Technologies Inc and its Group Companies (collectively “Neoxcel”, “Primemove
Technologies”, "we", "us", and "ours") is
committed to protecting your privacy. This Privacy Notice (“Notice”)
describes how Neoxcel processes Personal Data in its capacity as a
controller (i.e. when Neoxcel determines the purposes and means of
the processing of personal data) It also describes your choices and rights
regarding use, access and correction of your Personal Data.
capitalized terms used in this Notice but not defined herein shall have the
same meaning as defined in the Terms of Service at https://neoxcel.com/terms.
DOES THIS NOTICE APPLY TO?
Notice applies to the processing of Personal Data collected by us when you :
- Use our Service(s) whether it is through our web platform or our
mobile applications. This notice is then applicable to our Customers, and
- Visit our websites.
- Visit our Offices.
- Receive communications from us.
- Register for, attend or take part in our events, webinars or
contests hosted by us.
make available for you an online marketplace platform where you can download
applications developed by Neoxcel or by third parties. When applications are
provided by us and the application links to this Notice, the Notice will apply.
When applications are provided by third parties, the privacy statement of the
third party will only apply.
PERSONAL DATA DOES NEOXCEL COLLECT?
Data we collect directly from you (“Collected Data)
Sign-up, billing and Account information.
When you subscribe and sign-up to any of our Service(s), we may collect your
(i) contact information such as name, e-mail address, mailing address, IP
address, geographic location, or phone number of the Account admin; (ii)
billing information, such as credit card number and billing address; (iii) name
and e-mail address when Account admin/Agent(s) provide feedback from within the
Service(s); and (iv) unique identifiers, such as username, account number or
When you apply for an open position by populating the application form, we may
collect your (i) contact information, such as name, email address, mailing
address, phone number, links to your social networking profiles; and (ii) any
other information contained in the resume that you submit to us.
Subject to this Notice, we will use such data to evaluate you for the open
position that you have applied for or any position that we consider you
suitable for at the time you submit your resume or at any later date. Unless
you notify us otherwise by an e-mail to email@example.com, we will retain such
data for a period of 1 year for archival purposes. If you wish to update the
data you provided to us, you may do so by contacting us at firstname.lastname@example.org.
purposes of evaluating you for an open position, you understand that we may
internally rate you based on parsing of your resume and your information. If
you do not wish to be rated by us, please do not provide us your information.
Personal Data provided at Neoxcel Events.
When you attend an event conducted by Neoxcel, including webinars or seminars,
we may collect your contact information such as name, e-mail address, phone
number, designation and company name. If you attend any user conferences hosted
by us at physical location where we serve food and other refreshments, we
collect information about your food preferences and allergies.
4) Program Registrations.
When you register for any of our programs through a registration form on our
Websites, we may collect information such as name, e-mail address, company
name, designation, company website URL, IP address, location and contact
5) Participation to Public forums, Community platform, Forms and
When you visit or register our publicly accessible community forums and blogs
or submit any forms on our Website, you should be aware that any information
you provide in these areas may be read, collected, and used by others who
access them. Further, we may collect your (i) contact information such as name,
e-mail address, mailing address, or phone number; (ii) information about your
business, such as company name, company size, business type; and (iii) a short
bio about you to identify you as the author of the post. When you actively
subscribe to our newsletters, we collect your e-mail address to share our
newsletters with you.
6) Service Data
When you use our services, we process the Service Data as instructed by you in
accordance with the Data Processing Addendum or Data Processing Agreement. We
perform analytics on those data to (i) assess needs of your business to
determine or suggest suitable Service(s); (ii) send you requested information
about the Service(s); (iii) respond to customer service requests, questions and
concerns; and (iv) for product improvement purposes.
Data, and Cookies
We use commonly used tools to automatically collect information that may
contain Personal Data from your computer or mobile device as you our visit our
Websites, use our application or in general our Service(s).
a. Cookies and Similar Technologies.
analyzing trends, administering the Website, tracking users’ movements around
the Webites, and gathering demographic information about our user base as a
whole. We may receive reports based on the use of these technologies by these
companies on an individual and aggregated basis. Most web browsers support
level. Please note that if you choose to disable cookies, it may limit your use
of certain features or functions on our Websites and services.
true of most websites, we gather certain information automatically and store it
in log files. This information may include internet protocol (IP) addresses,
browser type, internet service provider (ISP), referring/exit pages, the files
viewed on our Websites (e.g., HTML pages, graphics, etc.), operating system,
date/time stamp, and/or clickstream data. We link this automatically Collected
data to other data we collect about you.
download, install and use our Mobile Applications, we automatically collect
information on the type of device you use, operating system version, and the
device identifier (or “UDID”).
mobile analytics software to allow Us to better understand the functionality of
our Mobile Software on your phone. This Software may record certain information
such as how often you use the application, the events that occur within the
application, aggregated usage, performance data, and where the application was
downloaded from. We do not link the information we store within the analytics
software to any personal data you submit within the Mobile Applications.
