- INTRODUCE
This privacy notice for Neobridge (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you visit our website at https://www.neobridge.io, or any subdomain or website of ours that links to this privacy notice Download and use our application(s), such as our future mobile application "Nebridge", or any other application of ours that links to this privacy notice engage with us in other related ways including any sales, marketing, or events.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us.
- SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by using our table of contents below to find the section you are looking for. What personal information do we process?
When you visit, use, or navigate our services, we may process personal information depending on how you interact with Neobridge and the services, the choices you make, and the products and features you use. Do we process any sensitive personal information? We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law.
Do you receive any information from third parties? We may receive information from public databases, marketing partners, social media platforms, and other outside sources. How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, prevent money-maundering, and to comply with law. We may also process your information for other purposes with your consent.
We process your information only when we have a valid legal reason to do so. In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. How do I exercise my rights? The easiest way to exercise your rights is by contacting us by email at contact@neobridge.io.
We will consider and act upon any request in accordance with applicable data protection laws.
- TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
8. HOW LONG DO WE KEEP YOUR INFORMATION?
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
10. DO WE COLLECT INFORMATION FROM MINORS?
11. WHAT ARE YOUR PRIVACY RIGHTS?
12. CONTROLS FOR DO-NOT-TRACK FEATURES
13. DO WE MAKE UPDATES TO THIS NOTICE?
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal information provided by you the personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use.
The personal information we collect may include the following: IP Address Name Surname Date of birth Personal ID Country of birth Citizenship Residence country Adverse media Political exposure Financial data and source of funds Application Data. If you use our application(s), we also may collect the following information for security reasons: Geolocation Information.
We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services.
If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Access.
We may request access or permission to certain features from your mobile device, including your mobile device’s bluetooth, calendar, camera, own, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.
Mobile Device Data.
We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.
Push Notifications.
We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings. This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information. Information automatically collectedIn Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.
This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes. Like many businesses, we also collect information through cookies and similar technologies.
You can find out more about this in our Cookie Notice The information we collect includes: Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
Device Data.
We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
Location Data.
We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
Information collected from other sources.
In Short: We may collect limited data from public databases, marketing partners, social media platforms, and other outside sources.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media platforms, and from other third parties. Any personal information that we collect from your social media account depends on your social media account’s privacy settings.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including: To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
To prevent money laundering To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information. To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user. To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services. To send you marketing and promotional communications.
We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information see our Cookie Notice: [Cookie Notice URL]. To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention. To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you. To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests. If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information: Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose.
You can withdraw your consent at any time. Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.Legitimate Interests.
We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to: Send users information about special offers and discounts on our products and servicesDevelop and display personalized and relevant advertising content for our usersAnalyze how our services are used so we can improve them to engage and retain usersSupport our marketing activitiesDiagnose problems and/or prevent fraudulent activitiesUnderstand how our users use our products and services so we can improve user experience.
Legal Obligations.
We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved. Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person. In legal terms, we are generally the “data controller” under European data protection laws of the personal information described in this privacy notice, since we determine the means and/or purposes of the data processing we perform. This privacy notice does not apply to the personal information we process as a “data processor” on behalf of our customers. In those situations, the customer that we provide services to and with whom we have entered into a data processing agreement is the “data controller” responsible for your personal information, and we merely process your information on their behalf in accordance with your instructions. If you want to know more about our customers’ privacy practices, you should read their privacy policies and direct any questions you have to them.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: If collection is clearly in the interests of an individual and consent cannot be obtained in a timely wayFor investigations and fraud detection and prevention
For business transactions provided certain conditions are metIf it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claimFor identifying injured, ill, or deceased persons and communicating with next of kinIf we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuseIf it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records. If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was producedIf the collection is solely for journalistic, artistic, or literary purposesIf the information is publicly available and is specified by the regulations.
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: Wemay share information in specific situations described in this section and/orwith the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors,service providers, contractors, or agents (“third parties”) who performservices for us or on our behalf and require access to such information to dothat work. We have contracts in place with our third parties, which aredesigned to help safeguard your personal information. This means that theycannot do anything with your personal information unless we have instructedthem to do it.
They will also not share your personal informationwith any organization apart from us. They also commit to protect the data theyhold on our behalf and to retain it for the period we instruct. The categoriesof third parties we may share personal information with are as follows: CloudComputing ServicesCommunication & Collaboration ToolsData AnalyticsServicesData Storage Service ProvidersFinance & Accounting ToolsGovernmentEntitiesRetargeting PlatformsSales & Marketing ToolsTesting ToolsUserAccount Registration & Authentication ServicesWebsite Hosting ServiceProvidersWe also may need to share your personal information in the following situations: Business Transfers.
We may share or transfer your information inconnection with, or during negotiations of, any merger, sale of company assets,financing, or acquisition of all or a portion of our business to anothercompany.
