Privacy Policy

We at Neuriah, Inc. (“Neuriah,” “Company,” “we,” “our,” or “us”) operate Phineas, our AI-enabled wellness service, including the Phineas website, mobile application, and related services that link to this policy (collectively, our “Services”). We respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when you use Phineas and our related Services, and our practices for using, maintaining, protecting, and disclosing that information.

Please see the following definitions, which are applied for purposes of our Services:

Wellness Information.

Wellness Information means information you voluntarily provide or that is generated from your interactions with the Services, including Session Transcripts, journal entries, reflections, mood information, wellness goals, and information included in your Longitudinal Record. The Longitudinal Record may also include historical mood-assessment scores generated by the Services, allowing the Services to evaluate changes or patterns over time and compare those assessments with information the user voluntarily provides about their mood.

Session Transcripts.

Session Transcripts are the raw content of individual AI-assisted conversations. Neuriah retains Session Transcripts in its active database for no more than 30 days following the applicable session, after which they are deleted, unless longer retention is required by applicable law or necessary to comply with a valid legal obligation. Raw Session Transcripts do not follow you from session to session.

Longitudinal Record.

To provide continuity and personalization across sessions, Neuriah maintains an AI-generated Longitudinal Record derived from information you voluntarily share through Phineas and the Services. Phineas uses this Longitudinal Record to provide continuity and personalization across sessions. It may include wellness goals, preferences, important experiences, relationships, names of people you discuss, recurring concerns, and other contextual information relevant to future interactions. Unlike raw Session Transcripts, the Longitudinal Record is designed to follow you from session to session. The Longitudinal Record may also include historical mood-assessment scores generated by Phineas, allowing Phineas to evaluate changes or patterns over time and compare those assessments with information you voluntarily provide about your mood.

Use of Wellness Information.

Neuriah uses Wellness Information, including the Longitudinal Record, to provide Phineas and the Services you request, personalize your experience, maintain continuity across sessions, protect the Services, and for other limited purposes described in this Privacy Policy. Neuriah does not sell Wellness Information, provide it to data brokers, or use it for cross-context behavioral advertising or to make employment, insurance, credit, housing, or healthcare eligibility decisions.

This policy applies only to information we collect:

• Through the Services.
• In communications, including email, text, chat, and other electronic messages, between you and the Services.
• When you interact with third parties linked to our site when you use our Services.

It does not apply to information collected by:

• Us through any other means, including by any other third party that does not link to this policy.

We may provide additional or different privacy policies that are specific to certain features, services, or activities.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children’s and Minors’ Data

Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old, we will delete that information.

The Personal Data That We Collect or Process

“Personal data” means information that identifies, relates to, describes, or can reasonably be linked to you as an individual. Consistent with our data-minimization approach, the identifying account information Neuriah intends to maintain is limited primarily to your verified email address and an internal customer or client identifier. If you purchase a subscription or other paid Service, we may also maintain a customer identifier associated with our payment processor. Neuriah does not intend to maintain your payment card number, billing address, or other payment credentials in its own database. You may also voluntarily provide wellness information when using the Services, as described below.

The types and categories of personal data we collect or process include:

