neutrino8 Privacy Notice

We updated the neutrino8 Privacy Notice on August 12th , 2020

neutrino8, Inc. and its worldwide subsidiaries are committed to protecting your privacy. This Privacy Notice (“Notice”), (collectively “neutrino8”, “us”, “we”, “our”) explains our privacy practices and provides information on how and why we collect, use and share your personal data through our interaction with you and through our products and services when you visit our websites www.neutrino8.com and the other sites operated by neutrino8 and its subsidiaries, collectively, the “Website”), or use our cloud orchestration platform (“Services”) and mobile applications (“Apps”). The policy also describes your choices regarding use, access, deletion and correction of your personal information. This Notice may be updated periodically. If we plan to make any material changes to the way we handle personal data as described here, we will notify you by posting an updated version of this Notice on our website.

neutrino8’s Privacy Notice applies to Customers’ data and information (including Customer’s End Users) and Users (all other individuals who use the neutrino8 services, products or website) that they provide directly to us when they use our Website, Apps, or Services. If you have any questions or concerns about our use of your personal information, please contact us using the contact details provided at the bottom of this Notice.
This Notice applies to the personal data we process as a data controller, that is, as the party that determines what data to collect and why. When you use neutrino8’s Services and Apps through a neutrino8 account holder, such as your employer, the processing of your personal data is determined and administered by that account holder under its privacy policies. When you use neutrino8’s Services and Apps through a neutrino8 account holder, such as your employer, and if you have questions about how and why your personal data is collected, the legal basis for processing, or requests regarding your personal data, please refer to the account holder’s privacy statement and direct your inquiries to the account holder or its administrator.

QUICK LINKS

We recommend that you read this Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Notice, then you can click on the relevant link below to jump to that section.

INFORMATION WE COLLECT

You provide some of this information we collect directly, and we get some of it by collecting data about your interactions, use, and experiences with our Website, Apps, and Services. The data we collect depends on the context of your interactions with neutrino8 and the choices you make, including the products and features you use. We may also obtain data about you from third parties. In some countries, including in the European Economic Area, this information may be considered personal data under applicable data protection laws, including the EU’s General Data Protection Regulation (“GDPR”). The personal information that we may collect about you broadly falls into the following categories:

Information which you provide to us

Certain parts of our Website and Services may ask you to provide certain personal information. The personal information that you are asked to provide and the reasons you are asked to provide it are described below in the Information We Use section.

We collect information which you provide directly to us when you use our Website, Apps or Services. The types of personal information we may collect directly from you include email addresses, postal addresses, phone numbers, employee names, usernames, information about the type of service required, marketing preferences, job titles, credit card payment information, transactional information (including Services purchased), as well as any communications, inquiries, contact or other information you choose to provide during your use of the Services.

When you provide this personal information, we will only use this information for the specific reason for which it is provided. If you believe that one of your contacts has provided us with your personal information and you would like to request that it be removed from our database, please contact us at privacy@neutrino8.com.

Information we collect automatically when you use our Services or Apps or visit our Website

When you use our Services or Apps or visit our Website, we may collect certain information automatically from your device.

We keep track of the general surrounding wireless environment and of your wireless device’s activity in relation to the surrounding wireless environment the Services or Apps or the website, and collect data associated with your device’s interaction with the surrounding wireless environment, the Services, Apps or the Website. For example, when you use our Services, we may collect:

  1. Data specific to the wireless network infrastructure, your device’s interaction with the network and your device’s interaction with the Services and Apps, to enable us to deliver to you, other users and devices on the network an optimum, secure and reliable quality of experience;
  2. Logged data may include but not be limited to wireless signal strengths, data transfer speeds, bandwidth utilization, location data, RF channels, signal interference, device type, operating system information, connection status, duration and roaming, Internet Service Provider ("ISP"), pages, graphics, screens and other content accessed on the neutrino8 Services, Apps and Website;
  3. Device data about any device using the neutrino8 Services, Apps and the Website, including mobile phone number and other information related to mobile devices like operating system and model if you use our Services via our Apps. For other devices information collected by cookies and other similar technologies, We use various technologies to collect information which may include saving cookies to your devices;
  4. Meta data, which is data created about other data which can include size, formatting, other characteristics of a data item;
  5. Emails/Communications with us; and
  6. Billing data, which includes any payment data;
  7. Cookies and other similar technologies – We use various technologies to collect information which may include cookies when you visit our Website or use our Apps or Services;

Information we collect from third parties

We may collect the names, e-mail addresses, postal addresses and city of residence of individuals from third parties to market our products and services to these individuals. This collection of information and marketing is always carried out in compliance with applicable law. We only receive this information where these third parties either have your consent or these third parties are otherwise legally permitted or required to disclose your personal information to us.

