Last updated Feb 12th 2021
Thank you for choosing to be part of our community at Neatframe Limited (“Neat,” “Company,” “we,” “us,” or “our”). We are committed to protecting your personal information and your right to privacy.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
In Short: We collect information that you provide directly to us such as name, phone number, email address, contact information, usernames and passwords.Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected passively when you visit our Sites or utilize our Services.
Personal information you disclose to us
In Short: We collect personal information that you provide to us such as name, address, contact information, passwords and security data, and payment information.
We collect personal information that you voluntarily provide to us when registering for the Services, expressing an interest in obtaining information about us or our products and services, when participating in activities on the Services or otherwise, when you contact us.
The personal information that we collect depends on the context of your interactions with us and the Sites and Services, the choices you make and the products and features you use. The personal information we collect can include the following:
Name and Contact Data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We collect passwords, password hints, and similar security information used for authentication and account access.
Payment Data. We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information collected through our Sites and Services
In Short: We collect information regarding the apps, browsers, and devices you use to access the Sites and Services.
Tracking Technologies: Like many businesses, we also collect personal information through cookies and similar tracking technologies. This information may include specific device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, precise geolocation, and other information about how and when you use our Sites or Services and other technical information. This activity is further described in the Cookies and Advertising and Online Tracking sections below.
Usage Metrics: Additionally, certain of our products collect adoption and usage metrics, which might be considered personal information because they are often traceable to a particular device or user. Examples of such usage metrics include without limitation: (i) deployment information including software version and geolocation; (ii) quality metrics such as crash analytics, connectivity or responsiveness; (iii) installation information such as device orientation and surroundings; and (iv) information regarding your usage of available features.
Information collected about you from third parties
We collect your personal information from third parties, such as social media sites (such as Facebook), joint marketing partners, and data co-ops. Examples of the information we receive from other sources include: social media profile information, (your name, gender, birthday, email, current city, state and country, profile picture URL and any information that you choose to make public); and links including paid listings (such as sponsored links).
Inferences. We also collect inferences drawn from the categories above in order to create a profile about you to reflect your preferences, characteristics, behavior and attitude.
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, provision and improvement of the Sites and Services, compliance with our legal obligations, and/or your consent.
We use the information we collect or receive:
To facilitate account creation and logon process. If you choose to link your account with us to a third party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.
To send you marketing and promotional communications. We and/or our third-party marketing partners may use your personal information for our marketing purposes, if this is in accordance with your marketing preferences. For example, we may use your usage metrics to suggest methods to enhance the Services. You can opt-out of our marketing emails at any time (see the “MANAGING YOUR ACCOUNT INFORMATION AND PREFERENCES” section below).
Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Sites and Services.
Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in competitions.
Request Feedback. We may use your information to request feedback and to contact you about your use of our Sites and Services.
Maintenance and Improvement of the Site and Services. We use your information to provide you with the Site and Services, handle your customer service requests, improve the quality and experience of our Services, and to help us diagnose technical service problems and administer the Site and Services.
To protect our Services. We may use your information as part of our efforts to keep our Sites and Services safe and secure (for example, for fraud monitoring and prevention).
To enforce our terms, conditions and policies for Business Purposes, Legal Reasons and Contractual.
To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
To deliver services to the user. We may use your information to provide you with the requested Services.
To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
For other Business Purposes. We may use your information for other Business Purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Sites and Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
In Short: We only share information with your consent, to comply with laws, to provide you with the Site and Services, to protect your rights, or to fulfill business obligations.
We may process or share data based on the following legal basis:
Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.
Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
More specifically, we may need to process your data or share your personal information in the following situations:
Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Sites and Services, which will enable them to collect data about how you interact with the Sites and Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. Unless described in this Policy, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organization apart from us. They will hold it securely and retain it for the period we instruct.
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
Business Partners. We may share your information with our business partners to offer you certain products, services or promotions.
We use Google Analytics on the Site and Services to analyze how users use the Site and Services, and to provide advertisements to you on other websites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.
5. ADVERTISING AND ONLINE TRACKING
7. PROCESSING IN THE UNITED STATES
Please be aware that your personal information and communications may be transferred to and maintained on servers or databases located outside your state, province, or country. If you are located outside of the United States, please be advised that we process and store all information in the United States. The laws in the United States may not be as protective of your privacy as those in your location. By using the Site or Services, you are agreeing to the collection, use, transfer, and disclosure of your personal information and communications will be governed by the applicable laws in the United States.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites and Services is at your own risk. You should only access the services within a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites and Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Sites and Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age 18, please contact us at firstname.lastname@example.org.
