Last updated August 02, 2024
This privacy notice for Neon Cyber Inc. ( "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 http://www.neoncyber.io , or any website 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 at support@neoncyber.io .
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 clicking the link following each
key point or 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 us and the Services,
the choices you make, and the products and features you use.
Learn more about
personal information you disclose to us.
Do we process any sensitive personal information? We do not process
sensitive personal information.
Do we collect any information from third parties? We do not collect any
information from third parties.
How do we process your information? 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 information
only when we have a valid legal reason to do so. Learn more about
how we process your information.
In what situations and with which parties do we share
personal information? We may share information in specific situations and with specific
third parties. Learn more
about
when and with whom we share your personal information.
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. Learn more about
how we keep your information safe.
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.
Learn more about
your privacy rights.
How do you exercise your rights? The easiest
way to exercise your rights is by visiting http://www.neoncyber.io/contact , or by contacting us. We
will consider and act upon any request in accordance with
applicable data protection laws.
Want to learn more about what we do with any information we
collect?
Review the privacy notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us
In Short:We collect personal information
that you provide to us.
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:
-
names
-
phone numbers
-
email addresses
-
job titles
-
contact preferences
Sensitive Information. We do not process
sensitive information.
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 collected
In 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.
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).
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 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
fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- 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
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. Learn more about withdrawing your consent.
- 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.
- 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.
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 way
- For investigations and fraud detection and prevention
- For business transactions provided certain conditions
are met
- If it is contained in a witness statement and the
collection is necessary to assess, process, or settle an
insurance claim
- For identifying injured, ill, or deceased persons and
communicating with next of kin
- If we have reasonable grounds to believe an individual
has been, is, or may be victim of financial abuse
- If 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 produced
- If the collection is solely for journalistic, artistic,
or literary purposes
- If the information is publicly available and is
specified by the regulations
In Short:
We may share information in specific situations
described in this section and/or with the following third parties.
We may need
to share your personal information in the
following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
5. 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 the United States
If you are a resident in the European Economic Area
(EEA), United Kingdom (UK), or Switzerland, then these
countries may not necessarily have data protection laws
or other similar laws as comprehensive as those in your
country. However, we will take all necessary measures to
protect your personal information in accordance with
this privacy notice and applicable law.
European Commission's Standard Contractual Clauses:
We have implemented measures to protect your personal
information, including by using the European
Commission's Standard Contractual Clauses for transfers
of personal information between our group companies and
between us and our third-party providers. These clauses
require all recipients to protect all personal
information that they process originating from the EEA
or UK in accordance with European data protection laws
and regulations. Our Standard Contractual Clauses can be provided
upon request. We have implemented similar appropriate
safeguards with our third-party service providers and
partners and further details can be provided upon
request.
6. HOW LONG DO WE KEEP YOUR
INFORMATION?
In Short: We keep your information for as long as necessary
to fulfill the purposes
outlined in this privacy notice unless otherwise required
by law.
We will only keep your personal information for as long
as it is necessary for the purposes set out in this
privacy notice, unless a longer retention period is
required or permitted by law (such as tax, accounting,
or other legal requirements). No purpose in this notice
will require us keeping your personal information for longer
than the period of time
in which users have an account with us .
When we have no ongoing legitimate business need to
process your personal information, we will either delete
or anonymize such information,
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.
7. 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 and organizational security measures
designed to protect the security of any personal information
we process. However, despite our safeguards and efforts to
secure your information, 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. Although we will
do our best to protect your personal information, transmission
of personal information to and from our Services is at your
own risk. You should only access the Services within a secure
environment.
8. DO WE COLLECT INFORMATION FROM
MINORS?
In Short:
We do not knowingly collect data from or market to children under 18
years of age .
We do not knowingly collect, solicit data from, or
market to children under 18 years of age, nor do we
knowingly sell such personal information. By using the
Services, you represent that you are at least 18 or that
you are the parent or guardian of such a minor and
consent to such minor dependent’s use of the Services.
If we learn that personal information from users less
than 18 years of age has been collected, we will
deactivate the account and take reasonable measures to
promptly delete such data from our records. If you
become aware of any data we may have collected from
children under age 18, please contact us at support@neoncyber.io .
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: Depending on
your state of residence in the US or in some regions, such as the European
Economic Area (EEA), United Kingdom (UK),
Switzerland, and Canada , you have rights that allow you greater
access to and control over your personal
information. You may review, change, or terminate your
account at any time, depending on your country,
province, or state of residence.
