Neuralink Privacy Policy

Last UpdatedFebruary 12th, 2024

This Privacy Policy describes how Neuralink Corp. (“Neuralink”, “we”, “us”, or “our”) collects, uses, discloses and otherwise processes personal information. “Personal information” means information about an identifiable individual as described under applicable privacy laws.

We may provide additional privacy notices to individuals at the time we collect their personal information. For example, our privacy practices in connection with clinical trials are governed by applicable clinical trial protocol(s) and related informed consents and, where applicable, HIPAA authorization forms. Also, the informed consent form to participate in the Neuralink Patient Registry describes our privacy practices with respect to personal information collected as part of the Neuralink Patient Registry. This type of an “in-time” notice will govern how we may process the personal information you provide at that time.

We may change this Privacy Policy from time to time. The “Last Updated” date at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes will become effective when we post the revised Privacy Policy.

How We Collect Personal Information

The Ways in Which We May Collect Information about You:

Information you directly provide to us, such as:

through our website (https://neuralink.com) (the “Website”)
through digital properties or documents that refer or link to this Privacy Policy
when you participate in our research or product-development activities
when use our products or services
when you communicate or interact with us

Third party sources, when authorized by you or otherwise permitted by law, including:

Healthcare professionals, including physicians
Hospitals, clinics and other healthcare providers
Contract research organizations and clinical trial investigators
Publicly available records
Nonprofit organizations, patient advocacy organizations and other industry groups
Online platforms, such as LinkedIn, Facebook, and X, if you engage with our content or otherwise communicate with us via such platforms

Information we collect automatically through your use of the Website, as described further below

The Types of Personal Information We May Collect About You:

We may collect the following information from and/or about you:

Health and medical information (such as information about your medical insurance coverage, physical and mental health conditions, diagnoses, and treatments, genetic information, and family medical history)
Personal contact information (such as your name, email address, mailing address, phone number, and emergency contact information)
Biographical and demographic information (such as your date of birth, age, gender, marital status, education history, and information regarding any parents or legal guardians or legally authorized representatives)
Other identifying information (such as your image, face, body or other identifying characteristics)
Communication information, which may include audio, electronic, or visual information, any data in any files uploaded, emailed or otherwise provided by you, the contents of your communications with us, whether via email, social media, telephone or otherwise, and inferences we may make from other personal information we collect
Publicly available information (such as information you post on LinkedIn and other social networking platforms)
Other information you provide to us, our service providers or research partners (such as information you provide in emails, on phone calls, in surveys, or in other correspondence)

Information Automatically Collected

Like many online websites, we use the following technologies to collect information automatically from you:

Cookies are files with small amounts of data that may include a pseudonymous unique identifier. Cookies are sent to your browser from a website and stored on your device.
Web beacons, also known as pixel tags, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

We and the third parties we work with use cookies and similar technologies to collect information about your use of the Website, such as your IP address, browser type, browser version, pages viewed, time spent on pages, links clicked, location and conversion information. This information may be used by us and our service providers to, among other things, analyze and track data, determine the popularity of certain content, deliver content targeted to your interests on our Website, troubleshoot issues with and improve the operation of our Website, and better understand your online activity.

Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. If you do not accept cookies, however, the Website may not function properly.

We also use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our Website. This information is used to compile reports and to help us improve the Website. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our Website – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page:

https://tools.google.com/dlpage/gaoptout

Do Not Track Signals

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not recognize Do Not Track signals.

How We May Use Personal Information

We may use personal information for various purposes, including:

To operate, maintain, administer and/or improve the Website
To maintain and service our relationship with you (including to provide support services), and to undertake activities to verify or maintain the quality or safety of any of our products or services
To help ensure the security and integrity of our business
To verify your identity
To respond to your requests, questions and feedback
To communicate with you and to send you details or updates about features of the Website or changes to our policies
To conduct product-improvement activities or research-related activities
To inform you about Neuralink’s activities, including to communicate with you in accordance with our legitimate interests (or with your consent, where required by law) to (i) provide you with news and updates about Neuralink’s work and research, including opportunities to participate in clinical trials or other research and development work; (ii) send you questionnaires and surveys to collect feedback about your experience with Neuralink and (iii) send you questionnaires and surveys for use in research and product development or other legally permissible purposes
To comply with our legal and/or regulatory obligations and/or cooperate with regulators and law enforcement bodies
To create anonymized and/or aggregated data sets (i.e., that we cannot link back to any individual) that may be used for a variety of functions, including internal analysis, analytics, and other functions
To protect our rights, your rights, and the rights of others, and to meet our own high standards of business practice
With your consent

How We May Share Your Personal Information

We do not sell your personal information or share personal information with third parties for targeted advertising purposes.

