Privacy
Privacy & cookie policy.
How NeuroMedia collects, uses, stores and protects personal data, and
how we use cookies on our websites and services.
Company
NeuroMedia Software SA
Effective date
20.05.2026
Last updated
19.05.2026
01
Introduction and Scope
NeuroMedia Software SA (“NeuroMedia”, “we”, “us”, or “our”) is a Belgian technology company that develops AI-
powered media intelligence, advertising monitoring, audience analytics, and related data analysis solutions.
This Privacy Policy describes how we collect, use, store, disclose, transfer, and protect Personal Data when you:
access or use the DeepMonitor Data Explorer platform or any related services (collectively, the “Service”);
visit our websites, including neuromedia.io and related domains;
communicate or interact with us in a business, contractual, or professional context.
This Privacy Policy applies to:
Clients
Authorised end-users
Website visitors
Business contacts
Support contacts
Prospective customers
Other individuals whose Personal Data we process as a Data Controller
This Privacy Policy is drafted in accordance with:
Regulation (EU) 2016/679 (“GDPR”);
the Belgian Data Protection Act of 30 July 2018;
applicable ePrivacy rules; and
Regulation (EU) 2024/1689 (the “EU AI Act”), where applicable.
Where NeuroMedia acts as a Data Processor on behalf of a Client, processing activities are governed by a separate
Data Processing Agreement (“DPA”) and Section 8 of this Privacy Policy.
For the purposes of this Privacy Policy:
Personal Data
Has the meaning set out in Article 4(1) GDPR.
Customer Data
Means any data, content, media, metadata, identifiers, or materials submitted to,
uploaded to, imported into, generated through, or otherwise processed through the
Service by or on behalf of a Client.
Client
Means the organisation subscribing to or using the Service.
End-user
Means any authorised individual accessing or using the Service on behalf of
a Client.
Publicly Available Media
Content
Means media, advertising, publication, broadcast, business, or publicly accessible
online content lawfully accessible without circumvention of access restrictions,
authentication controls, or technical protection measures.
Service
Means the DeepMonitor Data Explorer platform and any related products,
applications, APIs, websites, analytics systems, or services operated by NeuroMedia
Software SA.
Certain Personal Data is necessary for us to provide the Service, including authentication credentials, account
identifiers, billing information, and security-related information. Failure to provide such information may prevent us
from establishing or maintaining access to the Service or fulfilling contractual obligations.
02
Data Controller Identity
For Personal Data processed in connection with the Service, the Data Controller is:
NeuroMedia Software SA
Address
Rue de l'Avouerie 7, 4000 Liège
Phone
+32 2 315 84 65
Service Desk (preferred)
support.deepmonitor.app
Privacy enquiries
support@neuromedia.io
Website
neuromedia.io
NeuroMedia has designated an internal responsible contact for privacy and data protection matters. Where required
by applicable law, NeuroMedia will appoint a Data Protection Officer and publish the relevant contact details.
03
Personal Data We Collect
NeuroMedia collects only Personal Data that is adequate, relevant, and limited to what is reasonably necessary for
the purposes described in this Privacy Policy.
3.1
Data You Provide Directly
We may collect:
Full name
Business email address
Username and authentication credentials
Company name
Professional title and department
Billing and invoicing information
Subscription and contractual records
Support requests and communications
Survey responses and product feedback
Information voluntarily provided during
demonstrations, onboarding, or commercial
discussions
Passwords are stored using industry-standard hashing and security protections and are not stored in plaintext form.
3.2
Data Collected Automatically
We may automatically collect:
IP addresses
Browser type and version
Operating system and device characteristics
Timestamps and session metadata
Authentication events
Pages, reports, features, and functions accessed
API usage and operational telemetry
Search queries and interaction patterns
Error events, diagnostics, and performance metrics
Security, audit, and operational logs
Security and operational logs are maintained for authentication, auditability, fraud prevention, abuse prevention,
incident response, platform integrity, and operational reliability purposes.
