Neatframe Limited Privacy Notice

Effective: July 13, 2026

This Privacy Notice describes how Neatframe Limited (“Neat,” “we,” “us,” or “our”) collects, uses, and discloses information from or about you through our websites, including www.neat.no (our “Websites”), products or services we provide through the Websites, Neat devices, and any related interactions (e.g., customer service inquiries, etc.) you may have with us (collectively, the “Services”). 

This Privacy Notice does not apply to you as an employee or applicant for employment with Neat, or your use of our recruitment website(s).  You will be provided with a separate privacy notice if you apply for a job or act as a Neat employee.

Please note that when Neat collects and processes data about end users of our customers (“Customer End Users”) on behalf of such customers (“Customer Data”), in connection with the services we provide to customers pursuant to our agreements with such customers (each an “Agreement”), the customer is the “data controller” and Neat is a “data processor.”  In such circumstances, Neat processes Customer Data under the instructions of the relevant customer, as described in the applicable Agreement, and in accordance with Neat’s Data Protection Addendum (“DPA”).  Neat's obligations with respect to Customer Data are defined in the DPA, and in the event of a conflict between the DPA and this Notice, the DPA controls.  If you are a Customer End User and you have questions about how Customer Data is collected and processed through the services we provide to the customer, please contact the customer for more information. 

PLEASE READ THIS PRIVACY NOTICE CAREFULLY TO UNDERSTAND HOW WE HANDLE YOUR INFORMATION. By using or accessing our Services, you agree that we may handle your information as set forth in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use the Services.

This Privacy Notice contains the following sections:

1. Neat Pulse Services
2. Information We Collect
3. How We Use Your Information
4. How We Disclose Your Information
5. Online Analytics and Advertising
6. Your Rights and Choices
7. Security and Retention
8. International Transfers of Your Information
9. Links to Third Party Sites
10. Children’s Privacy
11. Notice to California Residents
12. Changes to This Policy
13. Contact Us

1. Neat Pulse Services

If your organization uses the Neat Pulse services and makes them available to you as a user, we collect the following information about you in this capacity: full name, country/region, email address, authentication data, IP address and general location data, e.g., country or region (to identify you as our service user and to maintain communication with you), information about your preferences and feedback regarding Neat Pulse, images captured by Neat Pulse for purposes of troubleshooting and diagnostics, and information related to your interaction with the Neat Pulse services (including your chats within the chat feature, your voice for voice-to-text transcription purposes, and the resulting transcriptions). 

For purposes of certain data protection laws, and as explained more fully above, your organization is the “controller” of this information and we are a “processor.” How we collect, use, disclose, and retain such information is determined by our agreement with your organization, so please contact your organization for more information on how this information is processed or to exercise any rights you may have regarding such information. If you contact us with questions or to exercise your rights using the contact information at the end of this document, we may provide your question or request to your organization for resolution.

2. Information We Collect About You

Sources of Information. We may collect information about you:

• Directly from you, such as when you use our Websites, book a demo, register for a seminar or webinar, create an account, subscribe to our Services, search for a product on the Website, place an order, communicate with us in any way (e.g., by phone, email, or chatbot), or otherwise use the Services or interact with us;
• By automated means, such as through our devices and via cookies, pixels, and other similar technologies; and
• From other sources, such as our corporate affiliates, our business partners (e.g., when you purchase a product through our distribution network), our vendors and service providers, from websites that employ our cookies, other third parties (such as data providers or aggregators, credit reference agencies, social media platforms), and publicly available sources.

Information We Collect From You or Other Sources. The types of information we collect about you depends on how you use the Services, the nature of our relationship with you, and certain other factors. This information may include:

• Identifiers, such as first and last name, email address, postal address, or phone number.
• Login credentials (username and password) and user role, such as if you are an administrator of your organization’s account.
• Professional information, such as company or organization name and business contact information, such as job title and business email, postal address, and phone number.
• Commercial information, such as a record of transactions with us and our products or services you have purchased from us or from a third-party seller.
• Payment information, such as billing and shipping address, payment information, and (if you apply for business credit) business credit verification information. Please note that our third-party payment processors, and not Neat, collect your full payment information.
• General location information, such a country or region.
• Social media information, such as social media name or ID and reposts of our content.
• Audio and/or visual information, such as recordings of meetings and customer service calls, subject to applicable laws.
• Any other information you choose to directly provide to us in connection with your use of the Services. 

