At Neone, privacy is always at top of mind. It’s why we created Neone in the first place. Your stuff should stay yours. As such, we endeavor to limit our collection only to what is needed to provide you with our services. This notice applies where, with respect to the personal data of our service users and website visitors, we are acting as a data controller, namely where we determine the purposes and means of the processing of that personal data.
This Privacy Notice is intended to inform you how and when Neone (“we”/”us”/”our”) collects, uses, processes, or discloses your personal information. It is organized by the Fair Information Privacy Principles, with which everyone should become acquainted in today’s big data world.
Collection Limitation Principle
- When you interact with the Neone Services, we may collect information from you. For example, we collect information when you register for the Services, create or modify your profile or account, participate in our online forum, make a purchase, request customer support, communicate with us, or even apply for a job.
- The types of information we collect depend on the Service. For example, if you register for the Neone Service, we may collect certain information:
- Identifying information: such as your email address so that we can communicate with you and provide you a username, your phone number for password resets, and your device ID so that we may send you push notifications.
- Protected Classification: You control the content you upload to the Neone Service. Please remember that this content could allow your connections to infer information like your race, gender, or ethnicity. You also control the content of your profile page (for example, your profile photo and username), which is available to your both your connections and their connections (friend of a friend).
- Audio/Video: If you choose to use the feature, your audio or video recordings can be uploaded to Neone Services.
- Geolocation: Neone does not collect location information. Photos you upload, however, may include geolocation information embedded in the photo’s metadata. Neone does no scanning on files, but we do not strip out the metadata, so the metadata could be seen by your connections who view your photo. Operating systems like iOS and Android allow you to switch off geolocation for photos. Third-party apps are available that can remove location data from photos and other files.
- If you participate in our forum, we may ask for your name, email address, device type and operating system, and a question or two about yourself.
- If you apply for a job at Neone, we may collect professional or employment-related information, or education information.
- In limited circumstances, the information of third parties may be collected as well. For example, when you invite friends to the Service, we collect their name and email address in order to send them an invite to join you in Neobase.
- Service Selection: Depending on your subscription, we may collect commercial information, such as the products or services purchased, obtained or considered.
- Log Information: When you access and use the Neone Service, we may receive information that includes your IP address, device ID, and access times. Neone does not log this information, but in order to connect with your device, we use third parties (like your mobile phone carrier) and they may be logging this information. When you access our website, we may log your IP Address, browser type, destination on our site, and time and date of your visit.
- Usage Information: To keep our Services streamlined, we monitor limited user activity and may collect information about the number of connections you have, bandwidth usage, and overall storage size for your account.
- Device Information: When you use Neobase via the mobile app, we collect some information about your device, including device ID, hardware model, mobile operating system and version, and platform information.
- Do Not Track: Neone does not track its customers over time or across third-party websites and therefore does not respond to Do Not Track signals.
We strive to collect as little of your personal data as is needed to provide you with our services.
Although we would prefer not to collect any personal information, we need a few things in order to provide our services to you.
Information You Give Us
Information We Automatically Collect
Purpose Specification and Use Limitation Principles
- To provide you with the Services as you would expect
- To communicate with you about the Services you have requested or to respond to a communication by you
- To process payment(s) and communicate with you about purchase confirmations and invoices
- If enabled on your device, to send you push notifications regarding the Services
- Ensure that you are a registered user and eligible to receive customer support
- Inform you of any updates to the Services, technical notices, security alerts, or administrative messages
- Investigate and prevent unauthorized use of the Services, fraudulent transactions, or other illegal activities
- Enable you to invite, communicate with, and share content with other users you designate
- Better understand generalized usage and activity. Neone does not do data mining.
- Communicate with you regarding promotions, events, and other news
- Personalize the Services to match your interests
You deserve to know the purpose for which we collect and use your personal information. Otherwise, how can you determine whether to give your consent? Whenever practical, we let you know the purpose at the time of collection.
In the interest of transparency, we want you to know how your personal information will be used and, if the purpose is not already clear from the context, we will try to explain why we are collecting it before we do so. In addition to the information disclosed in the section above, examples of when we believe the purpose is clear from the context include:
We also may use your information to:
We may also collect and store log information such as your IP address and device ID. This information, stored in log files, is used for security purposes, to improve performance, and for statistical reporting.
Neone does conduct limited aggregate reporting for crash analytics purposes, but we try to keep this to the bare minimum and we do not share this with third parties.
Limited Disclosure Principle
- Where reasonably expected to fulfill the services, provided the third parties themselves are bound to Neone’s privacy and security principles.
- For example, we would share data with third-party cloud services companies to host our services.
- As needed to allow you to connect with third-party applications selected by you. If you choose to connect with said third party applications, we will share certain account information and content directed by you.1
- Compliance with legal process such as laws, regulations, search warrants, subpoenas, court orders, or law enforcement requests
- Resolution of contractual disputes related to your use of the services
- Resolution of issues regarding use of your account for illegal activities
- In connection with, or during negotiations of, any merger,sale of company assets, financing, or acquisition of all or aportion of our company to another entity.
The goal of privacy is to minimize disclosure so that your information is reasonably protected. For that reason, we limit disclosure only to those who legitimately need it to carry out the business purpose, as directed by you, to comply with law, and for other limited reasons described here.
Except as described in this Privacy Notice or in connection with the Services, it is Neone’s policy not to disclose your personal information or content to third parties without your consent. The limited circumstances where disclosure may be warranted include:
1 Please note that this Privacy Notice does not apply to your use of third-party applications and services. For information about how those third parties collect and use your information, please consult their individual privacy notices.
