If I may emphasize your point, the frequency reference doesn't come from a neurological time-keeping mechanism. Instead it comes from physical resonance. So it

If I may emphasize your point, the frequency reference doesn't come from a neurological time-keeping mechanism. Instead it comes from physical resonance. So it is definitely still a "clock". It's like having many pendulum clocks in your ear. However it is unlikely that whatever you use to count by seconds has to do with the little pendulums (pendula) in your ear.