You are not required to provide any information to us. However, if you choose not to provide certain information, we may not be able to provide the Services to you or respond to your other requests.

Information We Collect Automatically. When you use our Services, we and our vendors automatically collect certain information about your device, browser, and use of the Services, such as your IP address, browser type and version, time zone setting, browser plug-in types and versions, software version, operating system and platform, URLs of Website pages you visit, products viewed or searched for, page response times, length of visits to pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from the page, the date and time you used the Services, error logs, and other similar information (collectively, “online and device information”).

We and our vendors may collect this information using cookies and other similar technologies. Cookies are small data files that can be stored on your browser or device. We use cookies for a variety of purposes, including to recognize you when you return to the Services, to deliver certain features of the Services, to help us understand and analyze how you use the Services, to improve your experience, for advertising purposes, and to track, measure, and analyze the behaviors and usage patterns on our Services. You may set your web browser to notify you when a cookie is set and to accept or refuse certain cookies. However, if you choose not to accept cookies, the Services may not function as intended and some features may be unavailable. For more information about managing cookies, please follow the instructions from your browser, or if accessing the Services via a mobile device, please see the manufacturer’s instructions.

For more details, please see the “Online Analytics and Advertising” section below or review our Cookie Policy.

3. How We Use Your Information

We may use your information for various purposes, depending on the context and the type of information, including to:

• Provide, operate, maintain, and administer the Services;  
• Process orders, subscriptions, and registrations, and deliver products and services you request;
• Communicate with you about the Services, including to provide customer service and respond to your inquiries;  
• Communicate with you about updates, information, promotions, or other information that may be of interest to you regarding our Services or other services (subject to any preferences you have expressed to us regarding such communications);
• Operate our business, including to manage our relationships with business partners and conduct business planning;
• Personalize the Services, such as by remembering your login information and preferences;
• Analyze and research use of the Services, improve our Services, and develop new products and services;
• For marketing and advertising purposes, including to personalize the content and advertising you see on the Services and elsewhere, send promotional content such as newsletters and special offers, and measure the effectiveness of our marketing and advertising;
• Conduct surveys, sweepstakes, and contests;
• Secure the Services, address technical issues, and prevent fraud;
• Comply with applicable laws, rules, and regulations, obtain legal counsel, and establish, exercise, or defend our legal or contractual rights (including by enforcing our terms and this Privacy Notice);
• Protect Neatframe and our agents, affiliates, Services, employees, customers, and others; and
• For any purpose with your consent or at your direction.

Aggregate and De-Identified Information. We may aggregate and/or de-identify any information collected through our Services so that such information can no longer be linked to you or your device. We may use such information for any purpose, including without limitation for research and marketing purposes, and may disclose such information to any third parties.    

Combined Information. We may combine the information we collect through the Services with information we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Notice.  

Legal Bases. In applicable jurisdictions, we use your information as set forth in this Privacy Notice based on the following legal bases, as relevant given the type of information and the context and purpose for using it.

• As needed to perform the contract we are about to enter into or have entered into with you for the Services (e.g., if you place an order or subscribe to our Services). For example, we process your information on this basis to facilitate a transaction when you make a purchase; to manage our install base (e.g., provide updates to the Services) when you use or interact with our devices; for device management and remote administration purposes when you subscribe to the Neat Pulse service; and when we are involved in a sale of our Services through one of our business partners.

• As needed for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. For example, we process your information on this basis to provide and improve the Services, for marketing and advertising, for security and fraud prevention, and for any other purpose when we have a legitimate interest. This includes when we collect information from our affiliates, automatically when you use our Website, and from third parties or publicly available sources.