Access to such logs is restricted to authorised personnel and systems with a legitimate operational or security-
related need.
Where feasible and appropriate, NeuroMedia may reduce, truncate, pseudonymise, aggregate, or otherwise minimise
identifiable elements contained within operational logs.
3.3
Data Received from Third Parties
We may receive Personal Data from:
Client organisations
Authorised resellers or implementation partners
Publicly available business registries
Commercial business information providers
Authentication or identity providers
Lawful third-party data integrations authorised by
Clients
NeuroMedia processes Publicly Available Media Content for legitimate business purposes including media
monitoring, indexing, analytics, audience intelligence, reporting, searchability, and operational analysis, subject to
proportionality safeguards and applicable law.
3.4
Special Categories of Personal Data
NeuroMedia does not intentionally request or require special categories of Personal Data for ordinary use of
the Service.
However, Customer Data or Publicly Available Media Content processed through the Service may incidentally contain
information revealing:
Racial or ethnic origin
Political opinions
Trade union membership
Religious or philosophical beliefs
Health-related information
Other categories of sensitive information as defined
under Article 9 GDPR
Where such data is processed, NeuroMedia may rely on Article 9(2)(e) GDPR relating to Personal Data manifestly
made public by the data subject, where applicable.
Where NeuroMedia processes special-category data solely on behalf of a Client, the relevant Client remains
responsible for establishing an appropriate lawful basis under Article 9 GDPR.
NeuroMedia does not knowingly use special-category data for independent advertising, discriminatory profiling,
biometric identification, or unrelated commercial purposes.
Unless explicitly agreed otherwise in writing, NeuroMedia does not use the Service for biometric identification, facial
recognition, emotion recognition, or the creation of biometric templates intended to uniquely identify natural persons.
04
Legal Basis for Processing
NeuroMedia relies on the following lawful bases under Article 6 GDPR:
Purpose
Legal Basis
Account management and authentication
Contract performance
Service delivery and platform operations
Contract performance
Billing and financial administration
Contract + legal obligation
Security monitoring and fraud prevention
Legitimate interests
Customer support
Contract + legitimate interests
Product improvement and operational analytics
Legitimate interests
Legal compliance and regulatory obligations
Legal obligation
Marketing communications
Consent or legitimate interests where permitted by law
Where processing is based on legitimate interests, NeuroMedia performs and maintains appropriate balancing
assessments taking into account:
the nature and sensitivity of the data;
the reasonable expectations of affected individuals;
the necessity and proportionality of the processing; and
safeguards designed to minimise privacy impact.
Where consent is required, individuals may withdraw consent at any time without affecting the lawfulness of
processing conducted prior to withdrawal.
05
Purposes of Processing
NeuroMedia processes Personal Data solely for legitimate business and operational purposes including:
Providing and maintaining the Service
Authenticating users and managing accounts
Hosting, infrastructure management, and system
administration
Cybersecurity, fraud prevention, and incident
response
Audit logging and operational integrity
Customer support and technical troubleshooting
Subscription and contractual administration
Compliance with legal and regulatory obligations
Communicating service-related notices and security
alerts
Improving functionality, performance, usability, and
operational reliability
Generating aggregated, statistical, de-identified,
anonymised, or pseudonymised operational insights
Optional marketing and product communications
where permitted by law
NeuroMedia may generate aggregated, statistical, de-identified, anonymised, or pseudonymised information derived
from use of the Service for legitimate operational and business purposes, provided such information does not
reasonably identify individual persons or Clients.
06
AI-Assisted Analytics and Automated Processing
The Service may use machine learning, statistical analysis, automated classification, natural language processing,
and AI-assisted technologies to organise, analyse, categorise, index, enrich, or generate insights from Customer Data
and Publicly Available Media Content.
Such processing is intended to support operational analysis, media intelligence, reporting, and human
review processes.
Unless explicitly authorised in writing by the relevant Client, NeuroMedia does not use Customer Data to train shared,
customer-external, generalised, or foundation machine learning models.