In some regions (like the EEA, UK, Switzerland, and Canada ), you have certain
rights under applicable data protection laws. These may
include the right (i) to request access and obtain a
copy of your personal information, (ii) to request
rectification or erasure; (iii) to restrict the
processing of your personal information; (iv) if
applicable, to data portability; and (v) not to be
subject to automated decision-making. In certain
circumstances, you may also have the right to object to
the processing of your personal information. You can
make such a request by contacting us by using the
contact details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below.
We will consider and act upon any request in accordance
with applicable data protection laws.
If you are located in the EEA or UK and you believe we
are unlawfully processing your personal information, you
also have the right to complain to your Member State data
protection authority or
UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and
Information Commissioner.
Withdrawing your consent: If we
are relying on your consent to process your personal information, which may be express and/or
implied consent depending on the 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 contact
details provided in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below or updating your preferences .
However, please note that this will not affect the
lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect
the processing of your personal information conducted in reliance
on lawful processing grounds other than consent.
Opting out of marketing and promotional
communications:You can unsubscribe from our marketing
and promotional communications at any time by clicking on the unsubscribe
link in the emails that we send, or by contacting us using
the details provided in the section
" HOW CAN YOU CONTACT US ABOUT THIS NOTICE? " below. You will
then be removed from the marketing lists. However, we may still
communicate with you — for example, to send you service-related
messages that are necessary for the administration and use of
your account, to respond to service requests, or for other non-marketing
purposes.
Account Information
If you would at any time like to review or change the
information in your account or terminate your account, you
can:
-
Log in to your account settings and update your user account.
Upon your request to terminate your account, we will
deactivate or delete your account and information from our
active databases. However, we may retain some information in
our files to prevent fraud, troubleshoot problems, assist
with any investigations, enforce our legal terms and/or
comply with applicable legal requirements.
If you have questions or comments about your privacy
rights, you may email us at support@neoncyber.io .
10. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and
mobile applications include a Do-Not-Track ( "DNT" ) feature
or setting you can activate to signal your privacy
preference not to have data about your online browsing
activities monitored and collected. At this stage, no
uniform technology standard for recognizing and implementing
DNT signals has been finalized . As such, we do not currently respond to DNT
browser signals or any other mechanism that
automatically communicates your choice not to be tracked
online. If a standard for online tracking is adopted
that we must follow in the future, we will inform you
about that practice in a revised version of this privacy
notice.
California law requires us to let you know how we respond
to web browser DNT signals. Because there currently is not
an industry or legal standard for recognizing
or honoring DNT signals, we
do not respond to them at this time.
11. DO UNITED STATES RESIDENTS HAVE
SPECIFIC PRIVACY RIGHTS?
In Short: If you are a resident of
California, Colorado, Connecticut, Delaware, Florida,
Indiana, Iowa, Kentucky, Montana, New Hampshire, New
Jersey, Oregon, Tennessee, Texas, Utah, or Virginia , you may have the
right to request access to and receive details about
the personal information we maintain about you and
how we have processed it, correct inaccuracies, get
a copy of, or delete your personal information. You
may also have the right to withdraw your consent to
our processing of your personal information. These
rights may be limited in some circumstances by
applicable law. More information is provided below.
Categories of Personal Information We Collect
We have collected the following categories of personal
information in the past twelve (12) months:
Category | Examples | Collected |
A. Identifiers | Contact details, such as real name,
alias, postal address, telephone or
mobile contact number, unique personal
identifier, online identifier, Internet
Protocol address, email address, and
account name |
B. Personal information as defined
in the California Customer Records
statute | Name, contact information,
education, employment, employment
history, and financial information |
We may also collect
other personal
information outside
of these categories
through instances
where you interact
with us in person,
online, or by phone
or mail in the
context of:
- Receiving help
through our customer
support channels;
- Participation in
customer surveys or
contests; and
- Facilitation in the
delivery of our
Services and to
respond to your
inquiries.
- Category B -
As long as the user has an account with us
Gender, age, date of birth,
race and ethnicity, national
origin, marital status, and
other demographic data | ||
Transaction information,
purchase history, financial
details, and payment
information | ||
Fingerprints and
voiceprints | ||
Browsing
history,
search
history,
online | ||
Device
location | ||
Images
and
audio,
video
or
call
recordings
created
in
connection
with
our
business
activities | ||
Business
contact
details
in
order
to
provide
you
our
Services
at
a
business
level
or
job
title,
work
history,
and
professional
qualifications
if
you
apply
for
a
job
with
us | ||
Student
records
and
directory
information | ||
Inferences
drawn
from
any
of
the
collected
personal
information
listed
above
to
create
a
profile
or
summary
about,
for
example,
an
individual’s
preferences
and
characteristics | ||
Sources of Personal Information
Learn more about the sources of personal information we
collect in " WHAT INFORMATION DO WE COLLECT? "
How We Use and Share Personal Information
Learn about how we use your personal information in the
section, " HOW DO WE PROCESS YOUR INFORMATION? "
Will your information be shared with anyone else?
