Last Updated: 24/04/2018
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, such as:
- Postal address (including billing and shipping addresses)
- Telephone number
- Email address
- IP address
- GPS location through the Neit App
- Credit and debit card number
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Through the Services.
We collect Personal Information through the Services, for example, when you sign up for our newsletter or make a purchase.
- Offline interactions.
As part of our Services, we collect Personal Information from you via offline interactions, for example contact customer service.
- From Other Sources.
We receive your Personal Information from other sources, for example, our collaboration partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.
We don’t collect and ask that you not send us, and you not disclose, any sensitive Personal Information (for example, personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometrics or genetic characteristics, criminal background, data concerning health or data concerning a person’s sex life or sexual orientation, or social security numbers, health) on or through the Services or otherwise to us.
Use of Personal Information
We acquire, hold, use, and Process Personal Information about Individuals for a variety of business purposes, including:
Providing data to better our service.
The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is monitoring and improving our website interface and services.
Providing the functionality of the Services and fulfilling your requests.
Neit may use information about you to fulfill requests for products, Services, or information, including information about potential or future Services, including to:
- Generally manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Support the tracking and recovery of your Neit and/or other products;
- Provide access to certain areas, functionalities, and features of Neit’s Services;
- Allow you to register for events
Administrative Purposes: Neit may use Personal Information about you for its administrative purposes, including to:
- Measure interest in Neit’s Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Communicate about Individual accounts and activities on Neit’s Services and systems, and, in Neit’s discretion, changes to any Neit policy;
- Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
- Process payment for products or services purchased;
- Process applications and transactions;
- Comply with regulatory requirements, including collecting and using information relating to adverse effects you have experienced when using our products;
- Prevent potentially prohibited or illegal activities;
Providing you with our newsletter and/or other marketing materials and facilitating social sharing.
- To send you marketing related emails, with information about our services, new products and other news about our company.
- To facilitate social sharing functionality that you choose to use.
- To provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Neit may provide you with these materials via online social platforms, websites, phone, text/SMS, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or otherwise with your consent.
Analysis of Personal Information for business reporting and providing personalized services.
- To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
- To better understand you, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
- To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.
- We will provide personalized services either with your consent or because we have a legitimate interest.
Allowing you to participate in sweepstakes, contests or other promotions.
- To allow you to participate in sweepstakes, contests and similar promotions and to administer these activities. Some of these activities have additional rules containing additional information about how we use and disclose your Personal Information.
- We use this information to manage our contractual relationship with you.
From time to time, Neit may provide Services that are specifically designed to be compatible and used on mobile devices such as the Neit mobile app. Neit will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings and the operating system of your device. Mobile versions of Neit’s services may require that users log in with an account. In such cases, information about use of mobile versions of the services may be associated with user accounts. In addition, Neit may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may have information such as a GPS tracking to allows you to receive information about the Neit tracking unit.
- Accomplishing our business purposes.
- For audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft.
- For developing new products and services.
- For enhancing, improving, or modifying our current products and services.
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
- We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, and/or because we have a legitimate interest.
Providing your personal data to others
We disclose Personal Information:
- To our third party service providers, to facilitate services they provide to us.
These can include providers of services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services. Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices on https://stripe.com/gb/privacy , https://www.paypal.com/uk/webapps/mpp/ua/privacy-full
- To third parties, to permit them to send you marketing communications, consistent with your choices.
- To third-party sponsors of sweepstakes, contests, and similar promotions.
- By using the Services, you may elect to disclose Personal Information.
- On message boards, chat, profile pages, blogs and other services to which you are able to post information and content (including, without limitation, our Social Media Pages). Please note that any information you post or disclose through these services will become public and may be available to other users and the general public.
Other Uses and Disclosures
We also use and disclose your Personal Information as necessary or appropriate, especially when we have a legal obligation or legitimate interest to do so
- To comply with applicable law.
- This can include laws outside your country of residence.
- To respond to requests from public and government authorities.
- These can include authorities outside your country of residence.
- To cooperate with law enforcement.
- For example, when we respond to law enforcement requests and orders.
- For other legal reasons.
- To enforce our terms and conditions; and
- To protect our rights, privacy, safety or property, and/or that of our affiliates, you or others.
- In connection with a sale or business transaction.
- We have a legitimate interest in disclosing or transferring your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as:
- Browser and device information
- App usage data
- Information collected through cookies, pixel tags and other technologies provided by you that does not reveal your specific identity
- Demographic information and other information provided by you that does not reveal your specific identity
- Information that has been aggregated in a manner such that it no longer reveals your specific identity
- If we are required to treat Other Information as Personal Information under applicable law (e.g. under GDPR), then we use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.
Collection of Other Information
We and our service providers collect Other Information in a variety of ways, including:
- Through your browser or device.
- Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- When you download and use the App, we and our service providers track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Using cookies, pixel tags & analytics
- Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
- Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
- Analytics. We may also use Google Analytics and Google Analytics Demographics and Interest Reporting and other providers to collect information regarding visitor behavior and visitor demographics on some of our Services, and to develop website content. Google Analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Our uses of such Technologies fall into the following general categories:
- Advertising or Targeting Related. We may use first-party or third-party cookies and web beacons to deliver content, including ads relevant to your interests, on our sites or on third party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
- If you would like to opt-out of the Technologies we employ on our sites, services, applications, or tools, you may do so by blocking, deleting, or disabling them as your browser or device permits.
- We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. We may use your device’s physical location to provide you with personalized location-based services and content. We also sometimes share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location, but if you do, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
THIRD PARTY SERVICES
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section below.
CHOICES AND ACCESS
Your choices regarding our use and disclosure of your Personal Information
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving electronic communications from us: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by following the unsubscribe link in any marketing communication.
- Our sharing of your Personal Information with affiliates for their direct marketing purposes: you would prefer that we not share your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt-out of this sharing by contacting us via email@example.com
- Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes: If you would prefer that we not share your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt-out of this sharing by contacting us via firstname.lastname@example.org
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
How you can access, change or delete your Personal Information
If you would like to request to review, correct, update, suppress, restrict or delete Personal Information that you have previously provided to us, or if you would like to request to receive an electronic copy of your Personal Information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact us via email@example.com
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you make a purchase or enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such purchase or promotion). There may also be residual information that will remain within our databases and other records, which will not be removed.
Neit retains the Personal Information we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
USE OF SERVICES BY MINORS
The Services are not directed to individuals under the age of sixteen (16), and we do not knowingly collect Personal Information from individuals under 16, except in those countries where the minimum age is lower.
JURISDICTION AND CROSS-BORDER TRANSFER
Your Personal Information can be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your Personal Information.
If you are located in the European Economic Area (comprised of the EU Member States, Iceland, Liechtenstein, and Norway, together “EEA”): Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries is available at: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm). For transfers from the EEA to countries not considered adequate by the European Commission, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your Personal Information.
THIRD PARTY PAYMENT SERVICE
Because email communications are not always secure, please do not include credit card or other sensitive information in your communication with us.
We give users the opportunity to “opt out” of having their personal information used for purposes not directly related to the operation of the service at the point where we ask for the information. If you prefer to “opt out” and not have us send you material we think may be of interest to you, such as promotional mailings/e-mails from us and sites and companies we own or work with, then you can notify us by writing to us at firstname.lastname@example.org. Your instructions to limit the use of your information will be processed as soon as reasonably practicable.