Privacy Policy

This Privacy Policy is issued by Syntrixai LLC, a limited liability company organised under the laws of the State of Wyoming, United States of America, registered with the Wyoming Secretary of State under filing ID 2023-001384939, operating under the trade name NeuroPage. Its registered office is at 30 N Gould St, Ste R, Sheridan, WY 82801, USA. References in this Privacy Policy to NeuroPage, we, us, or our mean that company.

Although the company is incorporated in the United States, the Services are built and operated for a European customer base. Customer and prospect data is stored in the European Union, as described in Article 12.

This Privacy Policy applies to personal data processed by NeuroPage in connection with: (a) the NeuroPage website; (b) customer accounts and workspaces; (c) personalized pages generated through the Services; (d) persona analysis and the research that feeds it; (e) customer-authorized integrations; (f) support, billing, security, and administration; and (g) product analytics and service improvement activities.

If you are reading this because a NeuroPage customer sent you a page built for you, Article 7 explains what was analysed and why, and Article 15 explains what you can ask us and them to do about it. You can contact us directly at privacy@neuropage.io without going through the sender.

Where NeuroPage processes personal data on behalf of a customer in its capacity as a processor, the applicable Data Processing Agreement and customer instructions govern that processing in addition to this Privacy Policy. This Privacy Policy does not replace any separate contractual obligations between NeuroPage and its customers.

NeuroPage acts as an independent controller where it determines the purposes and means of processing for its own business operations, including account administration, website operations, customer relationship management, billing, fraud prevention, security monitoring, support, legal compliance, and internal service improvement activities.

NeuroPage acts as a processor when it processes Customer Data, including lead data and professional profile data, on behalf of a customer in order to provide the Services, generate personalized pages, run persona analysis, apply customer-configured logic, or support campaign workflows directed by the customer.

The customer decides which individuals are entered into the Services, on what legal basis, and what is sent to them. The customer is therefore the controller for that processing and carries the duty to inform those individuals and to weigh its interests against theirs. NeuroPage supports that duty rather than assuming it: we publish this Privacy Policy, we place a transparency notice on every generated page, and we provide customers with an assessment template on request.

The allocation of controller and processor roles depends on the factual context of the processing and not solely on the labels used in this Privacy Policy. Where required by applicable law, NeuroPage and the relevant customer will enter into a Data Processing Agreement.

Names, work email addresses, billing contacts, account credentials, business details, subscription information, and related administrative records needed to create and manage customer accounts and workspaces.

Depending on the workflow used by a customer: a LinkedIn URL, name, job title, employer or company name, seniority, public professional history, industry context, work email address, and other professional profile information relevant to page generation or persona analysis.

The output described in Article 7: a persona label, a written summary, and numeric estimates across communication-style and trait dimensions, together with the personalization settings derived from them. This output is stored against the lead record it was generated for.

Prompts, generated pages, generated copy, generated outbound messages, research summaries, layout choices, and related service outputs created through the Services.

When a recipient opens a personalized page, we record that the page was viewed, along with interaction events, approximate timing, and technical data such as device and browser information and IP address. Because a personalized page is generated for one named individual, these events are linked to that individual and are visible to the customer that sent the page. We do not record session replays of generated pages.

Usage events, session events, error logs, and other technical or behavioral analytics relating to use of the NeuroPage application by customers and authorized users.

If you contact us, request a demo, open a support request, or otherwise communicate with us, we process the information contained in those communications, including contact details, account references, issue descriptions, and related correspondence.

NeuroPage does not require personal phone numbers, private email addresses, or Sensitive Data for its standard workflow. If such data is received unnecessarily, we may ignore it, restrict it, suppress it from downstream use, or delete it in accordance with our service design and retention practices.

We receive personal data directly from customers, authorized users, website visitors, and support contacts when they create accounts, connect integrations, configure workspaces, upload files, submit URLs, request support, or otherwise interact with the Services.