We may disclose your personal information with our
service providers pursuant to a written contract between
us and each service provider. Learn more about how we
disclose personal information to in the section, " WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION? "
We may use your personal information for our own
business purposes, such as for undertaking internal
research for technological development and
demonstration. This is not considered to be "selling" of your personal
information.
We have not disclosed, sold, or shared any personal
information to third parties for a business or
commercial purpose in the preceding twelve (12) months.
Wewill not
sell or share personal information in the future
belonging to website visitors, users, and other
consumers.
Your Rights
You have rights under certain US state data protection
laws. However, these rights are not absolute, and in certain
cases, we may decline your request as permitted by law.
These rights include:
- Right to know whether or not we are processing
your personal data
- Right to access your personal data
- Right to correct inaccuracies in your
personal data
- Right to request the deletion of your personal
data
- Right to obtain a copy of the personal
data you previously shared with us
- Right to non-discrimination for exercising
your rights
- Right to opt out of the processing of your
personal data if it is used for targeted advertising
(or sharing as defined under California’s privacy law) , the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ( "profiling" )
Depending upon the state where you live, you may also have
the following rights:
- Right to obtain a list of the categories of third parties
to which we have disclosed personal data (as permitted by
applicable law, including
California's and Delaware's privacy law)
- Right to obtain a list of specific third parties to which
we have disclosed personal data (as permitted by applicable
law, including Oregon’s privacy law)
- Right to limit use and disclosure of sensitive personal
data (as permitted by applicable law, including California’s
privacy law)
- Right to opt out of the collection of sensitive data and
personal data collected through the operation of a voice or
facial recognition feature (as permitted by applicable law,
including Florida’s privacy law)
How to Exercise Your Rights
To exercise these rights, you can contact us by visiting http://www.neoncyber.io/contact , by
emailing us at support@neoncyber.io ,
or by referring to the contact details at the bottom of this
document. Under certain US state data protection laws, you can
designate an authorized agent to make a request on your behalf. We may deny a
request from an authorized agent that does not submit proof that they have been
validly authorized to act on your
behalf in accordance with applicable laws.
Request Verification
Upon receiving your request, we will need to verify your
identity to determine you are the same person about whom we
have the information in our system. We will only use
personal information provided in your request to verify your
identity or authority to make the request. However, if we
cannot verify your identity from the information already
maintained by us, we may request that you provide additional
information for the purposes of verifying your identity and
for security or fraud-prevention purposes.
If you submit the request through an authorized agent, we may need
to collect additional information to verify your identity before
processing your request and the agent will need to provide a
written and signed permission from you to submit such request
on your behalf.
Appeals
Under certain US state data protection laws, if we decline
to take action regarding your request, you may appeal our
decision by emailing us at support@neoncyber.io . We will inform you in writing
of any action taken or not taken in response to the appeal,
including a written explanation of the reasons for the
decisions. If your appeal is denied, you may submit a
complaint to your state attorney general.
California "Shine
The Light"
Law
California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our
users who are California residents to request and obtain from
us, once a year and free of charge, information about categories
of personal information (if any) we disclosed to third parties
for direct marketing purposes and the names and addresses of
all third parties with which we shared personal information in
the immediately preceding calendar year. If you are a California
resident and would like to make such a request, please submit
your request in writing to us by using the contact details provided
in the section " HOW CAN YOU CONTACT US ABOUT THIS NOTICE? "
12. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this
notice as necessary to stay compliant with relevant
laws.
We may update this privacy notice from time to time.
The updated version will be indicated by an updated "Revised" date at the
top of this privacy notice. If we make material changes to
this privacy notice, we may notify you either by prominently
posting a notice of such changes or by directly sending you
a notification. We encourage you to review this privacy notice
frequently to be informed of how we are protecting your information.
13. HOW CAN YOU CONTACT US ABOUT THIS
NOTICE?
If you have questions or comments about this notice,
you may email us at support@neoncyber.io or
contact us by post at:
14. HOW CAN YOU
REVIEW, UPDATE,
OR DELETE THE
DATA WE COLLECT
FROM YOU?