• As needed to comply with a legal or regulatory obligation. We may collect any of the information listed above under this basis, use it for the purpose of complying with applicable laws or regulations, and disclose it as required by such laws or regulations, including to any of the types of parties listed below.

• Where we have your consent to process your information. For example, we process your information on this basis (consistent with your consent) when you opt in to receive marketing from us or consent for us to use and disclose your information in other ways as specified in the request for consent.

4. How We Disclose Your Information

We may disclose your information to the following categories of recipients:

• Affiliates and subsidiaries. We may disclose the information we collect within the Neatframe family of companies.
• Vendors and advisors. We may disclose your information to third-party vendors that perform services on our behalf, which may include mailing or email distribution, payment processing, shipping, data enhancement, data storage, security, fraud prevention, web hosting, analytics, legal, or consulting services.
• Advertising and related analytics providers. We may allow third-party advertising technologies (e.g., ad networks and ad servers) and related analytics providers to use cookies and similar technologies on the Services to deliver relevant, tailored content and advertising to you on other websites you visit and applications you use, as explained further in “Online Analytics and Advertising” below.
• Business partners. We may disclose your information to business partners such as distributors, resellers, and integration partners to facilitate your purchases, provide joint services, or offer complementary products or services. 
• Third parties in connection with a business transaction. We may disclose your information to third parties in connection with a business transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, including for the purpose of determining whether to proceed or continue with such transaction or business relationship.
• Third parties for legal reasons. We may disclose your information to third parties as required by law or if we believe in good faith that the disclosure is necessary to (i) comply with the law and legal process such as subpoenas, warrants, or court orders; (ii) exercise or defend our legal rights and enforce our agreements, including terms applicable to the Services; or (iii) protect the rights, property, or personal safety of Neatframe or our agents, affiliates, Services, employees, customers, and others.
• Otherwise with your consent or at your direction. We may disclose your information to third parties if you consent to or direct such disclosures.

5. Online Analytics and Advertising

Online Analytics. We may use third-party web analytics tools on our Services for various purposes, including to collect and analyze usage information through cookies and other similar technologies, assist with fraud prevention, provide certain features to you, and engage in auditing, research, or reporting. One such service we may use is Google Analytics. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. If you receive emails from us, we may use certain analytics tools, such as clear GIFs, in those emails to collect data that helps us analyze the effectiveness of our communications and marketing campaigns, such as data about when you open the email or whether you click on any links in the email.

Tailored Online Advertising. When you use the Services, we may allow certain third-party advertising technology partners (e.g., ad networks and ad servers such as Google) to place cookies or other tracking technologies on your browser or device to collect information about you as discussed above. These third-party partners may use this information to serve relevant content and advertising to you across the Internet, and they may access their own cookies or other tracking technologies on your browser or device to assist in this activity. To learn more about these online advertising activities and how you can generally control cookies from being put on your browser or device to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices. These websites also allow you to opt out of receiving tailored advertising from companies that participate in these programs. We do not control and make no representations about these websites, their opt-out mechanisms, or whether any of our advertising partners participate in these opt-out mechanisms. We are not responsible for and make no representations about the accuracy or continued availability of these opt-out mechanisms.

Please note that if you opt out of tailored advertising, you may still see advertising on our Services or across the Internet, but it will not be tailored to you based on your online behavior over time.

6. Your Rights and Choices

Marketing Communications. Subject to applicable law and any preferences you have expressed to us, we may send you marketing communications regarding our Services or third-party services that we believe will be of interest to you. You can opt out of receiving future communications using the opt-out instructions provided in such communications or by contacting us as set forth in the “Contact Us” section below. Please note that even if you opt out of marketing communications, we may still send you non-marketing communications, such as emails about updates to this Privacy Notice, confirming your requests, or notifying you of security issues with your account. We may also use and disclose certain information as required by applicable law.

