Welcome to the NeuShield Privacy Policy

Privacy and online safety are important to NeuShield Inc. (“NeuShield,” “us,” or “we”). We offer software and services to help protect your data from ransomware and other threats. We collect data about our users and our customers (“Data”) when they use our software (“Product”), our website (“Site”), and our services (collectively, “Services”). This privacy policy describes how we collect, use and disclose information that can be used to identify you (“Personal Data”).

In this privacy policy, we sometimes refer to “you”. “You” may be a visitor to one of our Sites, a user of one or more of our Services (“User”). This Privacy Policy is meant to help you understand what Data we collect, why we collect it, and what we do with it. This is important; we hope you will take time to read it carefully.

Last modified: May 30^th, 2018

1. User Consent

By accessing or using NeuShield Services, you agree to the terms and conditions of this Privacy Policy.

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.

To process Website Usage Data, we use cookies and similar technologies. Click here to review our Cookie Notice.

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.

b. Other Data. We may use Other Data for a range of different purposes, provided we comply with applicable law and our contractual commitments. In some countries (for example, European Economic Area countries), local legal regimes may require us to treat some or all of Other Data as “Personal Data” under applicable data protection laws. Where this is the case, we will process Other Data only for the same purposes as Personal Data under this privacy policy.

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;

d. To Authorized Third Parties. We share data with parties directly authorized by a User to receive Data, such as when a User authorizes a third party application provider to access the User’s NeuShield account using the NeuShield Portal. The use of Data by an authorized third party is subject to the third party’s privacy policy;

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.

Once you leave our store’s Site or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Terms of Service.

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.

7. Security

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 privacy@neushield.com.

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 privacy@neushield.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

We will retain Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Please note that we have a variety of obligations to retain the Data that you provide to us, including to ensure that transactions can be appropriately processed, settled, refunded or charged-back, to help identify fraud and to comply with anti-money laundering and other laws and rules that apply to us and to our financial service providers. Accordingly, even if you close your NeuShield Account, we will retain certain Data to meet our obligations. There may also be residual Data that will remain within our databases and other records, which will not be removed.

10. Information for EU Residents

You are not legally required to provide NeuShield with the Personal Data described in this Privacy Policy. Further, the contractual relationship that you might have entered into with us by purchasing our Services does not imply any obligation to provide your Personal Data. However, you might not be able to use our Services to the full extent if you do not provide us with certain Data or object to the use of these Data.

NeuShield primarily processes Data as a controller under the General Data Protection Regulation (“GDPR”), for the purposes explained above under Sections 4 and 5 of this Privacy Policy. These purposes represent our legitimate interests for the purposes of Article 6 (1) f) GDPR. At the same time, some of the Personal Data we process is necessary for us to perform a contract with you or in order to take steps at your request prior to entering into a contract with you. For example, if you express your interest in purchasing one of our Services, such as by filling out a webform, we will process the Personal Data submitted to comply with your request. This may include sharing your Personal Data with one of our authorized resellers, who will then use your Personal Data to complete the purchase transaction. In addition, we are legally obliged to provide certain information to criminal prosecution or tax authorities in individual cases upon request. In these cases, the legal basis for the processing is either legal requirements (Article 6 (1) c) GDPR) or reasons of public interest (Article 6 (1) e) GDPR).

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.

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 privacy@neushield.com, so that we may immediately delete the information from our servers.

12. Changes to this Privacy Policy

We reserve the right to modify this privacy policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.

13. Contact Information

If you have any questions about this Privacy Policy, please contact us at privacy@neushield.com or at:

NeuShield, Inc.

200 Brown Road,
Suite 306

Fremont, CA, 94539