• Account and contact information, consisting primarily of your verified email address and an internal customer or client identifier. We do not require a home address or telephone number for ordinary use of the Services unless a specific feature or legal requirement makes that information necessary and you provide it to us.
• Account and subscription information, including account status, subscription status, and a customer identifier associated with our third-party payment processor. Payment card information is processed and maintained by the payment processor rather than Neuriah.
• We do not require demographic information such as age or gender for ordinary account identification. If a feature requests optional demographic information, we will identify the purpose at or before collection and process it in accordance with this Privacy Policy.
• Wellness information you voluntarily provide through the Services, including wellness concerns, reflections, goals, session content, or other information you choose to share to receive and personalize the Services. Wellness information is not used to provide medical diagnosis or treatment.
• Biometric and mood-assessment information, including biometric or sensory signals that may be processed solely to generate a mood-related assessment in connection with the wellness experience. Neuriah does not use facial recognition or process biometric information for the purpose of uniquely identifying or authenticating you. Neuriah does not retain the underlying biometric or sensory source data used to generate the assessment. However, the resulting mood assessment or score is retained in your historical Longitudinal Record so the Services can assess changes in mood over time, compare the assessment with mood information you voluntarily report, and reference historical mood information when useful for continuity and personalization.
• Neuriah does not intentionally collect precise geolocation for ordinary use of the Services. We may infer or receive general location information, such as country or region, from technical information such as an IP address when reasonably necessary for security, compliance, or service operation. Neuriah does not intentionally collect precise geolocation for its core wellness Services; limited location may be inferred from an IP address for security, fraud prevention, and system operation.
• Anonymous session identifier — random UUID, browser scoped, used for funnel analytics.
• Authenticated user ID — when logged in’
• IP address — stored in security and audit logs only, used for brute force and breach detection.
• Referral codes from URLs.
• In-app event timestamps and funnel step numbers.
• Browser type, operating system, and device class via user agent string — captured on referral link clicks and signup attempts.
• Full page URL at time of click or signup.
• Content and information you elect to provide as part of your profile.
• Images or similar inputs are not intended to be stored by Neuriah unless a specific feature expressly tells you otherwise before collection.
• If you are a California resident, to access our supplemental California privacy statement, visit [California-privacy].

Some of the information identified above may be considered sensitive data under certain laws. If required under applicable law, we will collect and process sensitive personal data only with your consent. If you choose not to provide or allow us to collect some information, we may not be able to provide you with requested features, services, or information.

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Services feature.
• Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), what you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.

How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information you choose to provide when you create or use an account and when you interact with the Services. This includes your verified email address and information you voluntarily provide during wellness interactions. Neuriah seeks to minimize collection of identifying information and does not require users to create a profile containing a legal name, home address, telephone number, or payment card information for ordinary use of the Services.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use limited automatic data collection technologies to collect technical and usage information reasonably necessary to operate, secure, troubleshoot, and improve the Services. This may include IP addresses in security or audit logs, browser type, operating system, device class, session identifiers, event timestamps, referral information, and similar technical information. We do not intentionally collect precise geolocation through these technologies for ordinary use of the Services. Neuriah uses third-party cloud security services to protect its website and application against malicious traffic, automated abuse, and unauthorized access. For these security purposes, the providers may process limited technical information, such as IP addresses, browser and device information, and website addresses requested. We also use a third-party service to measure visits and performance on our public website, but not within the authenticated Phineas application. These activities do not involve tracking your activities across unrelated websites for cross-context behavioral advertising.

We do not use automatic collection technologies to track your online activities over time and across third-party sites or other online services for cross-context behavioral advertising. We may use limited first-party analytics and similar technologies to understand use of the Services, operate and secure the Services, and improve functionality, as described in this Privacy Policy.

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
• Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by sending an email to [email protected]. Please note that some Services features may become unavailable as a result.

When you interact with the Services, authorized third-party service providers may process limited information we have collected from you on our behalf to provide functions such as cloud hosting, authentication, payment processing, analytics, security, communications, and AI-enabled wellness features. Neuriah uses cloud security providers to help identify suspicious traffic, prevent automated abuse during account creation and sign-in, and protect the Services from unauthorized access. These providers may process technical information, such as IP addresses, browser and connection information, and requested website addresses, for those security purposes. We also use database hosting and authentication providers, together with their authorized subcontractors, to verify account access and securely store and retrieve information. These providers may process account information and stored Wellness Information, including saved session notes, only as necessary to provide these services and subject to applicable privacy and security protections.

• Neuriah does not currently disclose Personal Information to advertisers, ad networks, or ad servers for cross-context behavioral advertising.
• Analytics companies.
• Your device manufacturer.
• Your internet or mobile service provider.
• Licensed professionals or referral resources, only if Neuriah offers such a referral feature and you affirmatively request the connection.

