Version: 1.0.1
Last Updated: 12-15-2023

Introduction

Neurox, Inc. d/b/a Shuttle (“Shuttle”) is committed to protecting your privacy. This privacy policy (“Privacy Policy”) describes how we treat the information we collect when you visit and use our Site, www.shuttlehq.com (the “Site”), and the services offered by Shuttle (including, without limitation, the Site, App, plugins, and services, collectively referred to as the "Services"). Please read this Privacy Policy to learn more about the ways in which we collect, use, and protect your information. By visiting the Site or using the Services, you are agreeing to the terms of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Site or Services.

The Site and Services are not intended for use by children. If you are under the age of 18, you may use the Site and Services only with the involvement of a parent or guardian. We do not knowingly collect personal information from children under the age of 13 without the consent of the child's parent or guardian. If you are under the age of 13, please do not submit any personal information through the Site or Services. If we learn that we have collected personal information from a child under the age of 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at: privacy@shuttlehq.com.

Information Collection and Use

Browsing the Site does not require you to register for an account or provide any personal information to us. However, we may collect certain non-personal information from you when you visit the Site, such as your IP address, browser type, operating system, the specific web pages visited during your connection, and the domain name from which you accessed the Site. Such generic information does not reveal the identity of the visitor directly. We use this information to monitor the usage of the Site and the development of the Services. Shuttle may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. As part of this use of information, we may provide aggregate information (not information about you personally) to our partners about how our visitors, collectively, use our Site.

We use analytics services (such as Google Analytics) to help analyze how users use the Site. These analytics services use cookies to collect and store anonymous information such as time of visit, pages visited, time spent on each page of the Site, IP address, and type of operating system used. We use this information to improve the Site and Services and make them appealing to as many users as possible. We do not link this data to personally identifiable information. For more information on how Google Analytics uses data, please visit https://www.google.com/policies/privacy/partners/.

Personal Data Collection

We collect the following types of information from you when you use the Services:

• Your name, email address, and other contact information;
• Your calendar and location information;
• Your username and password;
• Your correspondence through the Services, and correspondence sent to us;
• Information you provide to us when you use the Services;
• Information you enter into our system when using the Services, such as contact information and project management information.

We use this information to provide you with and to improve the Services.

Information we automatically collect when you use the Services:

• IP address;
• Device identifiers;
• Browser type;
• Operating system;
• Cookies and other tracking tools (e.g., Google Analytics);
• The specific web pages visited during your connection;
• The domain name from which you accessed the Services;
• The time and date you accessed the Services; and
• The links on which you clicked.

Personal Data Use

We use the information we collect to provide, maintain, and improve the Services. We also use the information we collect to:

• Send you technical notices, updates, security alerts, and support and administrative messages and to respond to your comments, questions, and customer service requests;
• Communicate with you about products, services, offers, promotions, and events offered by Shuttle and others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage, and activities in connection with the Services;
• Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of Shuttle and others;
• Personalize and improve the Services, and provide advertisements, content, or features that match user profiles or interests; and
• Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data because we need to process the data to perform under our User Agreement with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data:

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties. Examples of these legitimate interests include:

• Operation and improvement of our business, products and services;
• Marketing of our products and services;
• Provision of customer support;
• Protection from fraud or security threats; and
• Compliance with legal obligations.

When we process Personal Data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

Consent: In some cases we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

Information You Provide to Us

We may receive and store any information you enter into the Service or provide to us in any way. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our Service offerings. The personal information you provide may be used for such purposes as responding to your requests for certain information, products, and services, customizing the content you see, and communicating with you about the Services. If you send us or give us access to personal correspondence, such as emails or other messages, or if other users or third parties send us correspondence about your activities or postings on the Site, we may collect such information into a file specific to you.

Additionally, we may collect information about your location and clendar in order to provide you with more personalized Services. You can choose not to provide us with such information, but that may limit the features or services that you are able to use. It is your responsibility to ensure that you have shared the proper information with us and that you have obtained the proper consent from your contacts to share their information with us.

In your usage of the Services, you may engage in authorizing us to access your Google account. We will only access the information that you have authorized us to access. We will not access any information that you have not authorized us to access. We will not share any information that we access with any third parties unless directed by you to do so (which permission may be required in order to sign up for certain services).

Information Collected from Other Websites; Do Not Track Policy

Through cookies we place on your browser or device, we may collect information about your online activity after you leave our Services. Just like any other usage information we collect, this information allows us to improve the Services and customize your online experience, and otherwise as described in this Privacy Policy.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using the Services and after you leave our Services.

Data Sharing and Disclosure

We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

• payment processors;
• fraud prevention service providers;
• analytics service providers;
• hosting service providers;
• telecommunication service providers;
• other service providers who assist us in providing the Services.

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

• other users (where you are sending communications via the Services, post information publicly, or as otherwise necessary to effect a transaction initiated or authorized by you through the Services);
• social media services (if you interact with them through your use of the Services);
• third party business partners who you access through the Services;
• other parties authorized by you.

We also share Personal Data when we believe it is necessary to:

• comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies;
• protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud;
• maintain the security of our products and services; or
• fulfill your request.

We also share information with third parties when you give us consent to do so. For example, we often display personal testimonials of satisfied customers on our public websites. With your consent, we may post your name alongside the testimonial.

We use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements, available at: https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes

Data Storage and Security

At Shuttle, we recognize the importance of protecting your personal information and treat data as a critical asset that must be guarded against loss and unauthorized access. We employ industry-standard Secure Socket Layer (SSL) encryption to safeguard the security of your personal information during transmission.

