Both to ensure compliance with applicable regulations such as the General Data Protection Regulation and provide transparency to our process of keeping and using data, this data retention policy outlines how Neuromatch stores data, how long certain data is kept, and how one can request it should be deleted or forgotten.
Neuromatch gathers several types of data about people. This includes participants in our programs, employees, and contractors that we work with. Some of this data is needed for participation in our programs. For example, we need a person’s email to communicate with them about their course, provide them links to their classroom, and similar activities. Other data is required for financial compliance purposes. For example, we need to gather tax forms from our contractors (such as our teaching assistants).
Identity Data
Neuromatch gathers the following data about people and their identities, though not all data is gathered from every person and not all data is required to participate in our programs. If we didn’t ask for it from you in a form that you filled out, we didn’t gather it.
Name
Email Address
Physical Address
Phone Number
Citizenship Status
Photograph
Visa Status and Type
Social Security Number
Race and Ethnicity
Language Spoken
Gender Identity
Previously written content (Abstracts)
Third Party Profiles (LinkedIn, Google Scholar, Semantic Scholar, ORCID, etc)
Personal Finance Data
To pay teaching assistants, Neuromatch gathers some financial data from participants. To facilitate payment transfer to OFAC sanctioned countries, Neuromatch also occasionally gathers this information for intermediary people that are involved in the transaction.
Bank Information (Account Number, Routing Number, and Bank Name)
Address
Name
The information above is also shared to our service provider, bill.com
We collect and process incoming payments through Stripe, though we may send out refunds through this same service. See Stripe for their data retention policy. We can see the following data from Stripe:
Name
Email
Credit Card Type
Bank Name
Last Four Digits of Credit Card and Expiration Date
Amount Paid
Date Paid
Participation Data
When a person participates in our programs, we usually connect their name or personal data to their participation such that we know which people participated in which events and how they rated them. We do this to understand which events they may be interested in in the future and to know the demographics and diversity of people attending certain types of events. This helps us create events and programs that suit the most people possible. This type of data is typically only seen in summary form, not on an individual basis.
Finance Data
Neuromatch, accounting firms that it contracts with, and payroll firms it contacts with generate financial records in the form of income statements, payroll records, quarterly reports, yearly tax returns, and similar items. This includes payments made to individual contractors.
Contract Data
Neuromatch enters contracts with vendors, other companies, and individuals. These are sometimes mutually signed and sometimes signed one way. Some contracts contain identifying information such as a person’s name, title, and email. They will also typically contain a compensation amount for a service or payroll, dates, and locations.
Data Retention Periods
People Data
Data associated with people is used for maintaining user accounts. As long as we continue offering our services, these data will be kept indefinitely while the user wishes for their account to be active. We assume the account should be active unless told otherwise. A user can request for their account to be deleted in which we will delete all data that we are not required to keep by law (mentioned below in financial data).
An exception exists for personal financial data as this data is only used temporarily to initiate or receive money transfers. This data may be kept up to three years, but will generally be deleted upon use.
Finance Data
Neuromatch keeps all financial records for at least 10 years.
Contract Data
Neuromatch keeps all contract data indefinitely so as to continue to observe and understand the end date and indefinite conditions and terms on our contracts.
Requests to Remove Data
Users and participants may request their data be removed by emailing support@neuromatch.io from the email associated with their people data. No other data at Neuromatch can be requested to be removed.