Authorized third-party service providers may use cookies or similar technologies and may process limited personal data or technical information as reasonably necessary to perform services for Neuriah, such as payment processing, analytics, security, authentication, communications, and service operation. Neuriah limits the identifying information provided to these service providers based on the function they perform. Payment processors may receive identifying and payment information necessary to process transactions. Other service providers may receive technical, pseudonymous, or other information necessary to perform their services. Neuriah does not authorize these service providers to use Wellness Information for their own independent marketing or cross-context behavioral advertising purposes. Separately, Neuriah records limited information about stages in the account creation and sign-in process to identify where users may encounter difficulties. A stage means a point in that process, such as beginning account creation or reaching a sign-in screen; each recorded activity is called an event. Each event record contains only the stage reached, whether the visitor came from our website, and the hour of the activity. These records do not contain names, email addresses, IP addresses, or browser or device information. A daily deletion process removes records older than 90 days. Our public-website analytics reports provide aggregate daily visit totals rather than individual visitor-level reports.

Neuriah selects and manages service providers consistent with its privacy and security practices. Questions regarding Neuriah’s use of service providers may be directed to the contact information in this Privacy Policy.

From Third-Party Sources

We may receive personal data about you from other sources, including from service providers that we engage to perform services on our behalf, such as payment processors, analytics services, and data verification services.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Services and any contents, features, information, products, or services that we make available through the Services.
• Fulfill any other purpose for which you provide it.
• Provide you with notices about your account.
• Improve our Services, including by analyzing your information and creating aggregated data derived from your information) to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them.
• Promote our Services, business, and offerings by publishing advertising on our own Services.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• Notify you when Services updates are available and about changes to any products or services we offer or provide though them.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

• Estimate our audience sizes and usage patterns.
• Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
• Speed up your searches.
• Recognize you when you return to our Services.

Where you have chosen to receive promotional communications from us, we may use your contact information to communicate about Neuriah's own Services and offerings. You may opt out of non-essential promotional communications at any time using the unsubscribe mechanism provided or by contacting us at [email protected]. We do not use Wellness Information for behavioral advertising.

Who We Disclose Your Information To

We may disclose aggregated or de-identified information that does not reasonably identify an individual, subject to applicable law.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates to provide you with the Services.
• To third-party contractors, service providers, and other authorized third parties that support our organization and Services, such as cloud infrastructure, authentication, payment processing, AI functionality, cybersecurity, analytics, communications, and customer support providers, but only as reasonably necessary for the services they perform.
• To licensed mental health professionals or other providers only when you request or authorize a referral or disclosure, or where otherwise permitted or required by applicable law.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Neuriah Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Neuriah Inc. is among the assets transferred.
• Neuriah does not disclose Wellness Information to third parties for their independent marketing or cross-context behavioral advertising.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of use and other agreements.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, other visitors to our site, or others.

The categories of personal data we may disclose are limited to information we actually collect and that is reasonably necessary for the applicable purpose, which may include:

• Account information, including verified email address and internal customer identifier.
• Subscription and limited transaction information, including payment status and a payment processor customer identifier.
• Information you voluntarily provide when using the Services, where applicable.
• Limited technical information, which may include an IP address used for security, fraud prevention, and system operation; Neuriah does not intentionally collect precise geolocation for its core wellness Services. Neuriah does not intentionally collect precise geolocation for its core wellness Services; limited location may be inferred from an IP address for security, fraud prevention, and system operation.
• Device, browser, authentication, security, and diagnostic information reasonably necessary to operate and protect the Services.
• Wellness Information and other content you voluntarily provide when using the Services, where disclosure is necessary to provide the requested functionality or otherwise permitted by this Privacy Policy.
• Information voluntarily submitted to customer support, such as screenshots or files, if you choose to provide them.
• Neuriah does not ordinarily request or maintain government-issued identity document information for its core consumer wellness Services.

Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” setting that can send a signal to the online services you visit indicating you do not wish to be tracked.
• Promotions by the Company. If you receive non-essential promotional communications from Neuriah, you may opt out using the unsubscribe mechanism provided or by contacting us. We do not use Wellness Information to promote third-party products or services.
• Location data choices: Location Data. Neuriah does not intentionally collect precise real-time geolocation for its core wellness Services. Limited location may be inferred from technical information such as an IP address for security, fraud prevention, and system operation.

Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exception under applicable law.
• Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. Where applicable law provides these rights, you may exercise them as described below. Under Neuriah's current practices, we do not sell Personal Data or use Wellness Information for targeted or cross-context behavioral advertising.

Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise applicable privacy rights, please email [email protected] or use any privacy-request mechanism made available through the Services. We may request only the information reasonably necessary to verify your identity. Where applicable law provides a right to appeal a decision regarding a privacy request, you may email [email protected] with the subject line “Privacy Appeal” and include sufficient information to identify the original request.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law. Under Neuriah's current practices, because Personal Information is not sold or shared for cross-context behavioral advertising, an opt-out preference signal may have limited practical effect; Neuriah will nevertheless honor legally applicable signals.

Nevada provides its residents with a limited right to opt out of certain covered sales of personal information. Neuriah does not currently sell Personal Data under its stated practices. Nevada residents may nevertheless submit applicable privacy requests to [email protected] or by mail at Neuriah Inc., P.O. Box 114, Lititz, Pennsylvania 17543-9998.

If you are a California resident, additional information applies to you. To access our supplemental California privacy statement and learn more about California residents’ privacy rights, visit [California-privacy].

How We Protect Your Personal Data

We use commercially reasonable administrative, technical, and organizational safeguards designed to protect Personal Data from accidental loss or destruction and from unauthorized access, use, alteration, or disclosure. These safeguards may include encryption, access controls, authentication protections, security logging, vulnerability management, monitoring, and incident response procedures, as appropriate to our operations. No website, mobile application, system, electronic storage method, or online service can guarantee absolute security. You should carefully consider the information you choose to transmit through email or other communications channels.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

How We Retain Your Personal Data

We retain Personal Data only for as long as reasonably necessary for the purpose for which it was collected, to provide and secure the Services, satisfy legitimate operational needs, comply with legal obligations, resolve disputes, and prevent fraud or misuse. Retention periods may vary by category of information. When Personal Data is no longer reasonably necessary, we seek to securely delete, destroy, de-identify, or anonymize it, subject to applicable legal requirements and limited backup or recordkeeping needs. Wellness Information is retained only as reasonably necessary to support requested Services and continuity, subject to user deletion rights and applicable legal exceptions. If you are a California resident, visit [California-privacy] for additional information. Neuriah applies a specific retention rule to raw Session Transcripts: they are deleted from Neuriah's active database within 30 days after the applicable session, unless longer retention is required by law or necessary to comply with a valid legal obligation. The AI-generated Longitudinal Record is separate from raw Session Transcripts and may be retained for a longer period to provide continuity and personalization across sessions, subject to applicable privacy rights and Neuriah's retention practices.

Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

Contact Information

To exercise your rights or ask questions or comment about this Privacy Policy or our privacy practices, contact us at: Neuriah Inc., P.O. Box 114, Lititz, Pennsylvania 17543-9998, or email [email protected].

Privacy Policy (California Residents)

Last Updated on: October 23rd, 2026

This California Privacy Policy describes how Neuriah Inc. and its subsidiaries, affiliates, and related entities (collectively, “NEURIAH,” “Company,” “we,”or “us”) collect and process personal information about our consumers who reside in California. The California Consumer Privacy Act (“CCPA”) requires us to provide our California consumers with a privacy policy that contains a comprehensive description of our online and offline practices regarding our collection, use, sale, and sharing, and retention of their personal information, along with a description of the rights they have regarding their personal information. This Privacy Policy provides the information the CCPA requires, together with other useful information regarding our collection and use of personal information. Any terms defined in the CCPA have the same meaning when used in this policy.

This Privacy Policy does not apply to our collection and use of personal information from residents outside of California. Consumers residing in other locations should see our general privacy policy at: phineaschat.com

Personal Information Collected

We collect and use information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). Personal information does not include:

• Publicly available information, including from government records, through widely distributed media, or that the consumer made publicly available without restricting it to a specific audience.
• Lawfully obtained, truthful information that is a matter of public concern.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data; or
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act.]