addition to the information mentioned in Clause 7 (a) above that we
automatically collect, we also collect clicks, scrolls, conversion and drop-off
on our Websites and Service(s) to render user journey at real-time. Subject to
this Notice, we will use such data and Service Data, including without
limitation, to (i) assess needs of your business to determine or suggest
suitable Service(s); (ii) send you requested information about the Service(s);
(iii) respond to customer service requests, questions and concerns; and (iv)
for any analytical purposes.
log in to our Websites using sign-in services such as Google, Facebook Connect
and LinkedIn. These services will authenticate your identity and provide you
the option to share certain Personal Data with us such as your name and
e-mail address. Services like Google, Facebook Connect, Twitter, LinkedIn give
you the option to post information about your activities on our Websites to
your profile page and to share information with others within your network.
media features and third party cookies
Websites includes social media features, such as the Facebook “Like” button,
the “Share This” button or interactive mini-programs. Where you interact with
these features, they may collect your IP address, which page you are visiting
on our Websites, and may set a cookie to enable the feature to function
properly. Social media features and widgets are either hosted by a third party
or hosted directly on our Websites. Your interactions with these features are
governed by the privacy notice of the company providing them.
provide us or our service providers with any Personal Data relating to other
individuals, including End-User data or your employee’s data, you represent
that you have the authority to do so and acknowledge that it will be used in
accordance with this Privacy Statement.
that we collect from third party
time to time, we may receive personal information about you from third party
sources like databases and social media but only where we have checked that
these third parties either have your consent or are otherwise legally permitted
or required to disclose your personal information to us.
types of information we obtain from such third parties include your name,
e-mail address, postal address, location, designation, telephone number and we
use the information we receive from these third parties to maintain and improve
customer support experience, improve the accuracy of the records we hold about
you and for our sales and marketing purposes.
DO WE PROCESS PERSONAL DATA AND WHAT ARE THE LEGAL BASES WE RELY ON ?
collect and process your Personal Data for the following purposes:
- Providing you with the Service(s), administer your account, assess
the needs of your business to or suggest suitable Service(s) and respond
to service requests, questions or concerns: we process your Personal Data
for these purposes to perform our contract with you or based on our
- Based on our Legitimate Interest : to perform analytics, train our
algorithms, improve, enhance, develop, support and operate the Services
and its availability, compile statistical reports and record insights into
usage patterns, develop new products and services using machine learning
technologies and more generally to better serve you and be able to
provide you with customized content and features.
- Based on our Legitimate Interest or on your Consent : to send you
promotional and marketing communications); to send you communication from
the Services (s). On the mobile app : to send receiving push notifications
about any events or promotions that we may be running and/or update you
about new features to our Service(s); If you no longer wish to receive
these communications, you can opt out by following the instructions set
out in clause 9 below.
- facilitate your transactions with other users when you use our
- Based on our legitimate interest: to prevent or respond to any
misuse of our Services or Applications or any violations of our Terms and
any applicable laws.
- Based on your consent : we may post your
testimonials/comments/reviews on our Websites which may contain your
Personal Data. Prior to posting the testimonial, we will obtain your
consent to post your name along with the testimonial. If you want your
testimonial to be removed, please contact us at email@example.com.
- To send you communications related to an event or a webinar to
which you registered. We process your Personal Data for this purpose to
perform our contract with you or based on our Legitimate Interest.
- Based on our contract with you: we will process your personal data
to the extent necessary to collect your subscription fees.
- To respond to lawful requests by public authorities, including
meeting national security or law enforcement requirements and when we
believe that disclosure is necessary to protect our rights and/or to comply
with a judicial proceeding, court order, police request or other legal
process served on us.
WITH WHOM DO WE SHARE PERSONAL DATA
process Personal Data in the United States and the European Economic Area (“EEA”)
and in other countries through third parties that we may use. You may refer to
the page here for more information on hosting options.
also share your Personal Data as follows:
- With third party assisting Neoxcel in providing you the Service(s)
(“Sub-Processors" listed here).
Our Sub-Processors are given access to Customer’s Account and Service Data
only as reasonably necessary to provide the Service(s) and will be subject
to confidentiality obligations in their service agreements;
- With third party service providers providing services, such as
research and analytics, anti-spamming and anti-phishing services,
marketing and data enrichment or for them to reach out to you on our
- With third-party payment processors who process your credit card
and other payment information for Neoxcel but are otherwise not permitted
to store, retain or use such information;
- With third party partners for the purpose of assisting us in
onboarding you and providing any further support needed to use our
- With sponsors of contests for which you register;
- With third-party social media networks, advertising networks and
- With affiliates within Neoxcel and companies that we will acquire
in the future when they are made part of the Neoxcel group for customer
support, marketing, technical operations, account management or
organizational purposes and to provide, enhance and improve the
- If we are involved in a merger, reorganization or other fundamental
corporate change with a third party, or sell/buy a business unit to/from a
third party, or if all or a portion of our business, assets or stock are
acquired by a third party, with such third party including at the due
diligence stage. In accordance with applicable laws, we will use
reasonable efforts to notify you of any transfer of Personal Data to
unaffiliated third party.
transfers are covered by the service agreements with the relevant recipients
and we have taken appropriate safeguards to ensure that your Personal Data will
remain protected in accordance with this Privacy Notice. Further details can be
provided upon request.