Affiliates.
We may share your information with our affiliates,in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venturepartners, or other companies that we control or that are under common controlwith us. BusinessPartners. We may share your information with ourbusiness partners to offer you certain products, services, or promotions. Other Users. When you share personal information [(for example,by posting comments, contributions, or other content to the Services)] orotherwise interact with public areas of the Services, such personal informationmay be viewed by all users and may be publicly made available outside theServices in perpetuity.
OfferWall. Our application(s) may display a third-party hosted“offer wall. ” Such an offer wall allows third-party advertisers to offervirtual currency, gifts, or other items to users in return for the acceptanceand completion of an advertisement offer. Such an offer wall may appear in ourapplication(s) and be displayed to you based on certain data, such as yourgeographic area or demographic information. When you click on an offer wall,you will be brought to an external website belonging to other persons and willleave our application(s).
A unique identifier, such as your user ID, will beshared with the offer wall provider in order to prevent fraud and properlycredit your account with the relevant reward.
5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
In Short: We are not responsiblefor the safety of any information that you share with third parties that we maylink to or who advertise on our Services, but are not affiliated with, ourServices .The Services, [including our offer wall], may link tothird-party websites, online services, or mobile applications and/or containadvertisements from third parties that are not affiliated with us and which maylink to other websites, services, or applications.
Accordingly, we do not make any guaranteeregarding any such third parties, and we will not be liable for any loss ordamage caused by the use of such third-party websites, services, orapplications. The inclusion of a link towards a third-party website, service,or application does not imply an endorsement by us. We cannot guarantee thesafety and privacy of data you provide to any third parties.
Any data collected by third parties is not coveredby this privacy notice. We are not responsible for the content or privacy andsecurity practices and policies of any third parties, including other websites,services, or applications that may be linked to or from the Services. Youshould review the policies of such third parties and contact them directly torespond to your questions.
6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies andother tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific informationabout how we use such technologies and how you can refuse certain cookies isset out in our Cookie Notice.
7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store,and process your information in countries other than your own.
Our servers are located in Switzerland. If you are accessingour Services from outside Switzerland, please be aware that your informationmay be transferred to, stored, and processed by us in our facilities and bythose third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WESHARE YOUR PERSONAL INFORMATION?” above), in other countries.
If you are a resident in the European EconomicArea (EEA) or United Kingdom (UK), then these countries may not necessarilyhave data protection laws or other similar laws as comprehensive as those inyour country. However, we will take all necessary measures to protect yourpersonal information in accordance with this privacy notice and applicable law.
European Commission’s Standard ContractualClauses: We have implemented measures to protect your personal information,including by using the European Commission’s Standard Contractual Clauses fortransfers of personal information between our group companies and between usand our third-party providers.
These clauses require all recipients to protectall personal information that they process originating from the EEA or UK inaccordance with European data protection laws and regulations. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.
[EU-US] and [Swiss-US] PrivacyShield Framework[s] Neobridge UAB and the following entities andsubsidiaries: Neobridge UAB comply with the [EU-US] and [Swiss-US] Privacy Shield Framework[s] as set forth by the US Department of Commerceregarding the collection, use, and retention of personal informationtransferred from [the European Union (EU)], [the UK], and [Switzerland] to the United States.
Although Privacy Shield is no longer considered avalid transfer mechanism for the purposes of [EU] and [Swiss] data protectionlaw, in light of the judgment of the Court of Justice of the European Union inCase C-311/18 and opinion of the Federal Data Protection and InformationCommissioner of Switzerland dated 8 September 2020, Neobridge UAB will continue to comply with the principles of the [EU-US] and [Swiss-US]Privacy Shield Framework[s]. To learn more about the Privacy Shield program,please visit www.privacyshield.gov.
Neobridge adheres to and complies withthe Privacy Shield Principles when processing personal information from [theEU], [UK], or [Switzerland]. If we have received your personal information inthe United States and subsequently transfer that information to a third partyacting as our agent, and such third party agent processes your personalinformation in a manner inconsistent with the Privacy Shield Principles, wewill remain liable unless we can prove we are not responsible for the eventgiving rise to the damage. In limited situations, [EU], [UK], and [Swiss] individualsmay seek redress from the Privacy Shield Panel, a binding arbitration mechanism.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep yourinformation for as long as necessary to fulfill the purposes outlined in thisprivacy notice unless otherwise required by law.
We will only keep your personal information for as long as itis necessary for the purposes set out in this privacy notice, unless a longerretention period is required or permitted by law (such as tax, accounting, orother legal requirements).