We may receive personal information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you, in accordance with applicable laws. This helps us to update, expand and analyze our records, identify new potential prospects for our services, and provide products and services that may be of interest to you.

We may collect personal information about you from other applications you may use if you choose to integrate neutrino8 Apps or Services with other Apps or Services.

INFORMATION WE USE

Use of Information

We may use the information we collect from you for a range of purposes, including to:

  • Administer, operate, deliver Services and protect and maintain the Services, Apps and Website;
  • Manage and improve your use of the Services, Apps and Website;
  • To help personalize your quality of experience;
  • Investigate and prevent fraudulent activities, unauthorized access to the Website, Apps or Services, and other illegal activities; and
  • Send you technical alerts, updates, security notifications, and administrative communications.
  • To help deliver our Services Apps and Website to Customers for service and support;
  • Respond to inquiries and requests and to provide you with information and access to resources that you have requested;
  • Aggregate and analyze your use of the Services, Apps and Website for trend monitoring, marketing and promotional purposes; and
  • Process and complete transactions, and send related information, including transaction confirmations and invoices;
  • Prepare and provide you testimonials regarding the Website, Apps and / or Services;
  • For any other purposes about which we notify and receive your consent from you;

We and our third-party marketing service providers may also use the information Customers send to us for our marketing purposes, if this is in accordance with your marketing preferences and applicable law. However, you may opt out of our marketing by sending your request to feedback@neutrino8.com.

Legal basis for processing personal information (EEA only)

If you are from the European Economic Area (EEA), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect the personal information in question.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the "Contact Us" section below.

SHARING AND DISCLOSURE OF INFORMATION TO THIRD PARTIES

We will not rent or sell personal information about you. We may share and disclose your information that we collect with the following third parties:

  • neutrino8 or any of its worldwide affiliates consistent with this Notice for data processing;
  • Business partners, contractors, vendors, and authorized third party agents, to:
    • Operate, deliver, improve and customize the Services, Apps and Website, including services and Apps provided by our business partners and included in the Services;
    • Provide support and technical services;
    • Send marketing and other operational communications related to our Services;
    • Enforce our accept able use policy;
    • Law enforcement agencies, regulatory or governmental bodies, or other third parties in order to respond to legal process, comply with any legal obligation; protect or defend our rights, interests or property or that of third parties; prevent or investigate wrongdoing in connection with the Website, Apps or our Services;
    • Any third parties in connection with prospective or actual, sale, merger, acquisition, financing or reorganization of our business.

Note that, for California residents, we define “sale” and “personal information” in accordance with applicable California law.

YOUR PRIVACY RIGHTS

Right to Correct or Update Your Information

Where we process personal information collected via our Website, Services and/or Apps for our own account management, billing or marketing purposes and where required by applicable law, we provide individuals with the opportunity to access, review, modify, and delete any such personal information that we process.

If you would like to correct or update information that you have provided to us, please contact us at privacy@neutrino8.com.

Requests from End Users

If you believe neutrino8 may have collected or stored personal information from you on behalf of a neutrino customer, please contact the neutrino8 customer with any requests related to your personal information.

Marketing Communications

You may receive marketing email communications from us where permissible. If you would like to stop receiving these communications, you may at any time ask us to remove you from our mailing list by sending us an email at feedback@neutrino8.com or by clicking “Unsubscribe” in any e-mail communications or push notification we send you. We will remove you from our mailing list in accordance with applicable laws.

To request that your phone number be removed from future sales calls, please email us at feedback@neutrino8.com.

Your Privacy Rights as an EEA Person

If you reside in the European Economic Area, you may have the right to exercise certain privacy rights available to you under applicable laws. We will process your request in accordance with applicable data protection laws. We may need to retain certain information for record-keeping purposes or to complete transactions that you began prior to requesting any deletion.

