us what hardware and software you are using to access our app, including mobile platform (iOS/Android), version of the app, device model, system version, identifier for advertising in Apple for iOS and Android devices.
We collect app usage data that tells us how you use the app, like how often the app was opened, which areas were clicked on the app, app settings (language, notifications), and feedback data.
How we secure and protect your information
We use a variety of industry-standard security technologies and procedures to help protect your data from unauthorized access, use, or disclosure.
Your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and personal information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.
All transmitted data are encrypted during transmission. We use standard Secure Socket Layer (SSL) encryption that encodes information for such transmissions. All stored data are encrypted and maintained on secure servers. Access to stored data is protected by multi-layered security controls including firewalls, role-based access controls and passwords.
While we use reasonable commercial efforts to protect the data, no technology, data transmission or system can be guaranteed to be 100% secure. In the event of a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to your data, we’ll notify you as soon we spot the issue.
To whom we share your personal information
We neither rent nor sell your information in personally identifiable form to anyone. Conversations with our AI assistant Clara, are not shared with any other company or service without your consent.
However, we may share your information with third parties as described in this section:
Aggregated information that’s no longer personally identifiable.
We may de-identify or anonymize your information so that you are not individually identified, and provide that information to our partners. We also may combine your de-identified information with that of other users to create aggregate de-identified data that may be disclosed to third parties who may use such information to understand how often and in what ways people use our services, so that they, too, can provide you with an optimal experience. For example, we may use information gathered to create a composite profile of all the users of the Services to understand community needs, to design appropriate features and activities. However, we never disclose aggregate information to a partner in a manner that would identify you personally, as an individual.
Protection of Neurum and Others
Where we store your data
We will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
What information you can access
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us: name, password, email address, user profile information, text-based entries, moods, and associated factors, self-reported symptoms.
The information you can view, update, and delete may change as the services change. If you have any questions about viewing or updating information we have on file about you, please contact us at firstname.lastname@example.org.
How to delete your data
You can delete all your data by contacting our team at email@example.com. Our team will provide the support to delete all your data from our databases.
Your data protection rights
As a user of our app, you have the following data protection rights, depending on the circumstances of the specific case:
To receive information about your personal data processed by us and to request access to your personal data and/or copies of these data. This includes information on the purpose of use, the category of data used, its recipients and authorized persons and, if possible, the planned duration of data storage or, if this is not possible, the criteria for determining this duration;
Correction, deletion or limitation of processing
To request the correction, deletion or limitation of the processing of your personal data, e.g. by sending us an e-mail. If (i) the data are incomplete or incorrect, (ii) they are no longer necessary for the purposes for which they were collected, (iii) the consent on which the processing was based has been revoked, or (iv) you have successfully exercised your right to object to data processing; in cases where data is processed by third parties, we will forward your requests for correction, deletion or limitation of the processing to these third parties, unless this proves impossible or involves a disproportionate effort;
Opposition to the processing
To object to the processing for reasons arising from your particular situation;
Refusal and revocation of consent
To refuse your consent or – without affecting the legality of data processing prior to the revocation – to revoke your consent to the processing of your personal data at any time;
To require that you be subject to a decision based exclusively on automated processing only in the exceptional cases provided by law, if that decision has legal effect against you or significantly affects you in a similar manner; should such an automated decision take place in exceptional cases, you have the right to obtain information on the logic involved and the scope of the intended effects;
Right of appeal
Communicate with and, if necessary, complain to the data protection supervisory authority.
We reserve the right to change this data protection declaration in compliance with data protection regulations. The current version can be found here or at another accessible location in our app.