Personal Information Categories Chart

The chart below identifies the categories of personal information we intend to collect from our consumers and the expected retention period.

Sensitive Personal Information Categories Chart

Sensitive personal information is a subtype of personal information defined by the CCPA. Certain categories, such as government identifiers, account-access credentials, precise geolocation, the contents of certain communications, genetic data, and neural data, may qualify based on the nature of the information. Other categories include biometric information processed for the purpose of uniquely identifying a consumer and personal information collected and analyzed concerning a consumer's health, sex life, or sexual orientation. Because wellness conversations are user-directed, Wellness Information may include information that California law treats as Sensitive Personal Information.

The chart below identifies which sensitive personal information categories, if any, we plan to collect from consumers to infer characteristics about them. However, please note: Because wellness conversations are user-directed, if a user voluntarily discloses sensitive information that is not required to use the Services, such information may remain in a raw Session Transcript for up to 30 days and, when relevant to continuity and personalization, may be retained in the AI-generated Longitudinal Record. But please note that Neuriah does not require these sensitive characteristics as profile fields and does not use them for advertising, sale, data-broker activity, or eligibility decisions.

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from you, such as from the forms or other information you provide to the Company.
• Indirectly from you, such as from your interactions with the Company’s websites, mobile applications.
• · From our service providers and, if a referral feature is offered and you affirmatively request a connection, from licensed mental health professionals or other independent providers involved in that requested referral.

How We Use Personal Information

Personal Information Collection, Use, and Disclosure Purposes

We may use and disclose the personal information, including sensitive personal information, we collect to advance the Company’s business and commercial purposes, specifically to:

• Develop, offer, and provide you with our Services, including, if a referral feature is offered, facilitating a connection to a licensed mental health professional or other independent provider when you affirmatively request that referral. Such a referral does not make Neuriah or Phineas a healthcare provider or make treatment part of the Phineas wellness service.
• Meet our obligations and enforce our rights arising from any contracts with you or to comply with legal requirements.
• Fulfill the purposes for which you provided your personal information or that were described to you at collection, and as the CCPA otherwise permits.
• Improve our products or services, marketing, or customer relationships and experiences.
• Notify you about changes to our products or services.
• Administer our systems and conduct internal operations, including for troubleshooting, data analysis, testing, research, statistical, and survey purposes.
• Enable your participation in our websites’ or mobile apps’ interactive, social media, or other similar features.
• Protect our Company, employees, or operations.
• Measure the effectiveness of Neuriah's own communications and promotions without using Wellness Information for cross-context behavioral advertising.
• Provide information about Neuriah's own Services and offerings where permitted by law, without using Wellness Information for cross-context behavioral advertising.
• Manage your consumer relationship with us, including for:
  • online account creation, maintenance, and security; and,
  • reaching you, when needed, about your account;
• Perform data analytics and benchmarking, to ascertain who is using our Services.
• Administer and maintain the Company’s systems and operations, including for safety purposes.
• Engage in corporate transactions requiring review of consumer records, such as for evaluating potential Company mergers and acquisitions.
• Comply with all applicable laws and regulations.
• Exercise or defend the legal rights of the Company and its employees, affiliates, customers, contractors, and agents.
• Respond to law enforcement requests and as required by applicable law or court order.

Sensitive Personal Information Use and Disclosure Purposes

We may use or disclose sensitive personal information for the following statutorily approved reasons (Permitted SPI Purposes):

• Performing actions that are necessary for our consumer relationship and that an average consumer in a relationship with us would reasonably expect for us to provide you with the Services.
• Preventing, detecting, and investigating security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information.
• Defending against and prosecuting those responsible for malicious, deceptive, fraudulent, or illegal actions directed at the Company.
• Ensuring physical safety.
• Short-term, transient use, such as non-personalized advertising shown as part of your current interactions with us, where we do not:
  • disclose the sensitive personal information to another third party; or
  • use it to build a profile about you or otherwise alter your experience outside your current interaction with the Company.
• Services performed for the Company, including maintaining or servicing accounts, processing or fulfilling transactions, verifying consumer information, processing payments, or providing financing, analytic services, storage, or similar services for the Company.
• Activities required to:
  • verify or maintain the quality or safety of a product, service, or device that we own, manufacture, had manufactured, or control; or
  • improve, upgrade, or enhance the service or device that we own, manufacture, had manufactured, or controlled.
• Collecting or processing sensitive personal information that we do not use for the purpose of inferring characteristics about a consumer.

