Effective date: May 1, 2018
- In email, text and other electronic messages between you and us.
- When and where available, through mobile and desktop applications, which provide dedicated non-browser-based interaction between you and us.
- Us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
- Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on our website.
We gather various types of Personal Information from our users, as explained in more detail below, and we use this Personal Information internally in connection with our Services, including:
- to personalize and improve our services;
- to allow you to set up a user account and profile;
- to contact you and allow other users to contact you;
- to fulfill your requests for certain products and services;
- to provide and improve the Services; and
- to analyze how you use the Services.
In certain cases, we may also share some Personal Information with third parties, but only as described below.
We are not responsible for the practices of sites linked to from the Services, or for the privacy practices of nations that are run by our other customers on the Services, and you are advised to review their rules and policies before interacting with any of these sites or nations and before providing them with any private information.
Individuals under the Age of 18
As noted in the Master Terms, we do not knowingly collect, solicit or maintain Personal Information from anyone under the age of 18 or knowingly allow such persons to register for our Services, with the exception of children 13 or older who have permission from a parent or guardian who has agreed to the Master Terms on the child's behalf. If you are under 18, please do not send any Personal Information about yourself (such as your name, address, telephone number, or email address) to us. No one under age 18 is allowed to provide any Personal Information to or on the Services. In the event that we learn that we have collected Personal Information from a child under age 18 without verification of parental consent, we will use commercially reasonable efforts to delete that information from our database. Please contact us at [email protected] if you have any concerns.
Information We Collect About You and How We Collect It
We collect several types of information from and about users, including Personal Information that is about you but individually does not identify you, such as, time and date of visits to our Website, etc.; and/or, about your internet connection, the equipment you use to access our Website and usage details.
We may collect the following personal information from you:
- Your name
- Your job title
- Your email address
- Your phone number
- Your mailing address
- Your employer
- Other unique identifiers (including your device's internet protocol (IP) address)
We collect this information:
- Directly from you when you provide it to us. When you sign up for the Services, you provide us with information such as your name and email address. In jurisdictions where it is permitted, we may also collect information from your public social media accounts and use it to better provide you with products and services that may be relevant to you.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
- From third parties, for example, our business partners.
Information You Provide to Us. The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to or purchasing our services, posting material or requesting further services. We may also ask you for information when you report a problem with our Website.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
- Your search queries on the Website.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Content”). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies. As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
- Details of your visits to our Website, including, but not limited to, traffic data, geolocation data, logs and other communication data and the resources that you access and use on the Website.
- Information about your computer and internet connection, including your IP address, operating system and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). For more information on how to opt-out of advertiser tracking mechanisms, please visit www.networkadvertising.org/managing/opt_out.asp.
The information we collect automatically is statistical data and may include Personal Information, but we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including, but not limited to, by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize and improve our Website.
- Speed up your searches.
- Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include cookies, flash cookies, web beacons, pixel tracking, GIF and/or IP address. Each of these is discussed below. For details on the specific cookies we are currently using, please review our Cookie Declaration.
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. It may contain certain data, including, but not limited to: the name of the server that has placed it there, an identifier in the form of a unique number, and, an expiration date (some cookies only). Cookies are managed by the web browser on your computer (Internet Explorer, Edge, Firefox, Safari or Google Chrome).
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
- Web Beacons. Pages of our the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity)
- Pixel Tracking. In addition to using Cookies, the Website may employ “pixel tracking”, a common process which may be used in connection with advertisements on other sites. Pixel tracking involves the use of pixel tags that are not visible to the user and consist of a few lines of computer code. Pixel tracking measures the effectiveness of advertisements and compiles aggregate and specific usage statistics. A “pixel tag” is an invisible tag placed on certain pages of websites that is used to track an individual user’s activity. We may access these pixel tags to identify activity and interests that may allow us to better match our goods, services, and other offers with your interests and needs. For example, if you visit our Website from an advertisement on another website, the pixel tag will allow the advertiser to track that its advertisement brought you to the Website. If you visit our Website, and we link you to another website, we may also be able to determine that you were sent to and/or transacted with a third-party website. This data is collected for use in our marketing and research.
- GIF. We may use tiny images known as clear GIFs to track behavior of users, including statistics on who opens our emails.
- IP Address. Our servers automatically record certain log file information reported from your browser when you access the Services. These server logs may include information such as which pages of the Service you visited, your internet protocol (“IP”) address, browser type, and other information on how you interact with the Services. These log files are generally deleted after one week.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Financial information connected to payments may be collected or stored by a third-party payment processor and is subject to their terms and policies.
How To Turn Off Cookies
If you choose to turn cookies off, all modern browsers allow you to do so, usually in their settings page.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any Personal Information:
- To present our Website and its contents to you.
- To provide you with information, products or services that you request from us.
- For analyzing how the Service is used, diagnosing service or technical problems, maintaining security, and personalizing content.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account, including expiration and renewal notices.
- To operate, maintain, and provide to you the features and functionality of the Service.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- To notify you about changes to our Website, our policies, terms or any products or services we offer or provide though it.
- To allow you to participate in interactive features on our Website.
- In any other way we may describe when you provide the information.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Social Media Plugins
We integrate social media application program interfaces or plug-ins ("Plug-ins") from social networks, including Facebook, Google+, LinkedIn, Xing, Twitter, Instagram, Tumblr, Pinterest and/or possibly other companies, into the Website. In order to register as a user with us, you may have the option to sign in using your Facebook or other social media site ("SMS") login.