We receive personal data from integrations and uploads authorized by a customer, including CRM systems, outreach platforms, spreadsheets, APIs, and similar business systems used by the customer.

When a customer submits a lead, we query professional data and web research providers to assemble the public professional context used for page generation and persona analysis. Those providers are named in the Subprocessor List. NeuroPage does not offer a social-platform scraping interface, and does not sell or resell contact lists.

We collect usage data automatically through the website, through generated pages, and through the analytics tools named in the Cookie Policy.

To create, host, deliver, and operate customer workspaces, personalized pages, generated messages, customer-authorized workflows, integrations, and customer support.

To assemble public professional context about a lead and their employer, to run the persona analysis described in Article 7, and to generate page copy, page structure, and outbound message drafts that reflect that context.

To record page views and interactions and report them to the customer that sent the page, and to measure and improve page generation quality.

To manage subscriptions and credit balances, provide notices, administer accounts, respond to inquiries, and maintain customer records.

To detect misuse, investigate incidents, enforce our contractual terms, prevent fraud or abuse, debug issues, and protect the Services and our users.

Where necessary to comply with applicable laws, court orders, lawful requests, accounting obligations, tax obligations, or regulatory requirements.

NeuroPage estimates how a professional audience is likely to prefer to receive information, and uses that estimate to choose the tone, the order of sections, and the emphasis of a generated page or message. The estimate is expressed using well-known communication-style frameworks, including DISC and a five-factor trait model, because those frameworks give the generator a consistent vocabulary to work with.

Public professional signals only: job title, seniority, function, industry, employer, and publicly available professional text such as a public profile description or company website content. It is not based on private messages, browsing behaviour, purchased psychological data, or any special category of personal data.

It is not a psychological assessment, a clinical instrument, or a statement of fact about anyone. It is an inference drawn from role-level signals, it can be wrong, and it should be read as a writing instruction rather than a description of a person.

It is not used to make, and must not be used by customers to make, decisions producing legal effects or similarly significant effects, including employment, credit, insurance, or eligibility decisions. Article 17 states this as a prohibition on customers.

The Services present the persona analysis to customers as a label and a written explanation of how to approach the conversation. Raw dimension scores are not displayed as a per-person readout in the application, and NeuroPage does not market the product by showing scored profiles of named individuals.

We state this plainly because it matters: the persona analysis output, including the underlying dimension estimates, is stored against the lead record so that a page can be regenerated without repeating the research and the cost. It is retained for as long as the customer keeps that lead in their workspace, and is deleted under Article 13 when the lead, the campaign, or the account is deleted, or when a valid erasure request is accepted.

A recipient may object to this profiling. On a valid objection we will delete the persona analysis for that individual and suppress its regeneration, and we will inform the customer who submitted them. Write to privacy@neuropage.io. You do not need to contact the sender first.

NeuroPage does not use customer data or prospect data to train, fine-tune, or otherwise improve any machine learning model, whether our own or a third party model. We have never done so. This applies to Customer Data, Lead Data, persona analysis output, generated content, and page interaction data alike.

We generate text and analysis through third party model providers, named in the Subprocessor List. Each of them commits in its API terms not to train its models on data submitted through the API, and we keep our accounts configured to the no-training and reduced-retention options those providers make available.

Only what the generation step needs: the professional context assembled for that lead, the customer brand and campaign configuration, and the instructions built from them. Account credentials, billing data, and unrelated workspace data are not sent to model providers.

We do measure aggregate service performance, such as how often generation succeeds or how a section type performs across many pages. That measurement uses aggregated and de-identified analytics, and it is not model training.

We share personal data with the subprocessors that host, generate, research, communicate, and measure on our behalf. The complete current list, with each provider role, location, and the categories of data it receives, is published at neuropage.io/subprocessors. Subprocessors may process personal data only as needed to perform services for us and are bound by written terms consistent with this Privacy Policy and our Data Processing Agreement.

We give customers advance notice before a new subprocessor begins processing their personal data, so that a customer may object on reasonable data protection grounds. The mechanism is set out in the Data Processing Agreement.