Customer Data processed within one Client environment is logically segregated from Customer Data processed on
behalf of other Clients, except where reasonably necessary for infrastructure management, security, maintenance,
legal compliance, or service delivery purposes.
AI-assisted outputs generated through the Service are intended to support human review and operational workflows
and are not intended to independently determine legal, employment, financial, reputational, compliance, or similarly
significant outcomes relating to individuals or organisations.
AI-assisted classifications, summaries, recommendations, categorizations, analytical outputs, and generated insights
may contain inaccuracies, incomplete information, probabilistic inferences, or false positives and should not be relied
upon as the sole basis for materially significant decisions.
Clients remain responsible for exercising appropriate human review, professional judgment, and independent
verification of outputs generated through the Service.
The Service and AI-assisted outputs are provided for informational and operational support purposes only and are not
intended to constitute legal, regulatory, financial, employment, compliance, or professional advice.
6.1
Article 22 GDPR: Automated Decision-Making
NeuroMedia has assessed its processing activities against Article 22 GDPR relating to solely automated decision-
making producing legal or similarly significant effects.
AI-assisted outputs generated through the Service are designed to support human review by Client personnel and
are not configured to independently produce legally binding, employment-related, financial, reputational, or similarly
significant decisions regarding individuals.
NeuroMedia does not market or configure the Service as a system for fully automated high-risk or high-stakes
individual decision-making.
Clients are responsible for ensuring appropriate human oversight and for determining whether their own use of the
Service triggers obligations under Article 22 GDPR or other applicable laws.
Where applicable and reasonably possible, NeuroMedia will assist Clients in fulfilling relevant legal obligations
pursuant to the applicable DPA.
6.2
EU Artificial Intelligence Act
NeuroMedia monitors evolving obligations under Regulation (EU) 2024/1689 (the EU AI Act) and intends to implement
compliance measures applicable to its role, systems, and deployment contexts as required by law.
Clients deploying the Service in use cases that may independently constitute high-risk AI systems or regulated AI
deployments under the EU AI Act remain responsible for fulfilling their obligations as deployers under applicable law.
07
Data Retention
NeuroMedia retains Personal Data only for as long as reasonably necessary for the purposes described in this
Privacy Policy or as required by applicable law.
Category
Retention Period
Active account data
Throughout the active subscription period
Post-termination account data
Up to 12 months following termination
Platform usage and security logs
Generally up to 24 months
Support communications
Up to 3 years following case closure
Contractual and financial records
Up to 7 years or longer where legally required
Backup data
Generally purged within 90 days following deletion of the live record
Certain information may be retained for longer periods where reasonably necessary for:
Legal compliance
Dispute resolution
Fraud prevention
Security investigations
Protection of NeuroMedia’s legal
rights
Enforcement of contractual
obligations
At the end of the applicable retention period, Personal Data is securely deleted, anonymised, or irreversibly de-
identified where appropriate.
08
When NeuroMedia Acts as a Data Processor
For Customer Data processed on behalf of Clients, NeuroMedia acts solely as a Data Processor under Article
28 GDPR.
Such processing activities are governed by a separate Data Processing Agreement (“DPA”).
The relevant Client remains solely responsible for:
determining the lawful basis for processing Customer Data;
ensuring Customer Data is collected, disclosed, transferred, and processed lawfully;
providing required notices to affected individuals;
responding to data subject requests unless otherwise agreed;
configuring the Service, user permissions, retention settings, exports, integrations, and operational controls
appropriately for their legal obligations and intended use cases;
ensuring uploaded materials do not unlawfully infringe privacy, confidentiality, intellectual property, or other third-
party rights; and
ensuring that it possesses all necessary permissions, authorisations, licences, and legal rights relating to
Customer Data.
NeuroMedia:
processes Customer Data only on documented instructions from Clients unless otherwise required by law;
ensures authorised personnel are subject to confidentiality obligations;
implements appropriate technical and organisational security measures;
assists Clients with GDPR obligations where reasonably possible; and
imposes contractual data protection obligations on authorised sub-processors.