No purpose in this notice will require us keepingyour personal information for longer than [the period of time in whichusers have an account with us / [#] months past the termination of the user’saccount / [#] months past the start of the idle period of the user’s account /other]. When we have no ongoing legitimate business need to process yourpersonal information, we will either delete or anonymize such information, or,if this is not possible (for example, because your personal information hasbeen stored in backup archives), then we will securely store your personalinformation and isolate it from any further processing until deletion ispossible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical andorganizational security measures designed to protect the security of anypersonal information we process. However, despite our safeguards and efforts tosecure your information, no electronic transmission over the Internet orinformation storage technology can be guaranteed to be 100% secure, so wecannot promise or guarantee that hackers, cybercriminals, or other unauthorizedthird parties will not be able to defeat our security and improperly collect,access, steal, or modify your information. Although we will do our best toprotect your personal information, transmission of personal information to andfrom our Services is at your own risk. You should only access the Serviceswithin a secure environment.
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
By using the Services, you represent that you are atleast 18 or that you are the parent or guardian of such a minor and consent tosuch minor dependent’s use of the Services. If we learn that personalinformation from users less than 18 years of age has been collected, we willdeactivate the account and take reasonable measures to promptly delete suchdata from our records. If you become aware of any data we may have collectedfrom children under age 18, please contact us.
11. WHAT ARE YOUR PRIVACY RIGHTS?
InShort: In someregions, such as the European Economic Area (EEA), United Kingdom (UK), andCanada, you have rights that allow you greater access to and control over yourpersonal information. You may review, change, or terminate your account at anytime. In some regions (like the EEA, UK, and Canada), you havecertain rights under applicable data protection laws.
These may include the right (i) to request accessand obtain a copy of your personal information, (ii) to request rectificationor erasure; (iii) to restrict the processing of your personal information; and(iv) if applicable, to data portability. In certain circumstances, you may alsohave the right to object to the processing of your personal information. Youcan make such a request by contacting us by using the contact details providedin the section “HOW CAN YOUCONTACT US ABOUT THIS NOTICE?” below. We will consider and act upon any requestin accordance with applicable data protection laws. If you are located in theEEA or UK and you believe we are unlawfully processing your personalinformation, you also have the right to complain to your local data protectionsupervisory authority.
You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
If you are located in Switzerland, the contact details forthe data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
Withdrawing yourconsent: If we are relying on your consent to process yourpersonal information, which may be express and/or implied consent depending onthe applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contactdetails provided in the section “HOWCAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.
However, please note that this will not affect thelawfulness of the processing before its withdrawal, nor when applicable lawallows, will it affect the processing of your personal information conducted inreliance on lawful processing grounds other than consent. Opting out of marketing andpromotional communications: You can unsubscribe from our marketing andpromotional communications at any time by clicking on the unsubscribe link inthe emails that we send, replying “STOP” or “UNSUBSCRIBE” to the SMS messagesthat we send, [Other] or by contacting us using the details providedin the section “HOW CAN YOUCONTACT US ABOUT THIS NOTICE?” below. You will then be removed from themarketing lists — however, we may still communicate with you, for example tosend you service-related messages that are necessary for the administration anduse of your account, to respond to service requests, or for other non-marketingpurposes.
Account Information.
If you would at any time like to review or changethe information in your account or terminate your account, you can: Log in toyour account settings and update your user account. Contact us Upon your requestto terminate your account, we will deactivate or delete your account andinformation from our active databases. However, we will retain some informationin our files to prevent fraud, troubleshoot problems, assist with anyinvestigations, enforce our legal terms and/or comply with applicable legalrequirements. Cookies andsimilar technologies: Most Web browsers are set to accept cookiesby default. If you prefer, you can usually choose to set your browser to removecookies and to reject cookies. If you choose to remove cookies or rejectcookies, this could affect certain features or services of our Services. If you have questions or comments about your privacy rights, you may email us.
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operatingsystems and mobile applications include a Do-Not-Track (“DNT”) feature orsetting you can activate to signal your privacy preference not to have dataabout your online browsing activities monitored and collected. At this stage nouniform technology standard for recognizing and implementing DNT signals hasbeen finalized. As such, we do not currently respond to DNT browser signals orany other mechanism that automatically communicates your choice not to betracked online. If a standard for online tracking is adopted that we mustfollow in the future, we will inform you about that practice in a revisedversion of this privacy notice.
Howdo we use and share your personal information? Neobridge collects and shares your personalinformation through: Targeting cookies/Marketing cookiesSocial media cookiesBeacons/Pixels/TagsClickredirectsSocial media plugins: We use social media features, such as a “Like”button, and widgets, such as a “Share” button in our Services. Such featuresmay process your Internet Protocol (IP) address and track which page you arevisiting on our website.
We may place a cookie to enable the feature towork correctly. If you are logged in on a certain social media platform and youinteract with a widget or button belonging to that social media platform, thisinformation may be recorded to your profile of such social media platform. Toavoid this, you should log out from that social media platform before accessingor using the Services. Social media features and widgets may be hosted by athird party or hosted directly on our Services.
