Privacy Policy

1. Scope and roles

Neuralgents is a DBA of ITP360 LLC (“we,” “us”). This policy applies to our marketing website, the customer portal, and the platforms we deploy and run for customers.

Where we collect information for our own purposes — for example, visitors to our website and prospective customers — we act as a controller. Where we process personal information inside a customer’s platform on that customer’s behalf, the customer is the controller and we act as a processor. That processing is governed by our Data Processing Addendum, and the customer’s own privacy policy applies to its end customers.

2. Information we collect

Information you provide

• Account and contact details — name, business name, email, phone number, role.
• Onboarding information you share so we can deploy your platform and agents.
• Billing details processed through our payment processor (we do not store full card numbers).
• Support requests and the content of your communications with us.

Information we collect automatically

• Usage and device data — IP address, browser type, pages viewed, and timestamps.
• Cookies and similar technologies used to operate the site and understand traffic (see Section 9).

Information processed on behalf of customers

When agents operate inside a customer platform, they may process contacts, call recordings, transcripts, messages, tickets, invoices, and related records. We handle this information only on the customer’s documented instructions, as a processor.

3. How we use information

• To provide, operate, maintain, and improve the Services and our website.
• To deploy and run your platform and agents and to provide support.
• To process payments, send invoices, and manage your account.
• To communicate with you about the Services, security, and changes.
• To protect against fraud, abuse, and security threats, and to comply with law.

We do not sell personal information, and we do not use Customer Data processed on a customer’s behalf to train general-purpose AI models for our own benefit.

4. Legal bases (EEA/UK)

Where the GDPR or UK GDPR applies and we act as a controller, we rely on: performance of a contract; our legitimate interests in operating and securing our business; your consent (which you may withdraw); and compliance with legal obligations.

5. How we share information

We share personal information with:

• Service providers and subprocessors that help us deliver the Services — including cloud infrastructure, telephony, payment processing, and email providers — under contracts that restrict their use of the data. A current list of subprocessors is maintained in the Data Processing Addendum.
• Professional advisors such as auditors and lawyers, where needed.
• Authorities when required by law or to protect rights and safety.
• A successor in connection with a merger, acquisition, or sale of assets, subject to this policy.

6. AI processing

Our agents use large language models to generate text and speech and to take actions you configure. AI output may be inaccurate and should be supervised. We process inputs and outputs to provide the Services; we do not use customer content to train third-party foundation models, and our AI subprocessors are contractually restricted from doing so.

7. Data retention

We retain personal information for as long as needed to provide the Services and for legitimate business and legal purposes. When we act as a processor, retention and deletion follow the customer’s instructions and the Data Processing Addendum. Residual copies may persist in backups for a limited period before being overwritten.

8. Security

We use technical and organizational measures designed to protect personal information, including network isolation of customer platforms, encryption in transit, access controls, and logging. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

9. Cookies

We use strictly necessary cookies to run the site and limited analytics cookies to understand usage. You can control cookies through your browser settings; disabling some cookies may affect how the site works.

10. Your rights

Depending on where you live, you may have the right to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to withdraw consent. If you are a California resident, you have rights under the CCPA/CPRA, including the right to know, delete, correct, and to opt out of the sale or sharing of personal information — we do not sell or share personal information as those terms are defined.

To exercise rights, email support@neuralgents.com. If your request concerns data we process on behalf of a customer, we will refer you to that customer and assist them in responding. We will not discriminate against you for exercising your rights.

11. International transfers

We may process and store information in the United States and other countries. Where required, we use appropriate safeguards — such as the European Commission’s Standard Contractual Clauses — for transfers of personal information across borders.

12. Children

The Services are not directed to children under 16, and we do not knowingly collect their personal information.

13. Changes to this policy

We may update this policy from time to time. We will post the new effective date above and, for material changes, provide additional notice.

14. Contact

ITP360 LLC (Neuralgents) is the entity responsible for personal information collected as a controller. Contact us at support@neuralgents.com with privacy questions or requests.