Revised: November 2023
Your information privacy is important to us. We provide this Privacy Policy to explain how we collect, use, protect, and disclose information and data when you use the neat.no website (“Site”) and any Neat mobile application, application programming interfaces, Neat devices and other related products and services offered by Neat, and any other time you interact with our Company. (collectively, the “Services”). This Privacy Policy also explains your choices for managing your information preferences, including opting out of certain uses of your Personal Information (defined below). This Privacy Policy applies to all users of the Site and Services. The Site and Services are provided by Neatframe Ltd. (“Company,” “Neat” “we” “our” “us”).
BY USING THE SITE OR SERVICES, YOU ARE CONSENTING TO THIS PRIVACY POLICY. PLEASE READ IT CAREFULLY.
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:
Service Providers
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.
Our Affiliates
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.
Third Parties
We may share Personal Information with a third party if you specifically authorize it, or it is required in order to complete a transaction, service or activity that you initiated or requested. Note: In such case, the collection and processing of your Personal Information may be subject to the privacy policy of such third party.
Corporate Transactions
If our Company is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information in connection with such transaction. You will have the opportunity to opt out of any such transfer if, in our discretion, it will result in the handling of your Personal Information in a way that differs materially from this Privacy Policy.
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 cookies (a small text file placed on your computer to identify your computer and web browser) and may use anonymous identifiers (a random string of characters that is used for the same purposes as a cookie). We use cookies and other similar technologies to analyze use of and improve the Site and Services and as described in the Advertising and Online Tracking Section of this Privacy Policy. Most web browsers are initially set up to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent, however, certain features of the Site or Services may not work if you delete or disable cookies. Some of our Service Providers (defined below) may use their own cookies, anonymous identifiers, or other tracking technology in connection with the services they perform on our behalf.
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/.
We may allow third-party companies to serve ads and collect certain information when you visit the Site and Services. These companies may use certain information (e.g. click stream information, web browser type, time and date, subject of advertisements clicked or scrolled over) during your visits to the Site and other websites in order to provide advertisements about goods and services likely to be of interest to you. These companies typically use a cookie to collect this information. Our systems do not recognize browser “Do Not Track” signals, but several of our Service Providers who utilize these cookies on our Site enable you to opt out of targeted advertising practices. To learn more about these advertising practices or to opt out of this type of advertising, you can visit www.networkadvertising.org or www.aboutads.info/choices/. We also provide you with additional tools to opt out of marketing from us. You can learn about this in the “Managing Your Information Preferences” section of this Privacy Policy.
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.
You can review, correct, update, or change your Personal Information or opt out of receiving certain e-mails by changing the relevant settings in your account or by e-mailing us at support@neat.no. 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. If you have questions or concerns regarding this Privacy Policy, please e-mail us at that same address.
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.
Our Site and Services may contain links to other websites or allow others to send you such links. A link to a third party’s website does not mean that we endorse it or that we are affiliated with it. We do not exercise control over third-party websites. You access such third-party websites or content at your own risk. You should always read the privacy policy of a third-party website before providing any information to the website.
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 neat.privacy@neat.no. 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 neat.privacy@neat.no. 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: neat.privacy@neat.no.
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 neat.privacy@neat.no 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 neat.privacy@neat.no 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 neat.privacy@neat.no.
Our UK Representative can be contacted at Cannon Green 27 Bush Ln, London EC4R 0AA, United Kingdom or emailing neat.privacy@neat.no.
Our EU Representative can be contacted at Technopolis Rolfsbuktveien 4 C, 1364 Fornebu, Norway or emailing neat.privacy@neat.no.
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.
We may change this Privacy Policy from time to time. If we decide to change this Privacy Policy, we will inform you by posting the revised Privacy Policy on the Site. Those changes will go into effect on the “Revised” date shown in the revised Privacy Policy. By continuing to use the Site or Services, you are consenting to the revised Privacy Policy. If you are an employee, we will notify you of material changes to this Privacy Policy.
If you have any questions or concerns regarding this policy, you may contact us at neat.privacy@neat.no.
Please print a copy of this privacy policy for your records and please check the Site frequently for any changes.