Your interactions with these features are governedby the privacy notices of the companies that provide them. By clicking on oneof these buttons, you agree to the use of this plugin and consequently thetransfer of personal information to the corresponding social media service.
We have no control over the essence and extent ofthese transmitted data or their additional processing. More information aboutour data collection and sharing practices can be found in this privacynotice. If you are using an authorized agent to exercise your right to opt outwe may deny a request if the authorized agent does not submit proof that theyhave been validly authorized to act on your behalf. Will your information beshared with anyone else?
We may disclose your personal information with our serviceproviders pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information onour behalf. We may use your personal information for our own business purposes,such as for undertaking internal research for technological development anddemonstration. This is not considered to be “selling” of your personal information. Your rights withrespect to your personal dataRight to request deletion of the data — Request todeleteYou can ask for the deletion of your personal information. If you ask usto delete your personal information, we will respect your request and deleteyour personal information, subject to certain exceptions provided by law, suchas (but not limited to) the exercise by another consumer of his or her right tofree speech, our compliance requirements resulting from a legal obligation, orany processing that may be required to protect against illegal activities. Right to be informed — Request to knowDepending on the circumstances, you havea right to know: whether we collect and use your personal information; thecategories of personal information that we collect; the purposes for which thecollected personal information is used; whether we sell your personalinformation to third parties; the categories of personal information that wesold or disclosed for a business purpose; the categories of third parties towhom the personal information was sold or disclosed for a business purpose; andthe business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are notobligated to provide or delete consumer information that is de-identified inresponse to a consumer request or to re-identify individual data to verify aconsumer request. Right to Non-Discrimination for the Exercise of a Consumer’sPrivacy Rights
We will not discriminate against you if youexercise your privacy rights.
Verification processUpon receiving your request,we will need to verify your identity to determine you are the same person aboutwhom we have the information in our system.
These verification efforts require us to ask youto provide information so that we can match it with information you havepreviously provided us. For instance, depending on the type of request yousubmit, we may ask you to provide certain information so that we can match theinformation you provide with the information we already have on file, or we maycontact you through a communication method (e.g., phone or email) that you havepreviously provided to us. We may also use other verification methods as thecircumstances dictate.
We will only use personal information provided inyour request to verify your identity or authority to make the request. To theextent possible, we will avoid requesting additional information from you forthe purposes of verification.
However, if we cannot verify your identity fromthe information already maintained by us, we may request that you provideadditional information for the purposes of verifying your identity and forsecurity or fraud-prevention purposes. We will delete such additionallyprovided information as soon as we finish verifying you.
Other privacy rightsYou may object to theprocessing of your personal information. You may request correction of yourpersonal data if it is incorrect or no longer relevant, or ask to restrict theprocessing of the information. You can designate an authorized agent to make arequest under the CCPA on your behalf.
We may deny a request from an authorized agentthat does not submit proof that they have been validly authorized to act onyour behalf in accordance with the CCPA.
You may request to opt out from future selling ofyour personal information to third parties. Upon receiving an opt-out request,we will act upon the request as soon as feasibly possible, but no later thanfifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us byemail. If you have a complaint about how we handle your data, we would like tohear from you.
FinancialIncentives“Financial incentive” means a program, benefit, orother offering, including payments to consumers as compensation, for thedisclosure, deletion, or sale of personal information.
The law permits financial incentives or a price orservice difference if it is reasonably related to the value of the consumer’sdata. A business must be able to explain how the financial incentive or priceor service difference is reasonably related to the value of the consumer’s data.
The explanation must include: a good-faith estimateof the value of the consumer’s data that forms the basis for offering thefinancial incentive or price or service difference; anda description of themethod the business used to calculate the value of the consumer’s data.
We may decide to offer a financial incentive(e.g., price or service difference) in exchange for the retention or sale of aconsumer’s personal information. If we decide to offer a financial incentive, wewill notify you of such financial incentive and explain the price difference,as well as material terms of the financial incentive or price of servicedifference, including the categories of personal information that areimplicated by the financial incentive or price or service difference.
13. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will updatethis notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. Theupdated version will be indicated by an updated “Revised” date and the updatedversion will be effective as soon as it is accessible.
If we make material changes to this privacynotice, we may notify you either by prominently posting a notice of suchchanges or by directly sending you a notification. We encourage you to reviewthis privacy notice frequently to be informed of how we are protecting your information.
14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may contact our Data Protection Officer (DPO) by email at contact@neobridge.io
15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATAWE COLLECT FROM YOU?
Based on the applicable laws of your country, youmay have the right to request access to the personal information we collectfrom you, change that information, or delete it in some circumstances.