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Privacy Policy

A LEGAL DISCLAIMER

Effective Date: May 05, 2025
Website: www.neuronoirlabs.com
Company: NeuroNoir LTD, registered in Varna, Bulgaria, Commercial Register No. [Insert Registration Number], VAT No. [2082388243]
Contact: NeuroNoirLabs@gmail.com | +35699576906| Panorama 3, Osenovo, Varna, Bulgaria. 
Data Protection Officer:  NeuroNoirLabs@gmail.com

1. Introduction

NeuroNoir LTD ("we," "us," or "our") is committed to protecting your privacy and processing your personal data in compliance with the General Data Protection Regulation (GDPR), the ePrivacy Directive, and applicable Bulgarian data protection laws. This Privacy Policy explains how we collect, use, store, and protect personal data when you visit www.neuronoirlabs.com ("Website"), engage our AI-generated content creation services (e.g., video, audio, imagery), or subscribe to our fan subscription platforms (e.g., DarkAI, Lucid Therapy, Digital Art Collective). Our Website is hosted on Wix.com, which acts as a data processor on our behalf. By using the Website or our services, you consent to the practices described in this Policy.

2. Definitions

  • Personal Data: Any information relating to an identified or identifiable individual (e.g., name, email address).

  • Data Subject: The individual whose personal data is processed (e.g., Website visitors, clients, subscribers).

  • Data Controller: NeuroNoir LTD, determining the purposes and means of processing personal data.

  • Data Processor: Third parties (e.g., Wix.com) processing personal data on our behalf.

3. Data We Collect

We collect personal data to provide our services, improve user experience, and comply with legal obligations. The types of data we collect include:

3.1 Data You Provide:

  • Contact Information: Name, email address, phone number, and billing address when you contact us, request a quote, contract services, or subscribe to fan platforms.

  • Account Information: Username, password, and payment details (e.g., credit card information processed via secure third-party providers) for fan subscriptions or client accounts.

  • User-Generated Content: Feedback, comments, or poll responses submitted via the Website or fan platforms.

  • Client Project Data: Materials (e.g., logos, images) provided for content creation, which may include personal data.

3.2 Data Collected Automatically:

  • Usage Data: IP address, browser type, device information, pages visited, time spent on the Website, and referral sources, collected via cookies and analytics tools.

  • Cookies and Tracking: Essential, functional, analytics, and marketing cookies (e.g., Wix Analytics, Google Analytics) to enhance functionality and personalize content. See our Cookie Policy for details.

  • Geolocation Data: Approximate location based on IP address to comply with regional regulations and tailor content (not precise geolocation).

3.3 Data from Third Parties:

  • Wix.com: As our Website host, Wix collects data (e.g., IP addresses, session data) to operate and secure the Website, per their Privacy Policy (https://www.wix.com/about/privacy).

  • Payment Processors: Secure providers (e.g., Stripe, PayPal) collect payment details for transactions.

  • Social Media Platforms: Data from LinkedIn, Instagram, or other platforms if you interact with us or log in via social media accounts.

4. Legal Basis for Processing

We process personal data under the following GDPR legal bases:

  • Consent (Art. 6(1)(a)): For marketing emails, non-essential cookies, and personalized fan platform content, where you explicitly opt in.

  • Contract Performance (Art. 6(1)(b)): To deliver client services, process subscriptions, and manage accounts.

  • Legitimate Interests (Art. 6(1)(f)): For Website analytics, fraud prevention, and improving services, balanced against your rights.

  • Legal Obligation (Art. 6(1)(c)): To comply with tax, accounting, or data protection laws.

5. Purposes of Processing

We use personal data for the following purposes:

  • Service Delivery: Create and deliver AI-generated content (video, audio, imagery) for clients and provide access to fan subscription platforms (DarkAI, Lucid Therapy, Digital Art Collective).

  • Account Management: Process payments, manage subscriptions, and authenticate users.

  • Communication: Respond to inquiries, send service updates, and provide customer support.

  • Marketing: Send newsletters, promotions, or fan platform updates (with consent, where required).

  • Website Improvement: Analyze usage data to enhance functionality, security, and user experience.

  • Legal Compliance: Maintain records, respond to regulatory requests, and ensure GDPR compliance.

6. Data Sharing and Third Parties

We share personal data only when necessary and with safeguards in place:

  • Wix.com: As our Website host, Wix processes data (e.g., IP addresses, form submissions) to provide hosting, analytics, and security services. Wix complies with GDPR (see https://www.wix.com/about/privacy).

  • Payment Processors: Stripe, PayPal, or similar providers process payment details securely, without sharing full financial data with us.

