Privacy Policy

1. Introduction

Neuvana AI ("Neuvana", "we", "us", or "our") is committed to protecting the privacy and fundamental rights of individuals. This Privacy Policy explains how we collect, use, and protect information in connection with our products and services — including VisionPulse, LaunchIQ, and Elysium — and our website at neuvana.ai.

Neuvana is incorporated in the European Union, with our EU headquarters in Guimarães, Portugal. All data processing activities fall under EU jurisdiction and comply with applicable European data protection regulations.

2. Privacy by Architecture

Our products are designed with privacy as a foundational architectural principle, not an afterthought. This means:

• On-device processing: All AI inference and computer vision processing occurs locally on edge devices. No video or image data is transmitted to cloud servers for processing.
• No video storage: Camera frames are analysed and discarded in milliseconds. We do not record, store, or retain video footage.
• No facial recognition: Our systems do not perform facial recognition, build facial databases, or identify individuals. Demographic analysis (age range, gender) uses anonymous classification that cannot be reversed to identify a person.
• No personal data collection: We do not collect names, email addresses, phone numbers, or any other personally identifiable information from individuals observed by our sensors.
• Sovereign AI: Customer data never leaves the customer's premises unless explicitly configured for aggregated analytics delivery.

3. Data We Process

3.1 Sensor Data (Edge Processing)

Our edge AI sensors capture and immediately process:

• Anonymous presence detection (person count, not identity)
• Aggregate demographic classification (age range, gender distribution)
• Movement patterns and dwell time measurements
• Zone-level engagement metrics
• Product interaction events (pickup, handling duration, return-to-shelf)

This data is processed on-device and converted into statistical aggregates. The original sensor frames are never stored or transmitted.

3.2 Website Data

When you visit neuvana.ai, we may collect:

• Standard web analytics (page views, session duration, referral source)
• Information you voluntarily provide through contact forms
• Cookies necessary for website functionality

3.3 Business Contact Data

When you contact us for business purposes, we collect the information you provide (name, email, company, role) to respond to your inquiry and manage our business relationship.

4. Legal Basis for Processing (GDPR Article 6)

We process data under the following legal bases:

• Legitimate interest (Art. 6(1)(f)): Aggregated, anonymous analytics that cannot identify individuals, used to provide our services to retail and industrial customers.
• Consent (Art. 6(1)(a)): For website cookies and marketing communications, where applicable.
• Contract performance (Art. 6(1)(b)): For processing business contact data in the context of our service agreements.
• Legal obligation (Art. 6(1)(c)): Where required by law.

5. AI Act Compliance

Neuvana's products are designed in accordance with the European AI Act (Regulation (EU) 2024/1689). Our systems:

• Do not perform biometric identification or categorisation that would classify them as prohibited AI practices
• Do not use real-time remote biometric identification in publicly accessible spaces
• Provide transparency about AI processing through signage and documentation at deployment sites
• Maintain human oversight capabilities at all times
• Are subject to regular conformity assessments

6. Data Retention

• Sensor frames: Not retained — processed and discarded in milliseconds
• Aggregated analytics: Retained for the duration of the service agreement, then deleted within 30 days of contract termination
• Website data: Retained for up to 26 months in accordance with analytics best practices
• Business contact data: Retained for the duration of the business relationship plus 3 years

7. Data Sharing

We do not sell personal data. Aggregated, anonymous analytics may be shared with:

• Our direct customers (retailers, brand owners, industrial operators) as part of our service delivery
• Service providers who assist in operating our business (hosting, support), bound by data processing agreements
• Law enforcement or regulatory authorities when required by law

8. International Transfers

As an EU-incorporated company, data processed within our platform remains under EU jurisdiction. Where international transfers are necessary (e.g., for customers outside the EU), we rely on:

• EU Standard Contractual Clauses (SCCs)
• Adequacy decisions where applicable
• Binding corporate rules for intra-group transfers

9. Your Rights (GDPR Articles 15–22)

Because our sensor systems do not collect personal data, individual data subject rights (access, rectification, erasure, portability) do not apply to sensor-derived analytics — there is no personal data to access or delete.

For website and business contact data, you have the right to:

• Access the personal data we hold about you
• Rectify inaccurate data
• Request erasure ("right to be forgotten")
• Restrict processing
• Data portability
• Object to processing
• Withdraw consent at any time

To exercise these rights, contact us at privacy@neuvana.ai.

10. Data Protection Officer

For questions about this policy or our data protection practices, contact our Data Protection Officer at privacy@neuvana.ai.

11. Supervisory Authority

You have the right to lodge a complaint with a supervisory authority, in particular in the EU Member State of your habitual residence, place of work, or place of the alleged infringement. Our lead supervisory authority is the Comissão Nacional de Proteção de Dados (CNPD) in Portugal.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on our website with a revised "Last updated" date.

13. Contact Us

Neuvana AI
EU HQ: Guimarães, Portugal
Global HQ: Austin, TX, USA
Email: info@neuvana.ai
Privacy inquiries: privacy@neuvana.ai