NeuroMedia does not claim ownership of Customer Data processed on behalf of Clients.
09
Data Sharing and Disclosure
9.1
Sub-processors and Service Providers
NeuroMedia engages trusted third-party providers for hosting, infrastructure, communications, analytics, monitoring,
security, and technical support functions.
Sub-processors are subject to written contractual obligations and are required to implement appropriate security and
confidentiality protections.
NeuroMedia performs proportionate due diligence and security assessments of sub-processors appropriate to the
nature of the services provided and the sensitivity of the data processed.
NeuroMedia maintains a list of authorised sub-processors which is available upon written request or through
applicable contractual documentation.
Where required under applicable contractual obligations, Clients may be notified of material changes to authorised
sub-processors.
9.2
Client Organisations
Where End-users access the Service through a Client organisation, that organisation may independently process
Personal Data as a separate Data Controller.
The respective responsibilities of NeuroMedia and the relevant Client are governed by applicable
contractual arrangements.
9.3
Legal and Regulatory Disclosures
NeuroMedia may disclose Personal Data where required by applicable law, court order, regulatory obligation, or
legally binding governmental request.
Where legally permitted, NeuroMedia may challenge, narrow, seek clarification regarding, or object to requests that
NeuroMedia reasonably considers unlawful, disproportionate, overbroad, or lacking appropriate jurisdictional basis.
Where reasonably practicable and legally permitted, NeuroMedia may notify affected Clients or individuals
before disclosure.
9.4
Corporate Transactions
Personal Data may be transferred in connection with a merger, acquisition, financing transaction, restructuring,
insolvency proceeding, or sale of assets.
Where required by law, NeuroMedia will provide appropriate notice and implement required safeguards.
9.5
No Sale of Personal Data
NeuroMedia does not sell, rent, trade, or monetise Personal Data for third-party advertising or
unrelated commercial marketing purposes.
10
International Data Transfers
Personal Data is primarily stored and processed within the European Economic Area (“EEA”).
Where Personal Data is transferred outside the EEA, NeuroMedia implements safeguards consistent with Chapter V
GDPR, which may include:
Standard Contractual Clauses approved by the
European Commission
Adequacy decisions
Binding Corporate Rules
Approved certification frameworks
Supplementary technical, organisational, or
contractual safeguards
Where appropriate, NeuroMedia may conduct transfer impact assessments taking into account applicable legal,
technical, and operational risks associated with international transfers.
11
Your Rights Under GDPR
Subject to applicable law, individuals may have the following rights:
Right of access (Article 15 GDPR)
Right to rectification (Article 16 GDPR)
Right to erasure (Article 17 GDPR)
Right to restriction of processing (Article 18 GDPR)
Right to object to processing (Article 21 GDPR)
Right to withdraw consent (Article 7(3) GDPR)
Right to data portability (Article 20 GDPR)
Rights relating to automated decision-making under
Article 22 GDPR
Requests may be submitted via:
Service Desk
support.deepmonitor.app
support@neuromedia.io
NeuroMedia aims to acknowledge requests within 5 business days and respond substantively within the timeframes
required under applicable law.
NeuroMedia may request reasonable information necessary to verify identity and process requests securely.
Where permitted by law, NeuroMedia may decline or charge a reasonable fee for manifestly unfounded, excessive,
repetitive, technically disproportionate, or abusive requests.
12
Security Measures
NeuroMedia implements technical and organisational measures appropriate to the risks associated with processing
activities, taking into account:
the state of the art;
implementation costs; and
the nature, scope, context, and purposes of processing.
Security measures may include:
Encryption in transit and at rest
Role-based access controls
Least-privilege access management
Privileged-access protections
Multi-factor authentication for administrative access
where appropriate
Security monitoring and threat detection
Vulnerability assessments and periodic security
reviews
Incident response procedures
Backup, resilience, and recovery procedures
Personnel confidentiality obligations and security
awareness measures
Access to Personal Data is periodically reviewed and restricted to authorised personnel with a legitimate operational
or business need.
