Privacy Policy

Last Updated: May 26, 2025

1. Introduction

Welcome to SecureNeural ("SecureNeural", "us", "we", or "our"). SecureNeural is a mobile application (the "Application" or "Service") designed with your privacy as a core principle. This Privacy Policy explains how we handle information in relation to the Application. SecureNeural is operated by SecureNeural, registered in Cyprus.

We are committed to protecting your privacy. This Privacy Policy is intended to inform you about how we operate the Application and why, by its very design, it does not collect, store, or transmit your personal documents or the data contained within them.

If you have any questions or concerns about this Privacy Policy or our practices, please contact us at [email protected]

2. Scope of this Privacy Policy

This Privacy Policy applies solely to the SecureNeural Application that you download and install on your device. It does not apply to our website (e.g., information submitted via contact forms or for early access sign-ups on the website, which would be covered by a separate website privacy policy) or any third-party services.

3. Our Fundamental Privacy Commitment: On-Device Processing

3.1. The SecureNeural Application is engineered to perform all its core functionalities – including document uploading, processing, AI-powered analysis, and data storage – exclusively on your local device (e.g., your smartphone or tablet).

3.2. No Transmission of Your Document Data: Your documents, their content, and any data generated by the Application from your documents (such as summaries, insights, or answers to your queries) are NEVER transmitted to, stored on, or accessed by SecureNeural's servers, cloud infrastructure, or any third-party servers or vendors. We have no technical means to access this information through the Application.

3.3. Offline Functionality: The core features of the Application are designed to work entirely offline after the initial download, installation, and any subsequent updates you choose to install.

4. Information We Do Not Collect Through the Application

Given the on-device processing architecture of the Application, we DO NOT collect, monitor, or have access to:

  • a. Any documents you upload or process within the Application.
  • b. The content of these documents.
  • c. Any personal data contained within your documents.
  • d. Any information you search for or queries you make regarding your documents within the Application.
  • e. Usage analytics about how you specifically interact with your documents within the Application (e.g., which documents you open, features you use on specific content).
  • f. Your device's general usage data, IP address, or precise geolocation through the Application.

5. Information We May Collect (Minimal and Specific)

While the core principle is no collection of your document data, very limited and specific types of information may be processed by us in narrowly defined circumstances, separate from your document content:

5.1. License Validation Information: If your version of the Application requires a purchase or license validation, we may process minimal data necessary to validate your license (e.g., a transaction ID from the app store, a license key, or an anonymized device identifier for this sole purpose). This process will be designed to be privacy-preserving and will not involve the transmission of your personal documents or their content.

5.2. Customer Support Interactions: If you voluntarily contact us for customer support (e.g., via email), we will collect the information you provide in your communication (such as your email address and the content of your query) to assist you. This data is processed based on your consent and our legitimate interest in providing support.

5.3. Aggregated and Anonymized Crash Reports (Opt-In): In the future, we may offer an opt-in feature for you to submit anonymized crash reports to help us improve the Application's stability. If you choose to opt-in, these reports would be stripped of any personal identifiers and would not contain any part of your documents. The legal basis for processing this would be your explicit consent.

6. How We Use Information (If Any Minimal Data is Collected)

If we collect any of the limited information described in Section 5, it is used solely for the following purposes:

  • a. To Provide and Maintain the Service: For example, to validate your license to use the Application. (Legal basis: Performance of a contract with you).
  • b. To Provide Customer Support: To respond to your inquiries and resolve issues. (Legal basis: Your consent when you contact us, and our legitimate interest).
  • c. To Improve the Application: If you opt-in to provide anonymized crash reports, to identify and fix bugs and improve stability. (Legal basis: Your explicit consent).

We do not use any information for advertising or profiling purposes.

7. Legal Basis for Processing (Under GDPR)

As SecureNeural is based in Cyprus, our processing of any minimal personal data (as outlined in Section 5) is compliant with the General Data Protection Regulation (EU) 2016/679 (GDPR).

  • a. Your Documents and Their Content: We do not process this data. You are in control of this data on your device. Should your documents contain personal data, you are responsible for ensuring you have a lawful basis for processing it on your device using our Application.
  • b. License Validation Information: Processed on the basis of fulfilling our contract with you (Art. 6(1)(b) GDPR).
  • c. Customer Support Communications: Processed based on your consent when you initiate contact (Art. 6(1)(a) GDPR) and our legitimate interests to provide effective support (Art. 6(1)(f) GDPR).
  • d. Anonymized Crash Reports: Processed based on your explicit consent if you opt-in (Art. 6(1)(a) GDPR).

