Revised: November 2023
We collect the following categories and types of “Personal Information”:
We use your Personal Information for the following categories of use:
We collect Personal Information from the following sources:
From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours (“Service Providers”). For example, we may contract with Service Providers to provide certain services, such as performing background checks, hosting and maintenance, data storage and management, and marketing and promotions. We only provide our Service Providers with the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure. Service Providers are prohibited from using Personal Information other than as specified by us.
We may share Personal Information with businesses controlling, controlled by, or under common control with our Company.
Cross Contextual Behavioral Advertising
We may share information with third parties in order to provide cross-contextual behavioral advertising. This may include the following categories of Personal Information: other identifying information, geolocation information, commercial information and internet and other electronic activity.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to government or law enforcement officials or private parties if, in our discretion, we believe it is necessary or appropriate in order to respond to legal requests (including court orders and subpoenas), to protect the safety, property, or rights of our company or of any third party, to prevent or stop any illegal, unethical, or legally actionable activity, or to comply with the law.
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/.
Some browsers or browser extensions also allow you to tell websites not to share your information for cross-contextual behavioral advertising through the “global privacy control” signal. We will respond to this signal in a frictionless manner. If you configure this setting on your browser, certain features on our site may not work and you will receive less targeted advertising.
Options you make are device specific.
Residents of some jurisdictions (e.g., California, Virginia, Colorado) have the ability to opt out of cross-contextual behavioral advertising through other means. Please see the Right to Opt-out of Sale or Sharing section below.
Please be aware that whenever you share information on any public area of the Site or Services, that information may be accessed by others. In addition, please remember that when you share information in any other communications with third parties, that information may be passed along or made public by others. This means that anyone with access to such information can potentially use it for any purpose, including sending unsolicited communications.
We maintain physical, electronic, and procedural safeguards to protect the confidentiality and security of information transmitted to us. However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. As a result, while we strive to protect information transmitted on or through the Site or Services, we cannot and do not guarantee the security of any information you transmit on or through the Site or Services, and you do so at your own risk.
The Site and Services are intended for users who are 13 years old or older. We do not knowingly collect Personal Information from children under the age of 13. If we become aware that we have inadvertently received Personal Information from a child under the age of 13, we will delete such information from our records. California users under the age of 18 may request the removal of their content or information publicly posted on the Site or Services by e-mailing us at email@example.com. Please note that most of the user content that appears on our Site or Services is stored and controlled by third party providers; thus, complete and comprehensive removal of the content may not be possible.
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 some 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.
If you are a resident of California, or jurisdictions with similar laws (e.g., Colorado, Connecticut, Utah, Virginia), you may have certain additional privacy rights under the applicable privacy laws in your state (“State Privacy Laws”). This section generally describes those rights and how you can exercise them.
These rights are not absolute. In some situations we may not be able to process your request. This may include if a legal exception applies. We will let you know when or if a right does not apply to you. You will not be discriminated against for exercising a privacy right. Those rights are:
We will also maintain a record of your rights requests.
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.
To submit a request to know, please send an email to firstname.lastname@example.org. You must provide us with your first name, last name, postal address and email address. To verify your identity, we will match that information to the information we have on our systems. To designate an authorized agent to act on your behalf you must send a signed, written authorization containing your first name, last name, email address, and phone number to: email@example.com.
You can also call us toll free at (888) 632-1967 to submit your request by phone. You must provide us with all of the information set forth above in any such request, including what request you are making.
Residents of certain jurisdictions (e.g., Colorado, Virginia) have the right to opt out of the “sale” or “sharing” of their personal data, as such terms are defined under State Privacy Laws.
Under California law, “share” means disclosing your personal information by us to a third party for cross-context behavioral advertising, in exchange for money or anything else of value. Thus, when we use the term “share” under this section, we are using it in the narrow meaning of how it is defined under California law. Other State Privacy Laws do not use the term “share”, but describe the concept as using personal information for targeted advertising.
