NEUTON TERMS OF USE

Please note we have updated our Privacy Policy, including new information relating to California Consumer privacy practices and rights, effective January 1, 2020

This Privacy Policy (“Policy”) explains how Bell Integrator Inc., a Delaware corporation and its affiliates and subsidiaries (collectively, "Bell Integrator", “we”, “us” or “our”, as applicable) applies privacy practices to those who visit the web interface (the “Neuton Platform” and together with the software applications developed, hosted and offered through the internet, the “Neuton Service”). For purposes of this Policy, “Personal Data” shall mean any information relating to an identified or identifiable natural person. This might be by reference to an identifier such as a name, ID number, location data or online identifier, or by factors specific to them, such as their physical, genetic, economic or social identity.

This Policy describes how we collect, use, share and secure the Personal Data of the users of Service (the “User(s)” or “you” or “yours”, as applicable). It also describes the User’s choices regarding use, access and correction of the User’s Personal Data. The capitalized terms used in this Policy but not defined herein shall have the same meaning assigned to them in Bell Integrator’s Terms of Use located at: https://neuton.ai/terms-and-conditions (the “Terms”).

By using the Neuton 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 the Neuton 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 Bell Integrator 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.

NOTICE TO USERS: Please note that the EU’s General Data Protection Regulation (GDPR) applies to the User if the User collects Personal Data of the User’s Objects and any of the following two criteria are met: (i) the processing of Personal Data is done in the context of the activities of an establishment of a controller or a processor in the EU, regardless of whether the processing takes place in the EU or not; or (ii) the processing of Personal Data of data subjects who are in the EU by a controller or processor not established in the EU, where the processing activities are related to: (a) the offering of goods or services, irrespective of whether a payment of the data subject is required, to such data subjects in the EU; or (b) the monitoring of their behavior as far as their behavior takes place within the EU. Because Bell Integrator does not collect or determine the use of any Personal Data of User’s Objects, nor the purpose for which such data is collected by the User, how such data is collected and how it is used, Bell Integrator does not act as a data controller as defined under GDPR and bears no responsibility under the GDPR associated with a data controller. To the extent that Bell Integrator processes any User’s Object’s data, it should be considered only as a processor on behalf of the Subscriber as to any Personal Data that is subject to the requirements of GDPR. Please note that under GDPR you are regarded as a data controller vis a vis the User’s Objects and as such must comply with the requirements of GDPR. While you may employ your own privacy policy, you agree and acknowledge that for as long as you use the Neuton Service and are subject to the GDPR, you must comply with the GDPR requirements. Your obligations (which extend to your employees, agents, subcontractors, etc., collectively your “Personnel”) include, but are not limited to (i) promptly (and under no circumstances after seventy two hours) notifying Bell Integrator of becoming aware of any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to, Personal Data transmitted, stored or otherwise processed or any investigation by a governmental authority concerning your handling of Personal Data; (ii) promptly and in good faith responding to any inquiries or requests by Bell Integrator regarding the collection and/or processing of Personal Data by you; (iii) maintaining relevant records of collecting and/or processing of Personal Data subject to GDPR; (iv) transferring or processing the Personal Data outside the EU or European Economic Area in compliance with GDPR and with prior written notification of Bell Integrator; and (v) ensuring that your Personnel is aware of and complies with the foregoing obligations. Bell Integrator is under no circumstances obligated to, but reserves the right to monitor (and audit) the User’s compliance with the foregoing. To the extent that Bell Integrator suffers any losses as a result of the breach by the User of the foregoing obligations or failure to abide by the foregoing obligations, the User shall hold harmless and shall fully indemnify Bell Integrator from such losses. Bell Integrator is not responsible for the content of any Personal Data of User’s Objects or any other information that is stored on Bell Integrator’s or its third party suppliers’ servers at the discretion of the Subscriber. Bell Integrator owes no responsibility and bears no liability in regards to the User’s Objects. If you need a signed Data Processing Agreement in addition to this Policy and the Terms, please contact us at privacy@bellintegrator.com.

