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NeoSystems Corporation

Privacy Policy

Privacy Policy

NeoSystems (“we” or “us”) is committed to ensuring that your privacy is protected. This Privacy Policy (“Privacy Policy”) describes the types of information that we gather from you, including when you use our website (www.neosystemscorp.com) (the “Site”) or that you may provide to us through means other than the Site, as well as how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or applicable supervisory authorities in the event you have a complaint. Should we ask you to provide any personal information, then you can be assured that it will only be used in accordance with this Privacy Policy.

NeoSystems may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are aware of any changes. This policy was last updated on June 30, 2020.

We collect and use certain information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“personal information”). When we do so we may be subject to various laws in the United States, including the California Consumer Privacy Act of 2018 (“CCPA”) and the General Data Protection Regulation (“GDPR”) which applies across the European Union, and we are responsible as “controller” of that personal information for the purposes of those laws.

Notwithstanding the foregoing, we do not market or promote our services to residents located in any country or jurisdiction other than the United States.

1. Personal Information We Collect About You. We may collect and use the following personal information:

Category Information Collected
A. Identifiers. Examples include: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples include: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, education, employment, employment history, bank account number, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law. Examples include: citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), veteran or military status.
D. Commercial information. Examples include: Services purchased, obtained, or considered.
E. Internet or other similar network activity. Examples include: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
F. Professional or employment-related information. Examples include: Current or past job history or performance evaluations.
G. Inferences drawn from other personal information. Examples include: Preferences, characteristics, behavior, attitudes, intelligence, abilities, and aptitudes.

2. How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email and via our website. However, we may also collect information:

  • From publicly accessible sources (e.g., social media sites and other publicly available web sites);
  • Directly from a third party (e.g., credit reporting agencies, or customer due diligence providers);
  • From vendors;
  • Using cookies on our website, as described below;
  • Via our IT systems, including automated monitoring of our websites and other technical systems, such as our computer networks and connections, access control systems, communications systems, email and instant messaging systems; and
  • From business partners with whom we hold co-branded marketing events, such as event attendee list with names, affiliation, and contact information.

3. How We Use Cookies. A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets us know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

4. How and Why We Use Your Personal Information. We require this information to understand your needs and provide you with a better service, and in particular for the
following reasons. In addition, your personal information may be subject to data protection laws that require us to only use your personal information if we have a proper reason for doing so, e.g.,:

  • To comply with our legal and regulatory obligations;
  • For the performance of our contract with you or to take steps at your request before entering into a contract;
  • For our legitimate interests or those of a third party; or
  • Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests under applicable law. The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for Our reasons
To provide services to you For the performance of our contract with you or to take steps at your request before entering into a contract
Conducting checks to identify our customers and verify their identity
Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business
To comply with our legal and regulatory obligations
Ensuring business policies are adhered to, e.g., policies covering security and Internet use For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training and quality control For our legitimate interests or those of a third party, e.g., to be as efficient as we can so we can deliver the best service for you
To comply with our contractual obligations To comply with our legal obligations
Ensuring the confidentiality of commercially sensitive information

For our legitimate interests or those of a third party, e.g., to protect trade secrets and other commercially valuable information

To comply with our legal and regulatory obligations

Statistical analysis to help us manage our business, e.g., in relation to our financial performance, customer base, product range or other efficiency measures For our legitimate interests or those of a third party, e.g., to be as efficient as we can so we can deliver the best service for you
Preventing unauthorized access and modifications to systems

For our legitimate interests or those of a third party, e.g., to prevent and detect criminal activity that could be damaging for us and for you

To comply with our legal and regulatory obligations

Updating customer records

For the performance of our contract with you or to take steps at your request before entering into a contract

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products

Ensuring safe working practices, staff administration and assessments

To comply with our legal and regulatory obligations

For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you

Marketing our services to:
⎯ existing and former customers;
⎯ third parties who have previously expressed an interest in our services;
⎯ third parties with whom we have had no previous dealings.
For our legitimate interests or those of a third party, e.g., to promote our business to existing and former customers
Credit reference checks via external credit reference agencies For our legitimate interests or those of a third party, e.g., to ensure our customers are likely to be able to pay for our products and services
External audits and quality checks

For our legitimate interests or a those of a third party, e.g., so we can demonstrate we operate at the highest standards and to audit our accounts.

To comply with our legal and regulatory obligations

The above table does not apply to special category personal information as defined under the GDPR. If you are an individual whose personal data is subject to the GDPR, we will only process your special category information with your explicit consent.

5. Promotional Communications. We may use your personal information to send you updates (e.g., by email, text message, telephone or post) about our services. We have a legitimate interest in processing your personal information for promotional purposes (see above “How and Why We Use Your Personal Information”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.
We will always treat your personal information with the utmost respect and, except as set forth in the section below titled “Who We Share Your Personal Information With,” we never sell or share it with other organizations for marketing purposes.
You have the right to opt out of receiving promotional communications at any time by:

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

6. Who We Share Your Personal Information With. We routinely share personal information with:

  • Service providers we use to help deliver our services to you, such as payment service providers, warehouses and delivery companies;
  • Other third parties we use to help us run our business, such as marketing agencies and website hosts;
  • Business partners with whom we jointly host promotional and other events;
  • Our external auditors; and
  • Our insurers and brokers.