We do not use or disclose sensitive personal information for purposes other than the Permitted SPI Purposes.

Additional Categories or Other Purposes

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. If required by law, we will also seek your consent before using your personal information for a new or unrelated purpose.

We may collect, process, and disclose aggregated or deidentified consumer information for any purpose, without restriction. When we collect, process, or disclose aggregated or deidentified consumer information, we will maintain and use it in deidentified form and will not to attempt to reidentify the information, except to determine whether our deidentification processes satisfies any applicable legal requirements.

Disclosing, Selling, or Sharing Personal Information

Business Purpose Disclosures

We may disclose the personal information we collect, including sensitive personal information, to service providers and contractors for the business purposes described in the Personal Information Collection, Use, and Disclosure Purposes section, such as to support our business functions. For example, we may disclose information from your visits to the Company’s website to a cybersecurity consultant to help secure the website.

We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, prohibit using the disclosed information for any purpose except performing the contract, and meet the CCPA’s other contract requirements for engaging service providers or contractors.

The chart below identifies the personal information categories we plan to disclose to service providers or contractors for a business purpose and the specific business or commercial purpose for disclosing that information/categories of entities to whom we have disclosed our consumers’ personal information for a business purpose, along with the personal information categories disclosed and the disclosure’s business purposes.

Business Purposes Disclosure Recipient Category, Personal Information Category, and Purposes Chart

Selling or Sharing Personal Information

To provide the Services, we may disclose personal information, including sensitive personal information where necessary, to service providers and contractors that process information on our behalf for the limited business purposes described in this Privacy Policy. Neuriah does not sell Personal Information and does not share Personal Information with third parties for cross-context behavioral advertising.

Under Neuriah's current practices, we do not sell Personal Information or share Personal Information for cross-context behavioral advertising. Our Services are intended only for adults age 18 or older, and we do not knowingly collect Personal Information from anyone under age 18.

We do not disclose personal information to advertising networks, data brokers, or marketing partners for commercial purposes.

Your Rights and Choices

If you are a California resident, the CCPA grants you the following rights regarding your personal information:

Right to Know and Data Portability Requests

You have the right to request that we disclose certain information to you about our collection and use of your personal information (the “right to know”), including the specific pieces of personal information we have collected about you (a “data portability request”). You may exercise your right to know twice in any 12-month period. Once we receive your request and confirm your identity (see How to Exercise Your Rights), we will disclose to you:

• The categories of:
  • personal information we collected about you; and
  • sources from which we collected your personal information.
• The business or commercial purpose for collecting your personal information and, if applicable, selling or sharing your personal information.
• If applicable, the categories of persons, including third parties, to whom we disclosed your personal information, including separate disclosures identifying the categories of your personal information that we:
  • disclosed for a business purpose to each category of persons; and
  • sold or shared to each category of third parties.
• When your right to know submission includes a data portability request, a copy of your personal information, subject to any permitted redactions.

For more on exercising this right, see Exercising the Rights to Know, Delete, or Correct, or Access.

Right to Delete and Right to Correct

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions and limitations (the “right to delete”). Once we receive your request and confirm your identity, we will delete your personal information from our systems unless an exception allows us to retain it. We will also notify our service providers, contractors, and other recipients to take appropriate action.

You also have the right to request correction of personal information we maintain about you that you believe is inaccurate (the “right to correct”). We may require you to provide documentation, if needed, to confirm your identity and support your claim that the information is inaccurate. Unless an exception applies, we will correct personal information that our review determines is inaccurate and notify our service providers, contractors, and other recipients to take appropriate action.

