Last modified: July 21, 2018
By using our Service, you express your unconditional agreement with this Policy and the conditions of processing the personal data contained herein. If you do not accept this Policy, do not use our Service or provide any personal information to us.
NOTICE TO USERS’ OBJECTS: If you use the Neuton Service to interact with other individuals, such as your customers or potential customers (the “User’s Objects”), you are solely responsible for ensuring compliance with all applicable laws in connection with the collection and/or processing of personal data of the User’s Objects. If you are a User’s Object please note that the Company has no relationship with you whatsoever and its only relation is with the Subscriber with whom you may interact. For any questions regarding the collection of your personal data or to amend your personal data, and for all other reasons, you must contact the Subscriber.
International Transfer of Personal Data
The Company is a global company, based in the United States. As such, we may transfer and access such Personal Data from around the world, including from other countries. In transferring your Personal Data, we will rely on lawful measures to transfer your Personal Data outside the EEA and Switzerland. If you are visiting the Neuton Service from the EEA or other regions with laws governing data collection and use, please note that by providing this Personal Data, you acknowledge that your Personal Data may be transferred to the United States and other jurisdictions in which we operate.
Information Collection and Use
The Company gathers two types of information: (1) personally identifiable information that is supplied voluntarily upon registration for Neuton Service, ordering products from Neuton website/Service, submitting data through the Neuton Service, or when you enter certain other areas of the Company’s websites and (2) aggregate tracking and site usage information that is gathered automatically when you use the Neuton Service. It is Company’s policy to use the personally identifiable information acquired at Company’s websites for internal business uses only and to provide content, products and Neuton Service. The Company operates and maintains a variety of online security measures to safeguard and keep personal data private.
Information That You Provide to Us
When you register for an account to access or utilize Neuton Service (an “Account”), we ask for and may collect personal information about you such as your name or your company, address, phone number, email address, credit card or other payment method information (collectively, an “Account Information”). By providing us with Account Information, you represent that you are the owner of such personal data or otherwise have the requisite consent to provide it to us.
The Company only collects "sensitive" personal information when you voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person's race, ethnicity, political, philosophical religious or similar beliefs, trade union membership, physical or mental health, sexual life, sexual orientation, or criminal record. Please use your discretion when providing sensitive information to the Company, and under any circumstances, do not provide sensitive information to the Company, unless you thereby consent to the Company’s use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in the Company’s databases. If you have any questions about whether the provision of sensitive information to the Company is, or may be, necessary or appropriate for particular purposes, please contact us at firstname.lastname@example.org.
Data Submitted by You
We may also use the materials you submit through the Neuton Service, such as data, to improve the Neuton Service, including its algorithms. All such data is anonymized. We shall not use such data for any other purpose, including for purposes of advertising.
Third Party Services
Automatic Collection of Personal Information
An IP address is a number assigned to your computer or internet-enabled device whenever you access the internet. It allows computers and servers to recognize and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to maintain and improve Neuton Service and to generate and analyze statistics about Neuton Service and your use of Neuton Service.
Cookies are text files put on your computer to collect standard internet log information and visitor behavior information. This information is then used to track visitor use of the website and to create statistical reports on website activity. The detailed description of cookies used on our site can be found here: neuton.ai/cookies.
You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. Please note in a few cases some Neuton Service features may not function because of this.
BY ACCESSING OR USING NEUTON SERVICE, YOU AGREE THAT WE, OR A THIRD PARTY ACTING ON OUR BEHALF, CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. We only uses web beacons in accordance with applicable laws.
How We Use Information That We Collect
We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote Neuton Service; (b) enable you to access and use Neuton Service; (c) process and complete transactions; (d) provide customer service and support and send you related notices; (e) send promotional communications; (f) process and deliver contest or sweepstakes entries and rewards; (g) monitor and analyze trends, usage, and activities in connection with Neuton Service and for marketing or advertising purposes; (h) monitor and assess compliance with our policies and standards; and (i) for other purposes for which we obtain your consent. With regard to newsletters, updates and other general communications, we will - where legally required – only provide you with such information if you have opted in. You have the opportunity to opt out of receiving such communications at any time
Legal Basis for Processing (EEA only)
If you are an individual from the European Economic Area (EEA), we use your personal data, we may process your personal data on one or more of the following legal grounds: (i) because processing is necessary to perform a contract with you, such as to deliver Neuton Service; (ii) to comply with our legal obligations; (iii) because processing is necessary for purposes of our legitimate interest or those of any third party recipients that receive your personal data, provided that such interests are not overridden by your interests or fundamental rights and freedoms. We may also process your data based on your consent where you have expressly given that to us.