Security measures are periodically reviewed and updated in light of evolving threats, operational requirements,
technological developments, and regulatory expectations.
No system, network, transmission method, or storage environment can be guaranteed fully secure or free
from vulnerabilities.
Users are responsible for maintaining appropriate password security and safeguarding account credentials.
12.1
Personal Data Breach Notification
Where NeuroMedia acts as Data Controller, NeuroMedia will comply with applicable breach notification obligations
under Articles 33 and 34 GDPR.
Where NeuroMedia acts as Data Processor, NeuroMedia will notify the relevant Client without undue delay
upon becoming aware of a breach affecting Customer Data, in accordance with the applicable DPA and
GDPR requirements.
NeuroMedia maintains incident response procedures and internal breach management processes for this purpose.
13
Children’s Privacy
The Service is intended exclusively for business and professional use and is not directed to individuals under 16 years
of age.
NeuroMedia does not knowingly collect Personal Data from children.
If NeuroMedia becomes aware that Personal Data relating to a child has been collected inadvertently, NeuroMedia
will take reasonable steps to delete such information.
14
Cookies and Tracking Technologies
14.1
Strictly Necessary Technologies
NeuroMedia uses strictly necessary cookies and similar technologies required for authentication, security, fraud
prevention, session continuity, and core Service functionality.
Such technologies do not require consent where exempt under applicable law.
14.2
Optional Technologies
Where optional analytics, preference, or functional technologies are used, NeuroMedia will obtain consent where
legally required.
Users may accept, reject, or customise optional technologies through applicable consent management mechanisms.
Cookie consent preferences may be retained to demonstrate compliance with applicable consent requirements.
14.3
What We Do Not Use
NeuroMedia does not use third-party advertising cookies, cross-site behavioural advertising
technologies, or social-media tracking pixels for unrelated advertising purposes.
15
Third-Party Services and Integrations
The Service may integrate with third-party services, APIs, websites, plug-ins, authentication providers, or
external platforms.
Such third-party services are governed by the privacy practices and terms of the relevant third party.
NeuroMedia does not control and is not responsible for the availability, security, functionality, content, or independent
data handling practices of third-party services except where required by law.
Certain third-party providers may independently act as separate Data Controllers.
16
Changes to This Privacy Policy
NeuroMedia may update this Privacy Policy periodically to reflect:
operational changes;
legal or regulatory developments;
evolving security practices; or
Service functionality updates.
Where changes are material, NeuroMedia may provide notice through the Service, by email, or through other
reasonable communication channels where practicable.
Continued use of the Service following publication of an updated Privacy Policy constitutes acknowledgement of the
updated terms to the extent permitted by applicable law.
17
Client-Specific Terms
Separate contractual agreements, enterprise arrangements, service terms, DPAs, or negotiated privacy provisions
may apply to certain Clients.
Where such agreements conflict directly with this Privacy Policy, the relevant contractual provisions prevail solely to
the extent of the conflict.
18
Right to Lodge a Complaint
Individuals may lodge complaints with a competent supervisory authority.
The lead supervisory authority for NeuroMedia is:
Autorité de protection des données / Gegevensbeschermingsautoriteit
Address
Rue de la Presse 35
1000 Brussels, Belgium
Website
autoriteprotectiondonnees.be
This right is without prejudice to other legal remedies available under applicable law.
19
Contact Us
For privacy, security, or data protection enquiries:
NeuroMedia Software SA
Address
Rue de l’Avouerie 7, 4000 Liège
Phone
+32 2 315 84 65
Service Desk
support.deepmonitor.app
support@neuromedia.io
Website
neuromedia.io
NeuroMedia aims to respond to privacy-related enquiries within reasonable timeframes and in accordance with
applicable legal obligations.
Questions about your data?
Write to us and we’ll get back to you.
support@neuromedia.io
© 2026 NeuroMedia Software