Privacy policy.

1. INTRODUCTION

NeuralFin Pty Ltd (“NeuralFin”, “we”, “our”, or “us”) is committed to protecting the privacy and security of personal information collected from users (“you” or “your”) of our websites, mobile applications, AI services, and related platforms (collectively, the “Services”). This Privacy Policy explains:

  • What personal data we collect

  • How we collect it

  • How we use it

  • How we store and protect it

  • When and why we share it

  • Your rights and choices

  • How you can contact us regarding your data

We comply with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), the General Data Protection Regulation (GDPR) for EU residents, and other applicable data protection laws.

2. DEFINITIONS

  • Personal Data: Any information relating to an identified or identifiable individual.

  • Processing: Any operation performed on Personal Data, including collection, storage, use, sharing, or deletion.

  • Data Controller: NeuralFin determines the purposes and means of processing your data.

  • Data Processor: Third parties processing data on our behalf under contractual obligations.

3. INFORMATION WE COLLECT

3.1 Directly Provided Information

We collect information you voluntarily provide to us, including:

  • Name

  • Email address

  • Contact details

  • Adoption registration details

  • Uploaded images, videos, or audio for shark identification and research

  • Communications sent to us (e.g. enquiries, feedback, support requests)

3.2 Automatically Collected Information

When you use our Services, we automatically collect:

  • Device Information: IP address, browser type, operating system, device identifiers

  • Usage Data: Pages visited, time spent, click actions, referring URLs

  • Cookies and Tracking Data: Small data files to operate, secure, and improve our Services

3.3 Information from Third Parties

We may receive information from:

  • Research partners submitting shark data for identification

  • Payment processors (for adoptions or purchases) providing transaction confirmations

  • Publicly available sources to verify conservation data accuracy

4. PURPOSES FOR DATA PROCESSING

We process your data for the following purposes:

  • To provide, operate, and maintain our Services

  • To verify shark species and individual identification

  • To enable adoption registrations and process related payments

  • To communicate with you regarding your account, adoptions, or uploads

  • To improve AI models for species recognition and marine conservation research

  • To analyse usage trends for platform optimisation

  • To comply with applicable laws and regulatory requirements

  • To protect the security and integrity of our systems

We do not use your data for automated decision-making that produces legal effects concerning you without human involvement.

5. LEGAL BASIS FOR PROCESSING

We process your data based on:

  • Consent: When you provide personal data for specific purposes (e.g. adoption registration)

  • Contractual necessity: To perform agreements with you

  • Legitimate interests: For research, conservation, and platform improvement while respecting your rights

  • Legal obligations: Compliance with law enforcement or regulatory requirements

6. DATA RETENTION

We retain your personal data only as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or for archiving in the public interest, scientific, or historical research purposes consistent with data minimisation principles.

Uploaded shark images and associated metadata may be retained indefinitely for research purposes, unless deletion is requested by you where applicable.

7. DATA SHARING AND DISCLOSURE

We may share your data with:

7.1 Service Providers

Third-party vendors performing functions on our behalf, including:

  • Cloud hosting and storage providers

  • Payment processors (e.g. Stripe, PayPal)

  • Email delivery platforms

  • Data analytics providers

These providers are required to protect your data and process it only in accordance with our instructions and applicable data protection laws.

7.2 Research and Conservation Partners

With your consent or as aligned with our mission, we may share relevant data with universities, marine conservation NGOs, or governmental agencies for:

  • Scientific publications

  • Shark population monitoring

  • Threat assessments and conservation strategies

7.3 Legal Requirements

We may disclose data when necessary to:

  • Comply with legal obligations

  • Respond to lawful requests from public authorities, including to meet national security or law enforcement requirements

  • Protect the rights, safety, or property of NeuralFin, our users, or others

8. DATA SECURITY

We implement a range of technical and organisational security measures to protect your data, including:

  • Secure server infrastructure with strict access controls

  • Data encryption in transit (SSL/TLS)

  • Regular vulnerability assessments and security audits

  • Access limited to authorised personnel under confidentiality agreements

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your data using commercially reasonable means, we cannot guarantee its absolute security.

9. INTERNATIONAL TRANSFERS

Your personal data may be transferred to and maintained on servers located outside your state, province, or country, including jurisdictions with different data protection laws. Where required, we implement safeguards such as standard contractual clauses to ensure an adequate level of protection in compliance with applicable laws.

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tracking technologies to:

  • Authenticate users

  • Remember preferences

  • Analyse site traffic and usage trends

  • Improve Services and AI performance

You can control cookie preferences through your browser settings. Disabling cookies may affect the functionality of certain features of the Services.

11. YOUR RIGHTS

Depending on your jurisdiction, you may have the right to:

  • Access the personal data we hold about you

  • Request correction of inaccurate or incomplete data

  • Request deletion or restriction of processing

  • Object to processing based on legitimate interests

  • Withdraw consent at any time (without affecting the lawfulness of processing before withdrawal)

  • Lodge a complaint with a supervisory authority

To exercise these rights, contact us at neuralfin.org@neuralfin.org. We will respond in accordance with applicable data protection laws.

12. CHILDREN’S PRIVACY

Our Services are not directed to children under 16 years of age. We do not knowingly collect personal data from children. If we learn that a child has provided us with personal data without parental consent, we will delete such information promptly.

13. CHANGES TO THIS POLICY

We may update this Privacy Policy periodically. Changes will be posted on this page with an updated effective date. You are advised to review this policy regularly to remain informed about how we protect your data.

14. CONTACT US

For questions, concerns, or to exercise your data rights, please contact:

NeuralFin Privacy Officer
📧 Email: neuralfin.org@neuralfin.org