For example, when you visit our Website or platform, the plugin creates a direct connection between your browser and the Facebook server. This allows Facebook to receive information about your visit to our Website or platform with your IP address. If you click the Facebook “Like” button while you are logged on to your Facebook account, you can link the contents of our Website or platform to your Facebook profile. This allows Facebook to assign your visit to our Website or platform to your user account. Please note that as provider of the Website or platform, we receive no notification about the contents of the transmitted data or their use by Facebook. If you do not want Facebook to assign your visit to our Website or platform to your Facebook user account, please log out of your Facebook user account.
How Long Do We Keep Your Personal Information?
We will keep your personal information as long as it is necessary for the purpose for which we obtained it, unless you ask us to delete it at an earlier time. Our retention periods are based on business needs and legal requirements, and your information that is no longer needed is either irreversibly anonymised or destroyed securely.
If you ask us to delete your personal information at an earlier time, we will delete all information we hold on you within 30 days, save for information which is reasonable for us to retain in order to operate our Website or information we are required to retain by law.
Following termination or deactivation of your account, we may retain your profile information and all information posted to public areas of the Service.
How We Share Your Information
Personal Information: We will never rent or sell your Personal Information to others, other than as noted below under “Disclosure/Assignment of Your Personal Information”. We may share your Personal Information with third parties for the purpose of providing or improving the Service to you. If we do this, such third parties’ use of your Personal Information will be bound by obligations of confidentiality. We may store Personal Information in locations outside our direct control (for instance, on servers or databases located or co-located with hosting providers). Any Personal Information or content that you voluntarily disclose for posting to the Service becomes available to the public, as controlled by any applicable privacy or website customization settings. To change your privacy settings on the Service, you may visit your Neutrino Labs account settings page. If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other users have copied or saved that information.
From time to time, we may run contests, special offers, or other events or activities (“Events”) on the Service together with a third party partner. If you provide information to such third parties, they may use it for the purpose of that Event and any other use to which you consent. We cannot control third parties’ use of your information. If you do not want your information to be collected by or shared with a third party, you can choose not to participate in these Events.
De-Identified Personal Information: We may share De-Identified Personal Information (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services.
Your Consent to Our Disclosure/Assignment of Your Personal Information. You consent to our disclosure of your Personal Information and other information to a potential buyer or other successor for the purpose of considering a merger, divestiture, restructuring, reorganization, dissolution, or sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred. You agree to and do hereby consent to our assignment, conveyance, or transfer (whether by contract, merger or operation of law) of rights to your Personal Information and other information, with or without notice to you and without your further consent.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure. All personal information you provide to us is stored on our secure servers (or those of our service providers) behind firewalls. We may store, retrieve, access, and transmit your personal information in the US or in other countries. Any payment transactions will be performed using our third party payment processors, who will use appropriate security procedures.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Website or Services, you are responsible for keeping this password confidential. You should not share your password with anyone. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account. The information you share in public areas may be viewed by other users.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do try to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to us or which we obtain. Any transmission of Personal Information is at your own risk. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or used with our Services.
What You Can Access
Through your account settings, you may access, and, in some cases, edit or delete the following information you’ve provided to us:
- name and password
- email address
- user profile information, including any content you have uploaded to the Services
The information that you can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at [email protected]
Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us annually for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes, and to being provided contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: [email protected]
Notices; Opting Out
By providing us with your email address (including by “following,” “liking,” linking your account to the Neutrino Labs service or other Services, etc., on a third party website or network), you consent to our using the email address to send you Service-related notices, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send you notifications of activity on the Service to the email address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages or content, such as, but not limited to, newsletters, additions or changes to features of the Service, or special offers. If you do not want to receive such email messages, you may opt out by emailing us your request at [email protected] Labs.com. Opting out may prevent you from receiving email messages regarding updates, improvements, special features, announcements, or offers. You may not opt out of Service-related emails.
You may be able to add, update, or delete information as explained above. You may request deletion of your account by emailing us at [email protected]
Data Protection Officer, [email protected]
Additional Information for Users Located in the European Economic Area (“EEA”)
If you are a resident of the European Union, the General Data Protection Regulation (“GDPR”) will come into force on May 25, 2018. While we take significant measures to protect privacy of your information, we are working toward ensuring that we are compliant with the GDPR rules by the time they become effective.
If you are a resident of country other than the United States, you acknowledge and consent to our collecting, transmitting, and storing your Personal Information out of the country in which you reside.
Transfer of data outside of the EEA
We may transfer some or all of your personal information outside of the EEA. The privacy laws of the receiving country may be different from those in the EEA and may not have adequate data protection standards. We will always have appropriate safeguards in place when transferring your personal information outside of the EEA, and you may ask us for a copy of these safeguards.
You have the following rights regarding your information:
- The right to rectification: You’re entitled to have your information corrected if it’s inaccurate or incomplete.
- The right to erasure: This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there’s no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.
- The right to restrict processing: You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.
- The right to data portability: You have rights to obtain and reuse your personal data for your own purposes across different services. Eg, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.
- The right to object: You have the right to object to certain types of processing, including processing for direct marketing (which we do only with your consent). For more information or to object, see Objecting to processing.