Rights Regarding Your Information. Depending on your jurisdiction, you may have certain rights under applicable data protection laws regarding your “personal information” or “personal data” (as such terms are defined under applicable law; collectively referred to in this section as “personal information”). If you are a resident of the European Economic Area; the United Kingdom; the U.S. states of California, Colorado, Connecticut, Oregon, Virginia, or other U.S. states with similar privacy laws; or another jurisdiction providing such rights, you have the right to ask us to:

• Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such personal information; the business or commercial purpose for collecting such personal information; and the categories of third parties to which we disclose such personal information;
• Provide you access to and/or a copy of certain personal information we hold about you;
• Provide you with a copy of your personal information in a structured, commonly used, machine-readable format, where technically feasible;
• Correct or update personal information we hold about you;
• Delete certain personal information we have about you;
• Restrict or object to certain uses of your information; or
• Opt you out of the processing of your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects (note that we do not engage in such processing). 
• Withdraw consent (if our processing of your personal information is based on your consent).

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information to provide the Services to you, fulfill your requests, or comply with applicable law, and if you ask us to delete such information, we may deny your request. We may take reasonable steps to verify your identity before responding to a request, which may include, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address (at a minimum). If we cannot verify your identity, we may be unable to respond to your requests.  As provided in applicable law, you have the right to not be discriminated against for exercising your rights regarding your personal information. 

To exercise these rights, you may email us at neat.privacy@neat.no. Please specify the right you want to exercise and the information with respect to which you want to exercise this right. You may be able to designate an authorized agent to make requests on your behalf. So that we can verify an authorized agent, you must provide the authorized agent with a power of attorney or a signed, written permission to make such requests. We may follow up with you to verify your identity before responding to the authorized agent’s request, as permitted by applicable law. You may also be able to exercise certain rights through your account with us – for example, you may be able to update your contact details and communication preferences. 

If we deny your request, you may appeal this decision if you reside in certain locations. We will provide information about how to make an appeal in our response denying the request if you are located in one of these jurisdictions. 

You also have the right to lodge a complaint with the supervisory authority in your jurisdiction. However, we encourage you to contact us first with any concerns or complaints so we can do our best to resolve them.

If you are a Customer End User and your information has been collected by us as a result of a customer’s use of the Services pursuant to an Agreement between us and the customer, we collect and process this information under the instructions of the relevant customer, which is the data controller, and our DPA. If these circumstances apply to you and you wish to access, edit, or delete your information, or exercise any rights you may have under applicable data protection laws with respect to any information that we have collected about you on behalf of a customer, please direct your query to the relevant customer, as this may expedite the completion of your request. We nevertheless provide reasonable assistance to our customers to give effect to your request to exercise your rights, as appropriate and required by applicable laws. 

Notice of Right to Opt Out of Sales of Personal Information and Processing/Sharing of Personal Information for Targeted Advertising Purposes. 

If you reside in the United States, you also have the right to opt out of “sales” of your personal information and “sharing” or processing of your personal information for “targeted advertising” purposes, as such terms are defined in applicable data protection laws.

As explained in the “Disclosure of Your Information” section above, we may provide personal information to third-party advertising and related analytics providers for targeted advertising and related analytics purposes. Under applicable law, these disclosures to these parties for these purposes may be considered a “sale” of personal information or “sharing” or processing personal information for “targeted advertising” purposes.

To opt out of the disclosure of your personal information to such third parties through cookies and similar tools for purposes that could be considered “sales” or “sharing” or processing for purposes of targeted advertising, you may visit the third party opt-out links in the “Online Analytics and Advertising” section above. Please note that you must complete this opt-out on each browser or device you use to access the Services.

7. Security and Retention

We implement various technical, organizational, and physical measures to protect your information against accidental or unlawful access, destruction, loss, misuse, change or damage. These measures include, for example, network security tools, access controls, incident response processes, and security policies and procedures. However, no electronic transmission of information is fully secure or error-free. You disclose your information to us at your own risk; please use discretion.

We retain your information for as long as necessary to fulfil the purposes for which we collect or use it, including for the purposes of our legitimate business interests and as required by applicable laws and regulations. Specific retention periods may vary depending on the nature of the personal information, the purpose of processing, and the applicable legal jurisdiction. Our data retention policies take into account various factors, including legal requirements, contractual obligations, and our business purposes.