8. Data Retention (For Minimal Data Collected)

We only retain any minimal personal data we might collect (as per Section 5) for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

  • Customer support emails may be retained for a reasonable period to ensure query resolution and for service improvement.
  • License validation data is kept as long as your license is active and as required by financial regulations.

Your documents and their content are stored on your device and their retention is solely under your control.

9. Data Security

9.1. Application Security: The security of your documents and data within the SecureNeural Application primarily relies on the "security by design" principle of on-device processing. No document data is transmitted from your device by the Application.

9.2. Your Device Security: You are solely responsible for the security of your device. This includes using strong passwords or biometric authentication for your device, keeping your device's operating system updated, being cautious about installing software from untrusted sources, and protecting your device from unauthorized physical access or malware. SecureNeural is not responsible for security breaches affecting your device itself.

9.3. Our Security Measures (for any minimal data we handle): For any minimal data we might collect directly (e.g., support emails, license data), we implement appropriate technical and organizational security measures to protect it against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

9.4. In the unlikely event of a security incident affecting any data we process, we will notify affected users within 72 hours as required by GDPR.

10. Your Privacy Rights Under GDPR

As we are established in Cyprus, you have certain rights under the GDPR regarding any minimal personal data we may hold about you (as described in Section 5). These rights include:

  • a. The right to access: You can ask for copies of your personal data that we hold.
  • b. The right to rectification: You can ask us to rectify inaccurate personal data or complete incomplete data.
  • c. The right to erasure ('right to be forgotten'): You can ask us to erase your personal data in certain circumstances.
  • d. The right to restrict processing: You can ask us to restrict the processing of your personal data in certain circumstances.
  • e. The right to data portability: You can ask that we transfer the personal data you gave us to another organization, or to you, in certain circumstances.
  • f. The right to object to processing: You can object to our processing of your personal data in certain circumstances (e.g., if processed under legitimate interests).
  • g. Rights related to automated decision making and profiling: SecureNeural does not engage in automated decision-making or profiling with any personal data it might minimally collect.

Regarding Your Documents and Content on Your Device: Since this data is stored and processed exclusively on your device and we do not have access to it, these rights are exercised by you directly on your device. For example, you can access, modify, or delete your documents directly within the Application or by managing the Application's data through your device's operating system settings. Uninstalling the Application should remove its associated data from your device, subject to your device's operating system behavior.

To exercise any of your GDPR rights concerning data we might hold (e.g., from support queries), please contact us at [email protected]. We will respond to your request within one month, as required by GDPR.

11. Children's Privacy

The Application is not intended for use by children under the age of 16 (or a higher age if stipulated by applicable law in your jurisdiction for processing personal data). We do not knowingly collect any personal information from children. If you believe that a child has provided us with personal information (e.g., by contacting support), please contact us, and we will take steps to delete such information.

12. International Data Transfers

As a rule, your document data processed by the Application does not leave your device and is therefore not subject to international transfers by us.

Any minimal personal data we might collect (e.g., support emails) may be processed on servers that could be located outside the European Economic Area (EEA). If this occurs, we will ensure that such transfers are lawful and that your data is protected to the standards required by GDPR (e.g., through adequacy decisions, Standard Contractual Clauses).

13. Updates to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the Application's functionality, or legal requirements. The updated version will be indicated by an updated "Last Updated" date and will be effective as soon as it is accessible. We will notify you of any material changes, for example, through a notice within the Application or on our website. We encourage you to review this Privacy Policy frequently.

14. Supervisory Authority

If you have concerns about our handling of your personal data that we are unable to resolve, you have the right to lodge a complaint with the data protection supervisory authority in Cyprus:

Office of the Commissioner for Personal Data Protection
1 Iasonos Street, 1082 Nicosia
P.O. Box 23378, 1682 Nicosia, Cyprus
Tel: +357 22818456
Email: [email protected]

15. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or your privacy rights, please contact us:
Email: [email protected]

16. Professional and Regulated Data

Users processing regulated data (medical, legal, financial) are solely responsible for ensuring compliance with sector-specific regulations. SecureNeural makes no representations about suitability for regulated use cases.

17. Limitation of Liability

To the maximum extent permitted by law, SecureNeural's liability for any data protection violations shall be limited to direct damages only and shall not exceed the license fee paid.