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information.

may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.
We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. The recipient of the information will be bound by confidentiality obligations.

7. Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information to the following categories of third parties:

  • Identifiers to business partners with whom we jointly host promotional and other events, service providers and auditors.
  • California Customer Records personal information categories to business partners with whom we jointly host promotional and other events, service providers and auditors.
  • Protected classification characteristics under California or federal law to service providers and auditors.
  • Commercial information to service providers and auditors.
  • Internet or other similar network activity to service providers and auditors.
  • Professional or employment-related information to service providers and auditors.
  • Inferences drawn from other personal information to service providers and auditors.
  • All categories of personal information may be disclosed to database or data storage and archiving service providers in connection with the storage and other processing of such information.

8. Sale of Personal Information
In the preceding twelve (12) months, we have not sold personal information for monetary value but we have disclosed the following categories of personal information for business and commercial purposes, which may constitute a sale of information under the CCPA, to the following categories of third parties:

  • Identifiers to business partners with whom we jointly host promotional and other events; and
  • California Customer Records personal information categories to Business partners with whom we jointly host promotional and other events.

We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

9. Where Your Personal Information is Held. Information may be held at our offices and those of our service providers as described above (see above: “Who We Share Your Personal Information With”). Some of these third parties may be based outside the European Economic Area. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA”.

10. How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us, while we are providing services to you, or as otherwise set forth under Section 4 above for the purposes for which you provided such information to us. Thereafter, we will keep your personal information for as long as is necessary:

  • To respond to any questions, complaints or claims made by you or on your behalf;
  • To show that we treated you fairly; or
  • To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes listed above and as otherwise set out in this policy.

11. Transferring Your Personal Information Out of the EEA. If you are a resident of the European Union, then to deliver services to you, it is sometimes necessary for us to share your personal information outside the European Economic Area (EEA), e.g.:

  • With our offices outside the EEA;
  • With your and our service providers located outside the EEA;
  • If you are based outside the EEA; or
  • Where there is an international dimension to the services we are providing to you.

These transfers are subject to special rules under European and UK data protection law.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. If you would like further information, please contact us (see “How To Contact Us” below).

12. Your Rights and Choices. This section describes the specific rights that may apply to you regarding your personal information and explains how to exercise those rights, depending upon the laws that apply to your personal information, such as the GDPR or CCPA. Please note that the law may exempt or exclude some or all of such rights from applying to you, depending upon the context in which you provide personal information to us. Accordingly, it is possible that some or all of the rights discussed in this section of the Privacy Policy may not apply to you. To the extent such rights apply to you under applicable law, this section describes your rights and explains how to exercise those rights.

Your Rights Under the GDPR (if applicable).

Right to Access The right to be provided with a copy of your personal information (the right of access)
Right to Rectification The right to require us to correct any mistakes in your personal information
Right to be Forgotten The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability The right to receive the personal information you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object The right to object:
⎯ at any time to your personal information being processed for direct marketing (including profiling);
⎯ in certain other situations to our continued processing of your personal information, e.g., processing carried out for the purpose of our legitimate interests.
Right Not to be Subject to Automated Individual Decision-Making

The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner’s Office (ICO) on individual rights under the General Data Protection Regulation.

Your Rights Under the CCPA (if applicable). You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You You have the right to know:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information is collected;
  • Our business or commercial purpose for collecting or selling personal information;
  • The categories of third parties with whom we share personal information, if any; and
  • The specific pieces of personal information we have collected about you.
  • Please note that we are not required to:
  • Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;
  • Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; or
  • Provide the personal information to you more than twice in a 12-month period.
Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and

The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale or disclosure of your personal information. If you exercise your right to opt-out of the sale or disclosure of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale or disclosure of your personal information, visit our homepage at https://www.neosystemscorp.com/ and click on the Do Not Sell My Personal Information link.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.

Please note that we may not delete your personal information if it is necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things:

  • Deny goods or services to you;
  • Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Provide a different level or quality of goods or services to you; or
  • Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

13. Third Party Websites. Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this Privacy Policy. You should exercise caution and look at the privacy statement applicable to the website in question.

14. Keeping Your Personal Information Secure. We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We periodically test our systems and our security and privacy practices are subject to third party audit, which means we follow strict standards for information security. However, no method of transmission over the Internet, or method of electronic storage is one hundred percent secure and we cannot guarantee its absolute security. We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a data security breach where we are legally required to do so.

15. How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, please:

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly through our website, via email, or by phone, you will need to provide us with:

  • Enough information to identify you (e.g., your full name, address and other contact information we may request);
  • Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
  • A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

16. How to File a Complaint. We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred. You are entitled to file any claim or complaint before the relevant data protection authorities if the answer provided by NeoSystems does not meet your expectations.

17. How to Contact Us. Please contact us by email, telephone or through our Site if you have any questions about this privacy policy or the information we hold about you.
Details for contacting us are shown below:

18. Do You Need Extra Help? If you would like this notice in another format (for example: audio, large print, braille) please contact us (see “How to contact us” above).

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