8. International Transfers of Your Information

The information we collect may be transferred to and stored in countries where we and our vendors have operations, including the United States. The data protection laws in these countries may differ from those in your country of residence, and information may be accessible to law enforcement and national security authorities under certain circumstances. Where legally required, we implement data transfer mechanisms such as, without limitation, Standard Contractual Clauses for transfer of data from the EEA or UK. By using the Services, you acknowledge that these transfers will occur. To understand your rights with regard to your information, please visit the website of the appropriate data protection authority for your region.  

9. Links to Third Party Sites

Our Services may contain links to third party websites, features, and other services that we do not own or operate (collectively, “Third-Party Services”). These links are provided for your convenience only. We do not control, endorse, or make any representations about any third parties. Further, we are not responsible for the practices of any third parties, and disclaim any liability for any loss, damage, or harm resulting from your interaction with or reliance on Third-Party Services. If you click a third-party link, the third party’s privacy notice and terms apply to your use of the Third-Party Services. We encourage you to read these materials before providing your information to a third party.

10. Children’s Privacy

Our Services are not directed to persons under the age of 18. To create an account, make a purchase, or interact with certain features of our Services, you must be at least the legal age of consent in your country or jurisdiction. By using our Services, you represent and warrant that you meet the minimum age requirements and have the legal capacity to enter into a binding agreement.

We do not knowingly collect personally identifiable information from children under 18. If we become aware that an individual under 18 has provided us with their personally identifiable information, we will take steps to delete this information if required by and in accordance with applicable law.

11. Notice to California Residents

If you are a California resident, California law requires us to provide you with some additional information about how we collect, use, and disclose your “personal information,” as defined in the California Consumer Privacy Act (“CCPA”).

This Privacy Notice discusses in detail the categories of personal information we collect and how we use and disclose such information. We provide additional information required by the CCPA in the chart below.

Opt Out of Sale/Sharing of Personal Information. The CCPA sets forth certain obligations for businesses that “sell” personal information or “share” personal information for “cross-context behavioral advertising” purposes. Under the CCPA, “sale” and “sharing” are defined such that they may include allowing third parties to receive certain information for advertising and related analytics purposes. To opt out of these activities, you may visit the third party opt-out links in the “Online Analytics and Advertising” section above. Please note that you must complete this opt-out on each browser or device you use to access the Services. We do not knowingly sell the personal information of minors under 16 years of age.

Additional California Privacy Rights. California residents may make certain requests about their personal information under the CCPA as set forth in “Your Rights and Choices” section above. In addition:

• If we ever offer financial incentives in exchange for your personal information, we will provide you with appropriate notice of such incentives.
• In the limited circumstances that we process sensitive personal information as defined in the CCPA (e.g., log-in information), we do not use or disclose it other than for disclosed and permitted business purposes for which there is not a right to limit under the CCPA.

“Shine the Light” Disclosure. California Law permits customers who are California residents to request certain information once per year regarding our disclosure of “personal information” (as that term is defined under applicable California law) to third parties for such third parties’ direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes without your consent.

Do Not Track. Do Not Track (“DNT”) is a signal that you can set on certain browsers. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

12. Changes to this Privacy Notice

We reserve the right to update this Privacy Notice at any time. We will make the updated Privacy Notice accessible on the Services and update the “Last Updated” date at the top of the Privacy Notice. Please review the Privacy Notice from time to time for changes. If we make a material change to the Privacy Notice, we will notify you in accordance with legal requirements. By continuing to use the Services after we update the Privacy Notice, you confirm that you have read, understood, and agree to the updated Privacy Notice.

13. Contact Us

You may contact us if you have questions about this Privacy Notice or our practices, or to exercise your statutory rights regarding your information. You may contact our Privacy Office at neat.privacy@neat.no. You can also reach us by mail at Neatframe Limited, 24 Cornhill, London, England, EC3V 3ND, or call us at +1 (888) 632-1967.