  • Right not to provide consent or to withdraw consent. We may seek to rely on your consent in order to process certain personal data. Where we do so, you have the right not to provide your consent or to withdraw your consent at any time. This does not affect the lawfulness of the processing based on consent before its withdrawal.
  • Right of access and/or portability. You may have the right to access the personal data that we hold about you and, in some limited circumstances, have that data provided to you so that you can provide or “port” that data to another provider.
  • Right of erasure. In certain circumstances, you may have the right to the erasure of personal data that we hold about you (for example if it is no longer necessary for the purposes for which it was originally collected).
  • Right to object to processing. You may have the right to request that neutrino8 stop processing your personal data and/or to stop sending you marketing communications.
  • Right to rectification. You may have the right to require us to correct any inaccurate or incomplete personal information.
  • Right to restrict processing. You may have the right to request that we restrict processing of your personal data in certain circumstances (for example, where you believe that the personal data we hold about you is not accurate or lawfully held).
  • Right to lodge a complaint to your local Data Protection Authority. If you are an EEA resident, you have the right to complain to a data protection authority about our collection and use of your personal data.

To make such requests, you can send an email to privacy@neutrino8.com or write to us at the mailing address in the “Contact Us” section below. We will consider and handle all requests in accordance with applicable laws. Please identify yourself and specify your request. If you have a password protected neutrino8 account, we will use your account information to verify your identity. If not, we will ask you to provide additional verification information. What we request will depend on the nature of your request, how sensitive the information is, and how harmful unauthorized disclosure or deletion would be.

We use commercially reasonable efforts to delete your personal data as required but retain records necessary to comply with a governmental authority or applicable federal, state, or local law. Where legally permitted, we may decline to process requests, including requests that are unreasonably repetitive or systematic, require disproportionate technical effort, or jeopardize the privacy of others.

Your Privacy Rights as a California Resident

Description of Your Rights

If you are a California resident and receive neutrino8 Services or visit our Website or Apps, you have certain rights under the California Consumer Privacy Act of 2018 (“CCPA”). This Statement also explains California residents’ rights under the CCPA and California Civil Code section 1798.83 (the “Shine the Light law”). For the purposes of this description of California privacy rights, unless a different definition is noted, "Personal Information" has the definition given in the CCPA. However, this Statement does not apply to (a) Information exempted from the scope of the CCPA; (b) Personal Information we collect from individuals acting in their capacities as representatives of organizations solely in the context of conducting due diligence regarding, or providing or receiving a product or service to or from, such organizations; or (c) Personal Information we collect, use, and share on behalf of our customers as a "service provider" under the CCPA for purposes of providing our services to them.

Under the CCPA, You can request the following information about how we have collected and used your Personal Information during the past 12 months:

  • The categories of Personal Information we have collected.
  • The categories of sources from which we collected the Personal Information.
  • The business or commercial purpose for collecting and/or selling Personal Information.
  • The categories of third parties with whom we share the Personal Information.
  • The categories of Personal Information that we sold or disclosed for a business purpose.
  • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

How to Exercise Your Rights

You may submit requests to exercise your California privacy rights described above as follows:

  • Right to information, access, and deletion. If you are a California resident, you may submit a request to exercise your information, access, and deletion rights by emailing privacy@neutrino.com.
  • Right to opt-out of the “sale” of your Personal Information. We do not sell your personal information in the conventional sense. However, like many companies, we use advertising services that try to tailor online ads or promotions to your interests based on information collected via cookies and similar technologies about your online activity. This is called interest-based advertising. The CCPA’s statutory definition of the term “sale” is broad and may include interest-based advertising. You can get more information and opt-out of the use of cookies on our sites for interest-based advertising purposes by clicking the Do Not Sell My Personal Information link on our homepage and setting your preferences. You will need to set your preferences from each device and each web browser from which you wish to opt-out. This feature uses a cookie to remember your preference, so if you clear all cookies from your browser, you will need to re-set your settings.

These rights are not absolute, and in some instances, we may decline your request as permitted by law. We will need to verify your identity to process your information, access, and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require you to log into your neutrino8 account (if applicable), provide government identification, give a declaration as to your identity under penalty of perjury, and/or provide additional information.

Your authorized agent may make a request on your behalf upon our verification of the agent's identity and our receipt of a copy of the valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity and provide us with written confirmation that you have given the authorized agent permission to submit the request.

Our Personal Information Collection and Use Practices

Categories.