For more on exercising these rights, see Exercising the Rights to Know, Delete, or Correct, or Access.

You have a right to ask businesses that use or disclose your sensitive personal information to limit those actions to just the CCPA’s Permitted SPI Purposes (the “right to limit”). For more on exercising this right, see Exercising the Right to Limit or Opt-Out, or Appeal an ADMT Decision. Neuriah uses Sensitive Personal Information only for purposes reasonably necessary to provide requested Services, maintain security, support continuity and personalization, comply with law, and perform other permitted operational purposes described in this Policy.

For more on the Permitted SPI Purposes and our additional use purposes, see Sensitive Personal Information Use and Disclosure Purposes.

Personal Information Sales or Sharing Opt-Out and Opt-In Rights

You have the right to request that businesses stop selling or sharing your personal information at any time (the “right to opt-out”), including through a user-enabled opt-out preference signal. Similarly, the CCPA prohibits businesses from selling or sharing the personal information of consumers it actually knows are under 16 years old without first obtaining consent from consumers who are between 13 and 15 years old or the consumer’s parent or guardian for consumers under age 13 (the “right to opt-in”). However, we do NOT knowingly collect information or data from anyone under the age of 18, and will delete any such information and data should we become aware that the information and data is from someone under the age of 18.

For more on exercising applicable opt-out rights, see Exercising the Rights to Know, Delete, or Correct, or Access ADMT Decision

ADMT Rights

When a business uses automated decision-making technology (ADMT) to make significant decisions about you, you may have rights to:

• Obtain certain information about how the business uses ADMT, that is specific to you (the “ADMT access right”).
• Opt-out of the ADMT use (the “ADMT opt-out right”) unless the business provides you with a method to appeal the decision to a human reviewer with the authority to overturn the decision (the “ADMT appeal right”) or another exception applies.

ADMTs are technologies that process personal information and use computation to execute a decision and either replace or substantially replace human decision-making, resulting in decisions made without human involvement. Decisions are significant when they result in the provision or denial of financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services. Advertising is not a significant decision.

Neuriah does not currently use ADMT to make significant decisions concerning financial or lending services, housing, education enrollment or opportunities, employment or independent contracting opportunities or compensation, or healthcare services. If Neuriah begins using ADMT for a significant decision subject to the CCPA, Neuriah will provide any notices and rights required by applicable law. Where an ADMT access right applies and we receive a valid request and confirm your identity (see How to Exercise Your Rights), we will provide the information required by applicable law, which may include:

• The specific purpose for which we use ADMT to make a significant decision about you.
• Information about the ADMT’s logic that explains how the ADMT processed your personal information to generate an output about you.
• The ADMT’s outcome for you, including how we used the ADMT’s output to make a significant decision about you and whether we may use the output to make future significant decisions about you.
• How you can exercise your CCPA rights and that we will not retaliate against you for exercising your CCPA rights.

For more on exercising your ADMT access right, see Exercising the Rights to Know, Delete, or Correct, or Access ADMT.

For more on exercising your ADMT appeal/opt-out rights, see Exercising the Right to Limit or Opt-Out, or Appeal an ADMT Decision.

Right to Non-Discrimination

You have the right not to be discriminated or retaliated against for exercising any of your privacy rights under the CCPA.

How to Exercise Your Rights

Exercising the Rights to Know, Delete, or Correct, or Access ADMT

To exercise the right to know (including data portability), delete, or correct, or access ADMT described above, please submit a verifiable request to us by either:

• Emailing: [email protected]
• Mailing address: P.O Box 114, Lititz, PA 17543-9998
• Request status: To check the status of your request email [email protected] request details and we will respond within 30 days.

Please describe your request with sufficient detail so we can properly understand, evaluate, and respond to it. You may only submit a request to know, including for data portability, twice in a 12-month period.

Exercising the Right to Limit, Opt-Out, or Appeal an ADMT Decision

You can submit an applicable request to limit or opt out, or an applicable request concerning an ADMT decision, through the methods described below.

