Effective Date: February 23, 2026 

Neumarker is committed to protecting the privacy and security of personal information. This  Privacy Notice describes how we process personal data in connection with our research, product development, and business operations. 

1. Who We Are 

Neumarker is a healthcare technology company developing AI-enabled software as a medical device (AI-SaMD) solutions intended to support clinical decision-making. 

For privacy-related inquiries, please contact:

Email: privacy@neumarker.ai

2. Categories of Personal Data We Process 

In connection with research collaborations and product development activities, we may process  the following categories of data: 

  • Pseudonymized health data (e.g., EEG data, clinical information) 
  • Limited demographic information 
  • Professional contact information (e.g., researchers, business partners) • Website usage information (if applicable) 

We do not receive direct identifiers such as names, addresses, or contact details of patients in research datasets unless explicitly stated and contractually permitted. 

3. How We Use Personal Data 

We process personal data for the following purposes: 

  • Research and validation of AI-SaMD technologies 
  • Development and testing of predictive models 
  • Regulatory submissions and compliance activities 
  • Collaboration with research institutions and healthcare providers 
  • Business operations and relationship management 

Where we receive health-related data from collaborators, it is processed solely for the specific research or development purposes defined in applicable data sharing agreements. 

4. Lawful Basis and Contractual Safeguards 

When we process health-related data provided by research collaborators, we do so pursuant to  contractual agreements that define permitted uses and safeguards. Where personal data is transferred to us from the United Kingdom or European Economic Area, such transfers are  governed by appropriate contractual safeguards, including Standard Contractual Clauses (SCCs) and, where applicable, the UK Transfer Agreement.

We do not independently determine the lawful basis for the original collection of data by research institutions. Our processing is limited to the purposes authorized under contract. 

5. International Data Transfers 

Neumarker is based in the United States. Where personal data is transferred from the UK or EEA to the United States, we rely on legally recognized transfer mechanisms such as Standard  Contractual Clauses to ensure appropriate safeguards are in place. 

6. Data Security 

We implement technical and organizational security measures designed to protect personal data  from unauthorized access, disclosure, alteration, or destruction. These measures include  encryption, role-based access controls, multi-factor authentication, and system monitoring. Access to research datasets is restricted to authorized personnel with a defined business need. 

7. Data Retention 

We retain personal data only for as long as necessary to fulfill the purposes for which it was  provided and in accordance with applicable contractual and regulatory requirements. Upon  completion of research activities or expiration of contractual obligations, data is securely deleted  or archived as required. 

8. Data Subject Rights 

Individuals located in the UK or EEA may have rights under applicable data protection laws,  including the right to request access to, correction of, or deletion of their personal data. 

If we receive a data subject request related to research data provided by a collaborator, we will coordinate with the data-providing institution as required under applicable agreements. Because  research datasets provided to us are typically pseudonymized, we may not be able to identify  individuals directly. 

To exercise privacy rights or submit a request, please contact: privacy@neumarker.ai Individuals also have the right to lodge a complaint with their local data protection authority.

9. Changes to This Notice 

We may update this Privacy Notice from time to time to reflect changes in our practices or legal requirements. Updates will be posted on this page with a revised effective date. 

10. Contact Us 

If you have questions about this Privacy Notice or our privacy practices, please contact:

Neumarker: privacy@neumarker.ai