Effective Date: July 27, 2025This Privacy Policy explains how Neuro Foundation LLC (“we”, “our”, “Operator”) collects, uses, shares and stores information when you use our services, including:
- The Neurodex non‑custodial trading interface at https://neurodex.ai (the “Platform”)
- The Neurobro AI Agent on Telegram
- The Neurobro Landing Page and Website
- The Neurodex Terminal Trading Platform
1. Summary
- We collect technical data required to operate our blockchain services: wallet addresses, IP‑derived region, server logs, and analytics data.
- We use analytics services including Google Analytics and PostHog to improve our services.
- For AI Agent services, we collect authentication information and chat history to enable communication.
- We do not collect payment‑card data and maintain non‑custodial practices for wallet interactions.
- We use JWT tokens for authentication across our services.
2. What We Collect
Wallet address you connect
Wallet address you connect
Purpose: Route your transaction, apply referral fee
Lawful Basis: Contract (you request a swap)
Lawful Basis: Contract (you request a swap)
IP‑derived country/region
IP‑derived country/region
Purpose: Enforce geo‑blocks & sanctions policy
Lawful Basis: Legal obligation (OFAC/UN sanctions); Legitimate interest (prevent abuse)
Lawful Basis: Legal obligation (OFAC/UN sanctions); Legitimate interest (prevent abuse)
Chainalysis Sanctions Oracle response
Chainalysis Sanctions Oracle response
Purpose: Block sanctioned / high‑risk wallets
Lawful Basis: Legal obligation
Lawful Basis: Legal obligation
Server logs
Server logs
Purpose: Debug and ensure security
Lawful Basis: Legitimate interestIncludes: timestamp, endpoint, error codes
Lawful Basis: Legitimate interestIncludes: timestamp, endpoint, error codes
Analytics data
Analytics data
Purpose: Improve user experience and service performance
Lawful Basis: Legitimate interestServices Used: Google Analytics, PostHog
Includes: page views, user interactions, device information, usage patterns
Lawful Basis: Legitimate interestServices Used: Google Analytics, PostHog
Includes: page views, user interactions, device information, usage patterns
Authentication information
Authentication information
Purpose: Provide AI Agent services and maintain user sessions
Lawful Basis: Contract (you request our services)Includes: JWT tokens, user identifiers, session data
Lawful Basis: Contract (you request our services)Includes: JWT tokens, user identifiers, session data
Chat history
Chat history
Purpose: Enable AI Agent communication and improve responses
Lawful Basis: Contract (you request AI Agent services)Includes: messages exchanged with AI Agent, conversation context
Lawful Basis: Contract (you request AI Agent services)Includes: messages exchanged with AI Agent, conversation context
We use cookies and local storage for analytics services and authentication. JWT tokens are used for secure authentication across our services.
3. How We Use the Data
Service Provision
To provide our services - build and relay your swap transactions, enable AI Agent communication, and maintain user sessions.
Compliance
To comply with sanctions laws - screen wallets using the Chainalysis Sanctions Oracle, which compares wallet addresses against OFAC, UN, EU, and other global lists.
Security
To secure our services - detect DDOS or abuse, maintain authentication security.
Analytics & Improvement
To analyze usage patterns and improve our services using Google Analytics and PostHog.
We do not sell or share your data with advertisers. We may share hashed logs with regulators or auditors if legally compelled. Analytics data is processed according to the respective privacy policies of Google Analytics and PostHog.
4. Data Retention
Wallet & swap logs
12 months then deleted/aggregated
IP‑level server logs
30 days unless required for security investigation
Chat history
12 months or until user requests deletion
Analytics data
As per Google Analytics and PostHog retention policies
No address hashes from sanctions screening are stored. Wallets flagged by Chainalysis are blocked at runtime without persistent storage. JWT tokens expire according to session settings.
5. Your Rights (EU/EEA & UK GDPR)
If you are in the EU/EEA or UK, you have the right to:Access
Access
Request a copy of data we hold about you.
Rectify
Rectify
Correct inaccurate data.
Erase
Erase
Request deletion where we no longer have a legal ground.
Restrict or Object
Restrict or Object
Restrict or object to processing in certain cases.
Data Portability
Data Portability
Receive data in a machine‑readable format.
6. Marketing and Newsletter Communications
When you sign in to Neurodex.ai using social‑login providers (Google Sign‑In, Apple ID), we receive your verified email address through our email‑delivery platform, Privy, Inc. (privy.io).What We Collect
We collect your verified email address and any display name shared by social‑login providers through our email‑delivery platform, Privy, Inc.Why We Collect It
We use your email address solely for non‑transactional communications:- Weekly product‑update newsletters
- Feature announcements
- Curated market recaps and relevant content
Legal Grounds for Processing
European Economic Area & UK: Your explicit consent (GDPR Art. 6(1)(a)). Marketing consent is optional and not required to use Neurodex.ai. Canada: Implied or express consent under CASL with business address and unsubscribe mechanism in every message. United States: CAN‑SPAM Act compliance with clear promotional identification and opt‑out links. California (CCPA/CPRA): We do not “sell” or “share” your personal information for cross‑context behavioural advertising.Communication Frequency
By default, we send at most one newsletter per week. Material changes to frequency will be communicated and may require fresh consent.How to Unsubscribe
You can opt out at any time by either:- Clicking the unsubscribe link in any marketing email
- Toggling preference checkbox in emails
- Emailing us at info@neurobro.ai
Retention & Deletion
We retain your email for marketing only until you withdraw consent. After withdrawal, it’s added to a suppression list to prevent future marketing messages.Third‑Party Processing
Privy acts as our data‑processor under GDPR Art. 28 with Standard Contractual Clauses for international transfers. Data may be stored in the United States with appropriate safeguards.Your Rights
Depending on your residence, you have rights including access, rectification, erasure, restriction, portability, and objection to direct marketing. Exercise them via info@neurobro.ai.7. Security
We use:- Encrypted transport (TLS 1.3)
- JWT tokens for secure authentication
- Least‑privilege keys
- Segregated production networks
8. Changes to this Policy
We may update this Policy. Important changes will be posted on our services and take effect 7 days after posting unless a shorter period is required by law.9. Contact
Phone
(856) 416-6698
Neuro Foundation LLC, 1111B S Governors Ave STE 28958, Dover, DE 19904
Version History
v0.3 - July 27, 2025
v0.3 - July 27, 2025
Added Marketing and Newsletter Communications section covering email collection via Privy, consent management, and unsubscribe processes for weekly newsletters and product updates.
v0.2 - July 09, 2025
v0.2 - July 09, 2025
Updated for expanded services including AI Agent on Telegram, Landing Page, and Neurodex Terminal. Added analytics services (Google Analytics, PostHog), authentication data collection, and chat history. Updated company information to Neuro Foundation LLC.
v0.1 - June 06, 2025
v0.1 - June 06, 2025
Initial draft - no cookies, no analytics