How We Share the Information That We Collect
We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of Neuton Service. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.
We may share your personal data with courts, law enforcement authorities, regulators or attorneys or other parties where it is reasonably necessary for the establishment, exercise or defense of a legal or equitable claim, or for the purposes of a confidential alternative dispute resolution process. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our terms and conditions, or as otherwise required by law.
We may share your personal data with any third party to whom we assign or novate any of our rights or obligations, or that acquires all or substantially all of our business, stock or assets, or with whom we merge.
We may also instruct service providers, to process personal data for the Permitted Purposes on our
behalf and in accordance with our instructions only. We will retain control over and will remain
fully responsible for your personal data and will use appropriate safeguards as required by
applicable law to ensure the integrity and security of your personal data when engaging such service
We may also use aggregated personal data and statistics for the purpose of monitoring website usage in order to help us develop our website and our services.
We will otherwise only disclose your personal data when you direct us or give us permission to do so, when we are required by applicable law or regulations or judicial or official request to do so, or as required to investigate actual or suspected fraudulent or criminal activities.
Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our (or a third party’s) legitimate interests which are not already described in this Notice, we will make clear to you at the relevant time what those legitimate interests are.
If you have any questions about or need further information concerning the legal basis, on which we collect and use your personal information, please contact us at email@example.com.
How Long We Retain Your Personal Information
We will retain your personal information for as long as is needed to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). 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. For personal information that we process on behalf of our Subscribers, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.
Your Privacy Rights Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at firstname.lastname@example.org. Subscribers may update or change their Account Information by editing their profile within Neuton Service. To make a request to have personal information maintained by us returned to you or removed, please email email@example.com. Requests to access, change, or remove your information will be handled within thirty (30) days; provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for Neuton Service, or as needed to provide you with Neuton Service, comply with our legal obligations, resolve disputes and enforce our agreements.
Additional Rights for EEA and Certain Other Territories
If you are from certain territories (such as the EEA), you may have the right to exercise additional rights available to you under applicable laws, as follows:
What is a Subject Access Request?
This is your right to request a copy of the information that we hold about you. If you would like a copy of some or all your personal information, please contact us at firstname.lastname@example.org. We will respond to your request within thirty (30) days of receipt of the request. We want to make sure your personal information is accurate and up to date. You may ask us to correct or remove information you think is inaccurate by email@example.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request
Objections to Processing of Personal Data
It is your right to lodge an objection to the processing of your personal data if you feel the “ground relating to your particular situation” apply. The only reasons we will be able to deny your request is if we can show compelling legitimate grounds for the processing, which override your interest, rights and freedoms, or the processing is for the establishment, exercise or defense of a legal claims. To invoke this right, please contact us at firstname.lastname@example.org. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
It is also your right to receive the personal data which you have given to us, in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller without delay from the current controller if:
(a) The processing is based on consent or on a contract, and
(b) The processing is carried out by automated means. To invoke this right, please contact us at email@example.com. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.
Your Right to be Forgotten
Should you wish for us to completely delete all information that we hold about you for, contact us at firstname.lastname@example.org. Please note, however, that we may need to retain certain information for record keeping purposes, to complete transactions or to comply with our legal obligations.
You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. If you feel that your personal data has been processed in a way that does not meet the GDPR, you have a specific right to lodge a complaint with the relevant supervisory authority. The supervisory authority will then tell you of the progress and outcome of your complaint.
California Privacy Rights
We will not share any Personal Data with third-parties for their direct marketing purposes to the extent prohibited by California law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance.
Policy Regarding Children
Neuton Service is not directed to children under the age of thirteen and we do not knowingly collect personally identifiable information from children under the age of thirteen as part of Neuton Service. If we become aware that we have inadvertently received personally identifiable information from a User under the age of thirteen as part of Neuton Service, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of Neuton Service.
If we change the Policy, we will post the revised Policy here with an updated revision date. Please check frequently the Site to see if the Policy is changed. If we make significant changes to our statement, we also may, but are not obliged to, notify all members whose Personal Data we have retained by means such as sending an email or posting a notice on our Site. Your continued use of Neuton Service constitutes your acceptance of all such changes and amendments. Your sole remedy is to cease using Neuton Service.
If you have any questions regarding this Policy or information we hold about you, you may contact us at email@example.com. In order for us to take the appropriate action, please describe in reasonable detail the nature of your request or inquiry.