Where a customer connects a third party service using their own credentials, data flows to that service because the customer instructed it. Those services are the responsibility of the customer rather than subprocessors of NeuroPage, and currently include HeyReach, Smartlead, Instantly, ReachBoost, Apollo.

We may disclose personal data to professional advisers, auditors, insurers, legal counsel, or competent authorities where reasonably necessary for legal, compliance, defence, or transaction-related purposes.

If NeuroPage is involved in a merger, acquisition, financing, restructuring, or sale of assets, personal data may be disclosed as part of that transaction subject to applicable confidentiality and legal requirements.

NeuroPage is not a lead database and does not sell, rent, or licence personal data. The Services are a personalization and page generation layer on top of customer-provided or customer-authorized data sources.

Customer and prospect data is stored in the European Union. The primary database and file storage run in Supabase in the eu-west-1 region (Ireland). Generated page assets are stored in Cloudflare R2 buckets created with EU jurisdiction. The web application is deployed to the Vercel eu-west region. Database backups stay in the same EU region as the database.

The following subprocessors store or process data inside the EEA: Supabase, Cloudflare, Vercel, Airscale, Linkup, PredictLeads, Google Workspace, PostHog.

Some processing necessarily takes place outside the EEA, principally the model providers that generate text and the research providers that look up public professional data. These transfers rely on the European Commission Standard Contractual Clauses incorporated into each provider data processing agreement, supplemented by the technical measures in Article 14.

The following subprocessors involve a transfer outside the EEA: OpenRouter, Anthropic, Groq, Apollo, Exa, Firecrawl, Resend, Google (Tag Manager and Analytics), Microsoft (Clarity). Each is listed with its location and safeguard on the Subprocessor List.

Customers may request the Standard Contractual Clauses annex to our Data Processing Agreement and our transfer impact assessment at privacy@neuropage.io, for use in their own records.

Subject to applicable law, individuals have rights of access, rectification, erasure, restriction, objection, and portability, and the right to lodge a complaint with a competent supervisory authority. In the Netherlands that is the Autoriteit Persoonsgegevens.

Write to privacy@neuropage.io and tell us the page address or the name of the company that contacted you. You do not need to contact the sender first, and you do not need an account.

Because the sending customer is the controller for that outreach, we will normally act on the request ourselves for the data we hold and pass the request to that customer so they can act on their copy. Where you object to the persona analysis specifically, Article 7.6 applies.

We respond within the statutory period, which under the GDPR is one month and may be extended by two further months for complex requests, in which case we will tell you. We may ask for information reasonably needed to verify who you are.

Where NeuroPage processes personal data on behalf of a customer as a processor, we act on the documented instructions of that customer, unless applicable law requires otherwise. We will not use a processor role as a reason to leave a request unanswered: we will tell you who the controller is and route the request.

Where personal data is processed for direct marketing or related profiling, you have the right to object. On objection we suppress the individual from further generation and outreach in our systems and notify the customer that submitted them.

The NeuroPage website uses strictly necessary cookies to keep you signed in and to remember your preferences, and analytics tags that load only after consent. Every cookie is named, with its purpose and lifetime, in the Cookie Policy.

Personalized pages served by NeuroPage set no cookies and write nothing to local storage. Page analytics are first-party and server-side, and no third-party analytics client, tag manager, or session-replay script is loaded on them.

Where a customer serves generated pages from their own domain, the customer is responsible for any additional tags, pixels, or consent requirements they add to that domain.

The Services are designed for business and professional use. NeuroPage does not intend its services for use in relation to the data of children or for child-directed services.

Customers must not use the Services, or the persona analysis described in Article 7, for child-directed targeting, political campaigning, unlawful discrimination, credit scoring, insurance eligibility, or automated employment or other decisions that produce legal effects or similarly significant effects concerning individuals.

We may update this Privacy Policy to reflect legal, operational, product, or service changes. When we do, we update the effective date above and, where the change is material, give customers notice.