We generally identify to whom, and for what purposes, we will share your personal information at the time we collect your personal information. We may share your personal information with the following persons/entities:

Service providers. We may share your personal information with our vendors and service providers who perform services on our behalf, including hosting, communication, analytics and product-improvement services. If we share your personal information with a service provider, we require that they comply with applicable privacy laws and maintain the confidentiality and security of your personal information. We also require that our service providers only use your personal information for the limited purposes for which it is provided.
Healthcare providers and healthcare professionals and organizations. We may disclose your information to healthcare providers, healthcare professionals and organizations.
Research partners. We may disclose your personal information to partners with whom we conduct product-improvement activities or research-related activities, including researchers, institutions, academics, and publishers.
Professional advisors. We may disclose your personal information with our professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us.
Compliance with laws and law enforcement; protection and safety. We may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern our Website; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
Business transfers. We may disclose your personal information to acquiring and other relevant parties to business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in Neuralink.

Your Privacy Rights

Consent. We collect, use, and disclose your personal information with your consent or as permitted or required by law. How we obtain your consent, including whether it is express or implied, will depend on the circumstances and the sensitivity of the personal information in question. Generally, we will seek your consent at the time we collect your personal information, either orally, electronically, or in writing. If you provide personal information about another individual to us, it is your responsibility to obtain the consent of that individual to enable us to collect, use and disclose their information.

If you wish to withdraw your consent to our collection, use or disclosure of your personal information, please contact us using the contact information below. We will accommodate your request to withdraw consent, subject to legal or contractual restrictions and as required by applicable laws. Withdrawal of your consent may mean that we will no longer be able to provide you with certain services.

Unsubscribe from communications. If you do not want to receive communications from us on a going-forward basis, you may opt-out by following the instructions in the relevant electronic communication or by contacting us using the contact information provided below. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving communications from us, we may still send you important communications such as administrative messages, which you cannot opt-out of.

Access your personal information. You may make a request to review any personal information about you that we have collected, used, or disclosed, by contacting us using the contact information provided below. We will provide you with any such personal information to the extent required by applicable laws.

Update or correct your personal information. In the event we collect personal information directly from you we will rely on the personal information you provide, so it is important that this information be accurate and up-to-date. If your personal information changes, or if you become aware that the personal information we maintain about you is inaccurate, incomplete, misleading, irrelevant or out of date, you may contact us using the contact information provided below. If you demonstrate that your personal information in our records is inaccurate or incomplete, we will amend your personal information as required by applicable laws.

Security

We have implemented safeguards to help secure your personal information. Despite these protections, however, we cannot guarantee that your personal information will never be compromised. You should take measures to protect your personal information. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

Children

We do not knowingly collect personal information from anyone under the age 18. If we learn that we have collected personal information directly from anyone under the age of 18, we will delete that information.

Data Retention And Storage

Neuralink is based in the United States. Please be aware that any information you provide to us, including via our Website, will be stored in the United States. We retain your personal information for as long as is necessary to fulfill the purposes for which it was collected and processed in accordance with applicable laws and this Privacy Policy. To determine the appropriate retention period for your personal information, we will consider our legal and regulatory obligations, the nature of the personal information, and the purposes for which we use personal information. We may also anonymize your personal information so that it can no longer be associated with you.

External Links / Websites

For your convenience and information, we may provide links to websites and other third-party content that are not owned or operated by Neuralink. These links are not an endorsement, authorization or representation that we are affiliated with that third party. We do not exercise control over third party websites or services, and are not responsible for their actions. Other websites and services follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies of the other websites you visit and services you use.

Contact Us

If you need to contact us for any reason specified above, or if you have any questions or concerns about our Privacy Policy, please contact us at privacy@neuralink.com.