The categories of Personal Information we collect are described below by reference to the statutory categories of Personal Information specified in the CCPA (California Civil Code section 1798.140):

  • Identifiers, such as name, email address, postal address, username, password, IP address, and other online identifiers.
  • Sensory information, such as call and video recordings and profile photos.
  • California customer records (as defined in California Civil Code § 1798.80), such as contact details and communications we collect through our support channels, marketing webpages, social media, at our events, and connected with our other marketing activities.
  • Commercial information, such as billing and transaction information and purchase history.
  • Internet or network activity information, such as information generated from interactions with our online services, such as data collected through server logs and cookies and similar technologies.
  • Geolocation, such as your city or other general location.
  • Professional or employment-related information, such as current or prior organizational affiliation, job title, information about your role, and work-related contact details.
  • Education information, such as student records and directory information.
  • Inferences that we derive from the preceding or other information we collect.

Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described above.

Sources. Internet/network activity information, geolocation, IP address, and other online identifiers are collected automatically through your use of our online services. We may collect some professional information, and California customer records information from our affiliates, third party data providers, or publicly available sources.

Disclosures to third parties for business purposes. We describe the categories of third parties to whom we disclose Personal Information described above for business purposes in the section of our Privacy Notice entitled “Sharing And Disclosure of Information to Third Parties”.

Business/commercial purposes for use. We describe above in this Privacy Notice the business and commercial purposes for which we use the Personal Information.

This section describes our practices currently and during the 12 months preceding the "Last Updated" date at the top of this Notice.

California Shine the Light Law

Under California’s Shine the Light law, you may also ask companies with whom you have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes and the categories of personal information disclosed. You may send us requests for this information to privacy@neutrino8.com . In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

THIRD-PARTY SITES

This Notice does not apply to, nor are we responsible for, the privacy, information or other practices of any third parties, including any third party operating any site or service to which the Website links including but not limited to social media sites. The inclusion of a link on the Website does not imply our endorsement of the linked site or service. You should check the privacy notices of those sites before providing your personal information to them.

BLOGS AND FORUMS

Our Website may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas will be public and may be read, collected, and used by others who access them and may remain on the public forum indefinitely. To request removal of your personal information from our blog or community forum, contact us at privacy@neutrino8.com. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. We encourage all Users to exercise caution when providing personal information in blogs and community forums.

SECURITY

Keeping your information secure is important to us. We maintain a variety of appropriate technical and organizational safeguards to protect your personal information both during transmission and once it is received. neutrino8 has no control over or responsibility for the security or privacy policies or practices of other sites on the Internet you might visit, interact with, or from which you might buy products or Services, even if you visit them using links from our Website.

Please note that no website, mobile app or service is completely secure and so, while we endeavor to protect our Customers' information using the measures described above, we cannot guarantee that unauthorized access, hacking, data loss or a data breach will not occur.

DATA RETENTION

We will retain your personal information for no longer than is necessary to fulfill the purposes for which the information was originally collected unless a longer retention period is required or permitted by law, for legal, tax or regulatory reasons, or other legitimate and lawful business purposes.

Where we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it.

INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. Specifically, information collected outside the United States, including in the European Economic Area (“EEA”), may be transferred to and stored on cloud servers our services operate from. These cloud servers may be located in European Union countries such as Ireland and Germany, in the United States and in Asia such as Singapore and South Korea. , and potentially in other countries where neutrino8 and our third-party service providers and partners operate. These countries may have data protection laws that are different to the laws in your country (and in some cases, may not be as protective).

However, we have taken appropriate safeguards to ensure that your personal information will remain protected in accordance with this Notice and applicable laws. In no event will your personal information be transferred to, and processed in countries except in compliance with applicable law.

CHILDREN'S PRIVACY

neutrino8 does not knowingly allow children under the age of 18 to sign up for their own accounts, provide products or services that are designed for use by children under the age of 18, or knowingly collect personal information from or about children under the age of 18. If you believe that a child under the age of 18 has disclosed personal information to neutrino8, please contact privacy@neutrino8.com.

CONTACT US

If you have any questions or comments about this Privacy Notice, or if you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us. To contact, please e-mail us
at privacy@neutrino8.com or you can write to us at:

neutrino8, Inc.
Attn: Legal Department 3120 Scott Blvd.
Santa Clara, CA 95054

UPDATES TO THIS NOTICE

We may update this Notice from time to time in response to changing legal, technical, or business developments. If we change our Notice, we will post those changes on this page in addition to updating the “Last Updated” date at the top of this Notice. If we make changes, we will notify you more directly, for example by posting a notification or message on the Website or by emailing you prior to such changes taking effect. We encourage you to review this Notice regularly to stay informed of the latest modifications.