- Where reasonably expected to fulfill the services, provided the third parties themselves are bound to Neone’s privacy and security principles.
We endeavor to make the nature, purpose, and consequences of our collection easy to understand so that your consent is meaningful and freely given.
Meaningful consent is one of the foundations of data privacy. And it can only be meaningful if our users understand to what they are consenting. For that reason, Neone endeavors to explain the “whats, whys, and hows” of our data collection processes and uses in a manner that is user-friendly and generally understandable. If you feel that the consent being asked of you is unclear, we encourage you to reach out to us at firstname.lastname@example.org.
Within bounds of law, we will give you reasonable access to your information.
Upon your reasonable written request, and subject to exceptions as permitted or mandated by law, Neone will inform you of the existence, use, and disclosure of your personal information and will give you access to that information. You may challenge the accuracy and completeness of your information and have it amended as is reasonable and appropriate. Depending on the circumstances, Neone may charge a reasonable fee for the provision of this information.
Neone employs safeguards designed to protect the information in our possession and control. It’s a team effort, and there are ways you can help.
For the purpose of protecting the personal information in our possession and control, Neone employs safeguards appropriate to the sensitivity of the information. One of the ways we do this is by restricting access to internal members of our team, and to third party vendors. We also employ Transport Layer Security 1.2 (TLS1.2) connection encryption for client-to-Neone communication. Of course, no security system is foolproof.
Any company that tells you otherwise is miseducated. But you can help by following some basic security principles, such as:
- Set a strong password – Length is more important than special characters.
- Do not reuse passwords between services.
- Pay attention to what you upload and share. If it is highly sensitive, maybe it is better stored on a local encrypted device rather than on a social media site.
To avoid any adverse impact on our users, we endeavor to ensure your information is accurate.
Within our control, Neone will take reasonable measures to maintain accurate, complete, and up-to-date personal information as identified in this privacy notice to avoid adverse impact on our users. Please let us know if your contact or other personal information changes. To update your personal information, please go to the Neone Client on your device or the Neone website, and edit your subscriber account information.
We may retain your information for a reasonable time to comply with law, for security reasons, or for legitimate purposes.
We hold your data while you remain a subscriber. Regarding your user content, you may export it at any time, and if you choose to leave Neone, we recommend that you do so. In the event that your account is designated as deleted, we will hold your data for around 30 days in the event of malicious deletion or a change of mind. Thereafter, data not required to be maintained for legitimate use or legal reasons will be scheduled for deletion.
We have implemented policies and practices designed to hold Neone accountable for your privacy rights.
Privacy is built into the culture of our company. Our privacy management program tracks the fair information privacy principles and we have designated an individual at Neone responsible for our program and general privacy compliance. You may contact that person at email@example.com.
You have certain privacy rights.
Depending on your state of residence, you may have privacy rights. We believe that all persons should have them. Therefore, we extend these rights to you regardless of where you live in the United States. Your principal rights under data protection law are:
- Right to Notice: You have the right to know the categories of personal information collected, the categories of sources from which data was collected, the business purpose for which your data is collected, the categories of third parties with whom your data is shared, and the specific pieces of personal information collected.
- Right to Access: You have a right to request the categories of personal information collected, the categories of sources from which data was collected, the business purpose for which your data is collected, the categories of third parties with whom your data is shared, and the specific pieces of personal information collected.
- Right to Deletion: With some limited exceptions, you have the right to request that we delete your data. Examples of where we may not be able to comply with such a request are where the information is necessary to comply with law, where it is part of an active investigation, where it is material to litigation, or where it relates to free speech. Information that others have shared about you is not part of your account and will not be deleted.
- Right to Data Portability: To the extent technically feasible, you have the right to take your personal information with you in a readily useable format.
- Right to Equal Services and Prices: Within certain prescribed bounds, you have the right not to be discriminated against because you exercise any of these rights.
- Right to Opt Out of Sale: Neone does not sell your information, so there is nothing to opt out of.
Exercising Your Rights
- Many of these rights may be exercised directly within the services. For example, you may access, delete, and/or download your content from within the Neone app at any time. You may delete your account.
- For inquiries or actions regarding data outside of your content, please submit your request to Neone at firstname.lastname@example.org, or on the web at www.neone.com/privacy or by calling (512) 662-1859.
- Depending on state law, the number of inquiries may be limited. For example, California’s Consumer Privacy Act restrict inquiries to two in a twelve-month period.
- To satisfy an inquiry or request, Neone may need to collect additional information from you in order to comply and/or to verify your identity.
From time to time, we may alter or modify this Privacy Notice as our business matures or technology changes. If this happens, we will do our best to succinctly point out what was changed by including a change log within this Notice, such as the one below. Depending on the change, we may provide you with additional notice through our communication channel with you, or by posting a notification on the Neone application splash screen. If, at any time, you do not wish your personal information to be subject to the terms of this Privacy Notice, you should deactivate your account and stop using the Services. Your continued use of the Services indicates your consent to this Privacy Notice and any changes thereto.
Of course, we do not want you to leave, so if you have any questions, concerns, or recommendations, feel free to email email@example.com. We will do our best to address them in a timely manner. Privacy in an interconnected world is a new and changing landscape; if we all work together, we can find that measured balance.
Effective Date: October 10, 2019
Any modifications to this Privacy Notice will be posted here.