Last modified: May 30th, 2018
1. User Consent
When you provide us with personal information to complete a transaction, verify your credit card or place an order, we imply that you consent to our collecting it and using it for that specific reason only.
If we ask for your personal information for a secondary reason, like marketing or support, we will either ask you directly for your expressed consent, or provide you with an opportunity to say no.
2. Collection of Data
Depending on how you interact with us, we process different kinds of Data and in different ways. Some Data is automatically processed if you visit our Site or use our Services. Other Data is only processed if you actively submit it to us (like using our web forms to get in touch with us or uploading content from our Services).
Even if you are only a visitor on our Site, your computer or device automatically sends technical information to our web servers that we store in log files, including the following “Website Usage Data”:
- Date and time of the visit and the duration of use of the Site;
- The IP address of your device as well as your internet service provider (ISP);
- The referral/exit URL;
- The visited subsites of the Site;
- Clickstream Data; and
- Information about your device (type of device, browser type and version, as well as settings, installed plug-ins, operating system).
We process Website Usage Data to allow you to surf the Site and to ensure its functionality. We also process Website Usage Data to perform analyses on the performance of the Site, to continuously improve the user experience of the Site and correct errors, to ensure IT security and operation of our systems, as well as to prevent or uncover abuse.
3. Data We Collect
a. Personal Data. We call Data that identifies, or that could reasonably be used to identify, you as an individual as “Personal Data”. We collect Personal Data in different ways. For example, we collect Personal Data when you register for a NeuShield account or subscribes to our Service. We also receive Personal Data from other sources, such as Google Account, Windows Live and Office 365. Personal Data does not include Data that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person. The Personal Data that we may collect includes:
- Account details, such as name, company name, telephone number, email address;
b. Other Data. We call Data other than Personal Data “Other Data”. We collect Other Data through our Services or our Site. Other Data that we may collect include:
- Device and browser device Data, such as hostname, IP address, Mac address, network card name, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, processor, installed memory, language, plug-ins, add-ons and the version of the Services you are using;
- Transaction Data, such as purchases, purchase amount, date of purchase, and payment method;
- Cookies, used for tracking user logon sessions;
- Product Data, such as protected folder, Product options and alert event logs;
4. How We Use Data
a. Personal Data. We use Personal Data to: (i) provide the Services; (ii) detect and prevent fraud; (iii) mitigate financial loss or other harm to Users or NeuShield; and (iv) promote, analyze and improve our Products, systems, and tools. Examples of how we may use Personal Data include:
- To verify an identity for compliance purposes;
- To evaluate an application to use our Services;
- To conduct manual or systematic monitoring for fraud and other harmful activity;
- To respond to inquiries, send service notices and provide customer support;
- To process a payment with NeuShield Checkout, communicate regarding a payment, and provide related customer service;
- For audits, regulatory purposes, and compliance with industry standards;
- To develop new Products;
- To improve or modify our Services; and
- To conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions, and report on the performance of, our business.
5. How We Disclose Data
We may disclose your personal information if we are required by law to do so or if you violate our Terms of Service. NeuShield does not sell or rent Personal Data to marketers or unaffiliated third parties. We share your Personal Data with trusted third parties, including:
a. Payment Gateway. Because NeuShield uses a payment gateway, such as PayPal, to complete your purchase all credit card Data is handled by this gateway. Credit card Data is not collected or stored by NeuShield directly;
b. To NeuShield Service Providers. We share Data with service providers who help us provide the Services. Service providers help us with things like payment processing (i.e., banks, credit bureaus, payment method providers), website hosting, data analysis, information technology and related infrastructure, customer service, email delivery, and auditing;
c. To Our Users. We share Data with Users (such as merchants and application providers) as necessary to process payments or provide the Services. For example, we share Data with Users about purchases made by their customers through the NeuShield payment processing Services;
e. To Third Parties. We will share Data with third parties in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings); and
f. Safety, Legal Purposes and Law Enforcement. We use and disclose Data as we believe necessary: (i) under applicable law, or payment method rules; (ii) to enforce our terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence.
6. Third-Party Services
In general, the third-party providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located in a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the Services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
When you click on links on our store, they may direct you away from our Site. We are not responsible for the privacy practices of other sites and encourage you to read their privacy statements.
We use reasonable organizational, technical and administrative measures to protect Personal Data within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us immediately at firstname.lastname@example.org.
8. Choice and Access
You have choices regarding our use and disclosure of your Personal Data:
You can access or change your Personal Data. If you would like to review, correct, or update Personal Data that you have previously disclosed to us, you may do so by signing in to your NeuShield account or by contacting us at email@example.com.
If emailing us your request, please make clear in the email what Personal Data you would like to have changed. For your protection, we may only implement requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable.
9. Retention Period
10. Information for EU Residents
NeuShield’s principal place of business is in United States, which is generally not considered to afford the same level of protection that you enjoy in the EU, but NeuShield still provides an adequate level of protection for your Personal Data.
We have ensured that our service providers and affiliates have either certified under the EU-U.S. Privacy Shield Framework and will process all Personal Data received from EU member states in reliance on the Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee that an adequate level of Data protection for your Data is guaranteed.
As a natural person, you have certain rights as (“Data Subject”). You can assert the following rights against us under the GDPR:
Your right to information and access under Article 15 GDPR,
Your right to correction under Article 16 GDPR,
Your right to erasure under Article 17 GDPR,
Your right to restriction of processing under Article 18 GDPR, and
Your right to Data transferability under Article 20 GDPR.
In addition, you have a right of objection to the competent Data protection supervisory authority under Article 77 GDPR, but only with respect to the Data processing we conduct on our own behalf, as a controller. In the event NeuShield acts as a processor of your Data for a third party, you must refer to the entity acting as controller to assert this right.
1. Right of objection in individual cases
In addition to the rights already mentioned, you have the right, for reasons arising from your particular situation, to object at any time to the processing of Personal Data relating to you, which is processed on the basis of Article 6 (1) e) GDPR (Data processing in the public interest) and Article 6 (1) f) GDPR (Data processing on the basis of a balance of interests); this also applies to profiling based on this provision within the meaning of Article 4 (4) GDPR. If you file an objection, we will no longer process your Personal Data unless we can prove compelling grounds for the processing that outweigh your interests, rights and freedoms or the processing serves to assert, exercise, or defend legal claims. Please also note that, if we terminate the processing due to your objection, the Sites or Services may no longer be available to you or only to a limited extent.
2. The right to object to the processing of Data for advertising purposes
You also have the right to object at any time to the processing of your Personal Data for the purpose of direct marketing, including any subscription to our newsletters or personalized ads; this also applies to Profiling, insofar as it is associated with such direct marketing. If you object, we will no longer process your Personal Data in the future.
11. Use of Services by Minors
The Services are not directed to individuals under the age of eighteen (18), and we request that they not provide Personal Data through the Services. If a parent or guardian becomes aware that their child has provided NeuShield with Personal Data or that we have otherwise inadvertently collected this information, contact us at firstname.lastname@example.org, so that we may immediately delete the information from our servers.
13. Contact Information
200 Brown Road,
Fremont, CA, 94539