  • Service Providers: Cloud storage (e.g., Google Drive), project management (e.g., Trello), and analytics (e.g., Google Analytics) providers process data under strict data processing agreements (DPAs).

  • Legal Requirements: We may disclose data to authorities if required by law (e.g., tax audits, court orders).

  • No Sale of Data: We do not sell or rent personal data to third parties for marketing purposes.

7. International Data Transfers

As a Bulgaria-based company, most data is processed within the EU. However, some third-party processors (e.g., Wix, Google) may transfer data outside the EU/EEA. We ensure such transfers comply with GDPR through:

  • Adequacy Decisions: Transfers to countries with EU-recognized data protection standards.

  • Standard Contractual Clauses (SCCs): Binding agreements ensuring GDPR-level protection.

  • Binding Corporate Rules: For processors with global operations. You can request details of transfer safeguards at dpo@neuronoirlabs.com.

8. Data Retention

We retain personal data only as long as necessary for the purposes outlined:

  • Client Data: Retained for 5 years post-contract to comply with Bulgarian tax and accounting laws, unless you request deletion sooner (subject to legal obligations).

  • Subscriber Data: Retained during active subscription and up to 1 year after cancellation, unless deletion is requested.

  • Website Usage Data: Retained for up to 2 years for analytics, unless anonymized.

  • Marketing Data: Retained until you withdraw consent or opt out. Data is securely deleted or anonymized when no longer needed, per GDPR Art. 17.

9. Your Data Protection Rights

Under GDPR, you have the following rights regarding your personal data:

  • Access: Request a copy of your data.

  • Rectification: Correct inaccurate or incomplete data.

  • Erasure: Request deletion of data (subject to legal obligations).

  • Restriction: Limit processing in certain cases (e.g., disputed accuracy).

  • Data Portability: Receive your data in a structured, machine-readable format.

  • Object: Object to processing based on legitimate interests (e.g., marketing).

  • Withdraw Consent: Revoke consent for marketing or non-essential cookies at any time. To exercise these rights, contact our Data Protection Officer at dpo@neuronoirlabs.com. We will respond within 1 month (extendable to 3 months for complex requests). You may also lodge a complaint with the Bulgarian Commission for Personal Data Protection (www.cpdp.bg) or your local supervisory authority.

10. Cookies and Tracking

We use cookies and similar technologies (e.g., pixels, web beacons) to enhance Website functionality, analyze performance, and personalize content, hosted via Wix.com. Categories include:

  • Essential Cookies: Required for Website operation (e.g., session management).

  • Functional Cookies: Enable preferences (e.g., language settings).

  • Analytics Cookies: Track usage (e.g., Wix Analytics, Google Analytics) to improve the Website.

  • Marketing Cookies: Support targeted ads or promotions (with consent). Our Cookie Policy (www.neuronoirlabs.com/cookie-policy) provides details and opt-out instructions. You can manage preferences via the Website’s cookie banner, per the ePrivacy Directive. Declining non-essential cookies does not affect core Website functionality.

11. Security Measures

We implement technical and organizational measures to protect personal data, including:

  • Encryption: SSL/TLS for data transmission; encrypted storage for sensitive data.

  • Access Controls: Restricted access to authorized personnel only.

  • Wix Security: Leveraging Wix.com’s GDPR-compliant security features (e.g., DDoS protection, secure hosting).

  • Regular Audits: Periodic reviews of data processing practices. Despite these measures, no system is 100% secure. We will notify you and authorities of data breaches within 72 hours, as required by GDPR Art. 33.

12. Third-Party Links

The Website may contain links to third-party sites (e.g., social media, payment processors). We are not responsible for their privacy practices. Review their policies before sharing personal data.

13. Children’s Privacy

Our Website and services are not intended for individuals under 18. We do not knowingly collect data from minors. If we discover such data, we will delete it immediately, unless parental consent is provided (per GDPR Art. 8).

14. Changes to This Policy

We may update this Privacy Policy to reflect legal, technical, or service changes. Updates will be posted on the Website with the revised effective date. Significant changes (e.g., new data uses) will be notified via email or Website pop-up, with an option to withdraw consent if applicable. Continued use after changes constitutes acceptance.

15. Contact Us

For questions, concerns, or to exercise your data protection rights, please contact:
NeuroNoir LTD
Email: NeuroNoirLabs@gmail.com
Data Protection Officer: NeuroNoirLabs@gmail.com
Phone: +356 99576906
Address: Panorama 3, Osenovo, Varna, Bulgaria

For complaints, you may also contact the Bulgarian Commission for Personal Data Protection (www.cpdp.bg) or use the EU Online Dispute Resolution platform (https://ec.europa.eu/consumers/odr).

Last Updated: May 05, 2025

PRIVACY POLICY - THE BASICS

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