Our data processing and storage infrastructure utilizes Amazon Web Services (AWS) and Google Cloud Storage (GCS), renowned for their robust security measures. These platforms ensure high-level protection and security of your data, adhering to stringent industry standards and practices.

We restrict access to personal information to employees who require that information to perform specific job functions (such as customer service). Our employees are regularly trained and updated on our privacy and security practices to maintain the highest standards of data protection.

As a result of the complexities of the regulatory environment and the limitations it presents, while we strive to protect your personal information, we cannot guarantee that it will never be disclosed by us. For instance, we may need to disclose personal information to government entities or third parties under certain legal circumstances, or there is a possibility that third parties may unlawfully intercept or access transmissions or private communications.

You play a crucial role in protecting your account. We advise you to safeguard your passwords and ensure you log off after using a shared computer. Remember, you are accountable for all actions taken with your User ID and password. We strongly recommend not sharing your password with third parties. If you lose control of your password, you risk losing significant control over your personal information and may become susceptible to legally binding actions taken in your name. If your password is compromised, we urge you to change it immediately to maintain the security of your account.

Data Retention

We will retain your Personal Data for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Email, Calendar, and location data are considered sensitive and are subject to a shorter retention period for your privacy. We will delete calendar and location data of a user from our servers 30 days after collection. This is in line with our commitment to maintain the privacy and security of your personal information.

We may retain Non-Personal Data indefinitely.

Your Data Rights

At Shuttle, we recognize and respect your rights concerning your Personal Data. Below are the rights you have regarding the Personal Data we hold about you. To exercise any of these rights, please contact us at privacy@shuttlehq.com. We will respond to your request with consideration, but please note that in certain cases, we may not be able to fully comply with your request if it is impractical, jeopardizes the rights of others, or is not required by law. In such cases, we will inform you of our decision.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain Personal Data directly through your account settings on our platform.
• Rectification: If you believe that any Personal Data we hold about you is incorrect or incomplete, you can request that we correct or supplement the data. You may also make some corrections directly through your account settings.
• Erasure: You can request that we erase some or all of your Personal Data from our systems. Please note that this might limit your ability to use certain features of our Services.
• Withdrawal of Consent: If we process your Personal Data based on your consent, you have the right to withdraw this consent at any time. However, withdrawing consent may affect your ability to use certain Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format, and where feasible, you can request that we transmit this data to another data controller.
• Objection: If you have concerns about our use or disclosure of your Personal Data, you can contact us to express your objection. This is particularly relevant for direct marketing purposes.
• Restriction of Processing: You can request that we limit the processing of your Personal Data under certain conditions.
• Right to File Complaint: You have the right to lodge a complaint about Shuttle's data practices with the relevant supervisory authority in your jurisdiction.
• Transfers of Personal Data: Shuttle is based in the United States. If you are using our Services from outside the United States, your Personal Data may be transferred to, stored, and processed in the United States where our servers are located. By using our Services, you represent and warrant that you will not use the Services in any country or jurisdiction where such use would violate applicable law.

Children's Privacy

The Children's Online Privacy Protection Act (“COPPA”) requires that online service providers obtain parental consent before they knowingly collect personally identifiable information online from children who are under 13. We do not knowingly collect or solicit personally identifiable information from children under 13; if you are a child under 13, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn we have collected personal information from a child under 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us personal information, please contact us at

CCPA Compliance

In compliance with the California Consumer Privacy Act (CCPA), and under California Civil Code Sections 1798.83-1798.84, if you are a resident of California, you have certain rights regarding the personal information that Shuttle collects about you. These rights include the ability to request access to your personal information, the right to request that Shuttle deletes your personal information, and the right to know what personal information is being collected about you and the purpose for such collection.

To exercise these rights, California residents may contact us at privacy@shuttlehq.com. Shuttle will not discriminate against any user for exercising their CCPA rights.

Shuttle collects information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The categories of information we collect are outlined in our Privacy Policy.

Shuttle uses this personal information for business purposes as described in our Privacy Policy. We do not sell personal information to third parties. For any inquiries or concerns regarding your personal information under CCPA, please contact our designated CCPA compliance officer at [CCPA COMPLIANCE OFFICER].

International Transfer of Information

Shuttle is based in the United States and the information we collect is governed by U.S. law. If you are accessing the Services from outside of the United States, please be aware that information collected through the Services may be transferred to, processed, stored, and used in the United States. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Services or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personal Data, in the U.S. as set forth in this Privacy Policy.

Changes to this Privacy Policy

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. Please note that you are bound by any changes to our Privacy Policy when you use the Services after such changes have been first posted.

Security Breach Notification Procedures

In the event of a data breach that affects your Personal Data, Shuttle is committed to promptly notifying affected individuals in accordance with applicable laws and regulations. We will take immediate steps to identify the cause of the breach and take the necessary measures to prevent a recurrence. Notifications will include information about what happened, what data was involved, how you might be impacted, and what actions you can take to protect yourself. We will also provide contact information for any further inquiries.

Contact Us

If you have any questions or concerns regarding our privacy policies, please send us a detailed message to privacy@shuttlehq.com

Cookie Policy

Shuttle uses cookies on our Site and Services for analytics and authentication purposes. Cookies are small data files stored on your device that help us improve our Services and your experience, understand how our Services are being used, and ensure secure and efficient operation of our site. We do not use cookies for targeted advertising. You have the ability to accept or decline cookies through your browser settings, though this may impact your experience with certain features of our Services.

Definitions

Capitalized terms not defined in this Privacy Policy have the meanings given in the Terms of Use.

"App" means the Shuttle web application.

"Personal Data" means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

"Site" means the website www.shuttlehq.com or any other website operated by Shuttle.

"User Agreement" means the agreement between you and Shuttle governing your use of the Services.