The term “sell” has different meaning under certain State Privacy Laws. For example, under the laws of California and Colorado, “sell” means exchanging your personal information by us with a third party for money or anything else of value, while under Virginia law, “sell” is the exchange of personal information for money only.
Currently, we participate in digital advertising networks to deliver advertising that is tailored to your interests. The participation in certain ad networks can constitute a “sale” or “sharing” of personal data under State Privacy Laws. The categories of third parties to whom information may be disclosed in this context is our third party partners (e.g., advertisers and marketing partners and data analytics providers).
We may “sell” and/or “share” the following categories of Personal Information:
Residents of some jurisdictions (e.g., California, Colorado, Virginia) – subject to certain exceptions – may have a right to opt out of forms of automated processing performed on Personal Information to evaluate, analyze or predict personal aspects related to your economic situation, health, personal preferences, interests, reliability, behavior, location or movements (“Profiling”).
We engage in cookie-based or digital advertising-based Profiling. To opt out of this practice, please follow the instructions detailed above regarding opting out of the sale or sharing of your Personal Information.
We also engage in Profiling when we assess your interaction with this Site and our Services for the purpose of providing you information on additional products and services which may be of interest to you. Note, you can opt out of marketing emails as explained in the “Managing Your Marketing Preferences” section above.
We do not otherwise engage in Profiling.
Residents of some jurisdictions (e.g., California) have a right to limit the processing of their Sensitive Personal Information (as defined by the applicable State Privacy Law). We do not collect or process Sensitive Personal Information for inferring characteristics or use or disclose Sensitive Personal Information for purposes other than those permitted by law.
Residents of some jurisdictions (e.g., Virginia, Colorado) have a right to appeal our decision on a privacy rights request. If we were unable to fulfill your request, you may appeal our request by contacting us at firstname.lastname@example.org within fourteen days of our decision, and provide a detailed reason for your appeal, as well as your state of residence.
We offer various financial incentives as permitted by State Privacy Laws. 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 contacting us at email@example.com or by unsubscribing to our email marketing by vising our website. 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.
The data controller for this website is: Neatframe, Ltd.
Our Data Protection Officer can be contacted at firstname.lastname@example.org.
Our UK Representative can be contacted at Cannon Green 27 Bush Ln, London EC4R 0AA, United Kingdom or emailing email@example.com.
Our EU Representative can be contacted at Technopolis Rolfsbuktveien 4 C, 1364 Fornebu, Norway or emailing firstname.lastname@example.org.
We use the Personal 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:
If you are a job applicant or employee, we also use your Personal Information for the following purposes, which are necessary for the performance of the contract between us to evaluate you for or provide you with employment or which we consider in our legitimate interests:
You may have certain rights under the European Union, United Kingdom or Swiss data protection legislation (collectively, “European Privacy Laws”) with respect to your Personal Information, such as the right to:
If you wish to exercise any of your above rights, please reach out to us by: (888) 632-1967
You also have a right to make a complaint to a data protection supervisory authority, in the member state or country where you work, normally live, or where any alleged infringement of data protection laws occurred. The UK supervisory authority is the Information Commissioner’s Office (ICO). You can visit their website at www.ico.org.uk If you are in the EU, you can find your local data protection authority here. If you are in Switzerland, you can find your local data protection authority here.
Regarding the transfer of Personal Information to countries outside the European Economic Area, United Kingdom, or Switzerland, we have entered, or will enter, into so-called “Standard Contractual Clauses” approved by the Commission of the European Union for international transfer or personal information to controllers or processors established in third countries as the case may be, when appropriate. If you would like further information, please contact us at our Data Protection Officer at the information provided above.
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, unless a longer retention period is needed to:
We will not retain your Personal Information for longer than necessary for the purposes set out in this policy.
If you have any questions or concerns regarding this policy, you may contact us at email@example.com.