11. MANAGING YOUR ACCOUNT INFORMATION AND PREFERENCES
You can opt out of the collection of certain usage metrics by changing the relevant settings on your device, where applicable. You can opt out of receiving certain e-mails by e-mailing us at email@example.com. You can also opt out of receiving marketing e-mails from us by following the link provided at the bottom of all marketing e-mails you receive from us. You are able to opt out of receiving marketing e-mails from us, however, you cannot opt out of receiving all e-mails from us, such as e-mails about the status of your account.
12. DO EUROPEAN UNION (“EU”) AND UNITED KINGDOM (“UK”) RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are an EU or UK resident, you have certain privacy rights.
The data controller for the Site and Services is:
110 E 42nd St
New York 10017
We use the information we collect about you to pursue the following purposes, which are necessary for the performance of the contract between us to provide you with the products or services you requested or which we consider in our legitimate interests:
Based on your voluntary consent, we also use:
In order to comply with our legal obligations, we may also use some of your personal information to detect and prevent illegal uses, abuse, spam, fraud, security incidents and other harmful activity or government or court orders.
You may have certain rights under EU data protection legislation with respect to your personal information, such as the right to:
Regarding the transfer of personal information to countries outside the EU, we have entered, or will enter, into so-called “Standard Contractual Clauses” approved by the Commission of the European Union for international transfer of personal information to controllers or processors established in third counties as the case may be, when appropriate.
The principle that we apply is that your personal information will be deleted when they are no longer necessary for the purpose for which they were collected.
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a California resident, you have certain privacy rights under the California Consumer Privacy Act (“CCPA Rights”). This section describes those rights and how you can exercise them with Neat.
CCPA Rights Requests
Right to Know and Right to Deletion
You can request what personal information we have collected, used, disclosed, and sold in the preceding 12 months.
You can request the specific pieces of personal information we have collected about you.
You can request the following categories of information:
You can also request that we delete your personal information. We may not delete all of your personal information if one of the following exceptions applies:
Please note that if we delete your personal information, many of our services will not work the same. Some examples include, but are not limited to email newsletter, product recommendations:
To submit a request to know or a request to delete, please send an email to firstname.lastname@example.org. In order to verify your identity, you will need to provide personal information, such as purchase order or account information. We will match this information to the information on our systems. For an online request to delete, we will also send you a second verification to confirm that you want your information to be deleted. To use an agent, you must provide the agent with written authorization. In addition, the customer may be required to verify their own identity with Neat.
If you wish to make multiple requests under this section, we recommend sending the deletion request last, as we will not be able to fulfill your other requests once we have deleted your information. We will maintain a record of your request to know or request to delete.
Please note that if we delete your Personal Information, some of our services will not work the same. For example, your previous opt out requests will not be saved, and saved preferences and information will no longer be available.
Do Not Sell My Personal Information
Please note that Neat does not exchange personal information for money with anyone, nor does Neat otherwise share personal information within the meaning of a “sale.” Also, Neat does not currently disclose personal information to third parties for their direct marketing purposes.
Right to Opt Out of Sale
California residents have the right to opt out of the sale of your personal information to third parties, as “sale” is defined under CCPA.
Although we do not currently “sell” personal information, you can exercise your choice to opt out of the sale of your personal information at any time by emailing us at email@example.com and we will keep a record of your request in case our privacy practices change.
You may change your mind and opt back in to personal information sales at any time by emailing us at firstname.lastname@example.org.
We will not discriminate against you for exercising any of your CCPA Rights and we will not deny you services, charge you a different price, or provide you with a lesser quality of services if you exercise any of your CCPA Rights.
We offer various financial incentives. The terms of the financial incentive will be presented to you at the time you sign up. You may withdraw from any of the financial incentives by emailing us at email@example.com. The value of your data is the value of the offer presented to you. We have calculated the value of the incentive by using the expense related to the offer.
14. DO WE MAKE UPDATES TO THIS POLICY?
In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws and update you on any changes to our privacy practices.
15. HOW CAN YOU CONTACT US ABOUT THIS POLICY?
If you have questions or comments about this policy, you may email us at firstname.lastname@example.org or by post to:
110 E 42nd St
New York 10017