International Transfer of Personal Data

Bell Integrator 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 Neuton Service is currently integrated with Google Cloud Platform Marketplace (“GCP Marketplace”) operated by Google. Users log in to Neuton Service through their Google account, and except as set forth in this Policy, we do not collect any registration data or account data for any of our Users. Notwithstanding the foregoing, Bell Integrator may gather the following types of information about you: (1) personally identifiable information that GCP Marketplace makes available to us; (2) personally identifiable information that you voluntarily supplied to us; and (3) aggregate tracking and site usage information that is gathered automatically when you use the Neuton Service. This Policy governs Bell Integrator’s collection and use of your information in connection with the Neuton Service. Your use of any services provided by Google is governed by Google’s Terms of Service (available at: https://cloud.google.com/terms) and Google’s Privacy Policy (available at https://cloud.google.com/security/privacy/) (collectively, “Google Terms”).

It is Bell Integrator’s policy to use the personally identifiable information acquired from you for internal business uses only and to provide content, products and Neuton Service. Bell Integrator operates and maintains a variety of online security measures to safeguard and keep Personal Data private.

A. Information We Received from GCP Marketplace

To use the Neuton Service, you need to have an existing account or set up a new account through GCP Marketplace (an “Account”). When you register for an Account, you will be prompted for registration information, such as your first name, last name, your company name, email address, phone number, account login, and password. This information is submitted directly to Google, and we do not receive any information from GCP Marketplace except your full name and your email address.

B. Information That You Provide to Us

We may collect your personally identifiable information you voluntarily supplied to us. For example, we may ask for your full name, email address and phone number in order to complete your registration of webinars hosted by us.
Bell Integrator 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 Bell Integrator, and under any circumstances, do not provide sensitive information to Bell Integrator, unless you thereby consent to Bell Integrator’s use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in Bell Integrator’s databases. If you have any questions about whether the provision of sensitive information to Bell Integrator is, or may be, necessary or appropriate for particular purposes, please contact us at privacy@bellintegrator.com.

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.

C. Automatic Collection of Personal Information

In some instances, Bell Integrator and its service providers use cookies, web beacons and other technologies to automatically collect certain types of information when you use Neuton Service, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience; improve the performance, usability and effectiveness of Neuton Service; advertise and market our services; measure the effectiveness of our marketing activities; and generate and analyze statistics about your use of Neuton Service.

IP addresses

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

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.

Usage Analytics

We use several third party usage analytics tools including Google Analytics. More information about how Google Analytics is used by Bell Integrator can be found here: http://www.google.com/analytics/learn/privacy.html. To provide website visitors with more choice on how their data is collected by Google Analytics, Google has developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the Online Services or to other web analytics services.

Transactional Data

We use third party payment processors (currently Google) to assist in securely processing your personally identifiable payment information, including recurring charges (if any). The credit card information that you provide is encrypted and transmitted directly to Google. We do not store your credit card information and do not control and are not responsible for Google or its collection or use of your information. You may find out more about how Google stores and uses your credit card information by accessing Google payments privacy practice at: https://policies.google.com/privacy.

How We Use Information That We Collect

A. Permitted Purposes:

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

B. 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 providers. 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 privacy@bellintegrator.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 privacy@bellintegrator.com. 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 privacy@bellintegrator.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 privacy@bellintegrator.com. 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 privacy@bellintegrator.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 privacy@bellintegrator.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.

Data Portability

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 privacy@bellintegrator.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 privacy@bellintegrator.com. 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.

Privacy Notice for California Residents

This Privacy Notice for California Residents (this “CCPA Notice”) supplements the information contained in the Policy and except as provided herein, applies solely to California residents. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this CCPA Notice.

This CCPA Notice does not apply to employment-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. Where noted in this CCPA Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.

A.Information We Collect

The Information Collection and Use section describes the personal information we may have collected from you over the last 12 months, including the categories of sources of that information. We collect this information for the purposes of described in the How We Use the Information that We Collect section. We share this information as described in the How We Share the Information that We Collect section.

B.Your Rights

The CCPA provides California residents with specific rights to request information about our collection, use and disclosure of your personal information over the prior twelve (12) months, and ask that we provide you with the following information:

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information. Once we receive and confirm your verifiable consumer request, we will disclose to you:

We do not provide these access and data portability rights for B2B personal information.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

We do not provide these deletion rights for B2B personal information.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at: privacy@bellintegrator.com. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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.

Changes to our Privacy Policy

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.

Contacting Us

If you have any questions regarding this Policy or information we hold about you, you may contact us at privacy@bellintegrator.com. In order for us to take the appropriate action, please describe in reasonable detail the nature of your request or inquiry.

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