You can also submit your request to opt-out of personal information sales and sharing through an opt-out preference signal.

Opt-out preference signal: You may also submit your request to opt-out through a Global Privacy Control signal. If we detect a GPC signal from your browser we will honor it as a valid opt-out request.' Under Neuriah's current practices, because Personal Information is not sold or shared for cross-context behavioral advertising, an opt-out preference signal may have limited practical effect; Neuriah will nevertheless honor legally applicable signals.

No additional instructions are required to submit a privacy request.

Request status: To check the current status of your opt-out or limitation request, email [email protected] Privacy Request Status and include your original request details. We will respond within 30 days.'

Only you may make a request to know, delete, or correct, or access ADMT related to your personal information. We may request specific information from you to confirm your identity before we can process your right to know, delete, or correct your personal information.

We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the personal information relating to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make the request.

We may consider requests made through an authenticated account sufficiently verified when the request relates to personal information associated with that specific account. Neuriah uses one-time authentication codes and may permit users to set an optional password for additional account protection. You do not need to create an account with us to submit a request to know, correct, or delete.

For requests to limit or opt-out, we ask for the information necessary to complete the request, which may include, for example, the consumer’s name, email address, or account username.

Responding to Your Requests to Know, Delete, or Correct, or Access/Appeal ADMT

We will confirm receipt of your request within ten business days. If you do not receive confirmation within the ten-day timeframe, please email us at [email protected] or by mail at P.O Box 114, Lititz, PA 17543-9998.

We endeavor to substantively respond to a verifiable request within 45 days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. We will deliver our written response to your verified email address. Our substantive response will tell you whether or not we have complied with your request. If we cannot comply with your request in whole or in part, we will explain the reason, subject to any legal or regulatory restrictions. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, deleted, or made your personal information anonymous in compliance with our record retention policies and obligations.

Any disclosures we provide will cover information for the 12-month period preceding the request’s receipt date. We will consider requests to provide longer disclosure periods that do not extend past January 1, 2027, unless providing the longer timeframe would be impossible or involves disproportionate effort.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by CSV or PDF format delivered via secure email within 45 days of request.

We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Response and Timing on Rights to Limit or Opt-Out

In response to your request, we will process your request, as soon as feasibly possible, but no later than 15 business days from the date we receive the request. We will only use personal information provided from your request to comply with the request.

We will also notify our service providers, contractors, and certain other downstream recipients of your request and instruct them to both:

• Comply with your request.
• Forward the request to their own downstream recipients, if applicable.

We may deny opt-out requests if we have a good-faith, reasonable, and documented belief that the request is fraudulent and will clearly explain our denial decision to the requestor.

You may confirm the status of an applicable privacy request by contacting [email protected] and providing the original request details.

• Neuriah's current practice is to use Sensitive Personal Information only for the permitted purposes described in this Policy.
• Neuriah's current practice is not to sell Personal Information or share Personal Information for cross-context behavioral advertising.

Under Neuriah's current practices, we do not use or disclose Sensitive Personal Information for purposes outside the Permitted SPI Purposes and do not sell Personal Information or share it for cross-context behavioral advertising. If those practices materially change, Neuriah will provide required notices and choices before seeking any legally required authorization.

If Neuriah offers a legally applicable opt-in mechanism, instructions will be provided at the point where the choice is presented.

Reselling or Resharing Personal Information

We do not sell or share personal information with any third parties for resale or resharing purposes.

How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us through these communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

Privacy Policy Changes

We reserve the right to update this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will update the policy’s effective date and post the updated policy on our Website. We encourage you to check this Website each time you visit to review the current Privacy Policy in effect.

Contact Information

If you have any questions or comments about this policy, the ways in which we collect and use your information described here, or your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Website: phineaschat.com

Email: [email protected]

Postal Address: P.O Box 114, Lititz, PA 17543-9998

If you need to access this Privacy Policy in an alternative format due to a disability, please contact [email protected] and we will respond within 5 business days