TRANSFER OF DATA AND PRIVACY SHIELD COMPLIANCE
share your Personal data with our affiliates. The addresses of our affiliates
can be found here. Any transfers of Personal Data under this
Data Privacy Addendum from the European Union, the European Economic Area
and/or their member states, Switzerland and the United Kingdom to countries
which do not ensure an adequate level of data protection within the meaning of
Data Protection Laws and Regulations of the foregoing territories, is to be
made based on the Standard Contractual Clauses set forth in appendix to
this addendum. Neoxcel further commits to cooperate with EU data protection
authorities (DPAs) and the Swiss Federal Data Protection and Information
Commissioner (FDPIC) and comply with the advice given by such authorities with
regard to human resources data transferred from the EU and Switzerland in the
context of the employment relationship. With respect to Personal Data received
or transferred to the United States, Primemove Technologies Inc is subject to
the regulatory enforcement powers of the U.S. Federal Trade Commission. In
certain situations, Primemove Technologies Inc and/or its Group Companies may
be required to disclose Personal Data in response to lawful requests by public
authorities, including to meet national security or law enforcement
requirements. If you have an unresolved privacy or data use concern that we
have not addressed satisfactorily, please contact our U.S.-based third party
dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.
DOES NEOXCEL KEEP PERSONAL DATA SECURE?
appropriate technical and organizational measures to protect the Personal Data
that we collect and process. The measures we use are designed to provide a
level of security appropriate to the risk of processing your Personal Data.
information security risks are always evolving, so are the controls. The
controls, so implemented, are periodically reviewed as part of internal and
external audits. If you have questions about the security of your Personal
Data, please contact us immediately as described in this Privacy Notice.
AND SWISS SPECIFIC RIGHTS
are an individual resident in EEA or Switzerland, you have the following data
protection rights regarding Collected Data:
- If you wish to access, correct, update or request deletion of
your Personal Data, you can do so at any time by contacting us.
- You can object to processing of your Personal
Data, ask us to restrict processing of your Personal Data
or request portability of your Personal Data. Again, you
can exercise these rights by contacting us.
- You have the right to opt-out of marketing communications we
send you at any time. You can exercise this right by clicking on the
“unsubscribe” or “opt-out” link in the marketing e-mails we send you. To
opt-out of other forms of marketing (such as postal marketing or
telemarketing), please contact us.
- Similarly, if we have collected and process your Personal Data with
your consent, then you can withdraw your consent at any
time. Withdrawing your consent will not affect the lawfulness of any
processing we conducted prior to your withdrawal, nor will it affect
processing of your Personal Data conducted in reliance on lawful
processing grounds other than consent.
- You have the right to complain to a data protection
authority about our collection and use of your Personal Data. For
more information, please contact your local data protection authority.
seek access to, or wish to correct, update, modify or delete Personal Data
(hereinafter referred to as a “Request”) which forms a part of
Collected Data, please contact us at firstname.lastname@example.org. We respond to all
requests we receive from individuals wishing to exercise their data protection
rights within a reasonable timeframe in accordance with applicable data
acknowledge that you have the right to access your Personal Data. Neoxcel has
no direct relationship with the individuals whose Personal Data it processes.
If you seek access to, or wish to correct, update, modify or delete Personal
Data (hereinafter referred to as a “Request”) which is part of the
Service Data and processed by us on behalf of our Customer or if you are an
End-User of one of our Customers and would no longer like to be contacted by
one of our Customers that uses our Service(s), you should direct your query to
our Customer i.e, the controller. if requested to remove data, We will respond
within a reasonable timeframe.
are a Customer of our Service(s) and wish to raise a Request on behalf of your
Users and End-Users in connection with Service Data, you may raise a ticket on
the support portal of the relevant Service. Please note that if a Customer has
subscribed to more than one Service, a Request on a particular Service support
portal is specific to that Service only and separate Requests need to be raised
across other relevant Service support portals.
extent you are a 'consumer' as defined under the California Consumer Privacy
Act of 2018 ("CCPA") and Neoxcel is a 'business' as defined under
CCPA, the following applies to you:
to the provisions of the CCPA, you have the right to request in the manner
provided herein, for the following:
to request for information about the:
- Categories of Personal Data Neoxcel has collected about you.
- Specific pieces of Personal Data Neoxcel has collected about you.
- Categories of sources from which the Personal Data is collected.
- Business or commercial purpose for collecting Personal Data.
- Categories of third parties with whom the business shares Personal
to request for deletion of any Personal Data collected about you by Neoxcel.
seek to exercise the foregoing rights to access or delete Personal Data which
constitutes 'personal information' as defined in CCPA, please contact us
at email@example.com. We respond to all requests we receive from you
wishing to exercise your data protection rights within a reasonable timeframe
in accordance with applicable data protection laws. By writing to us, you agree
to receive communication from us seeking information from you in order to
verify you to be the consumer from whom we have collected the Personal Data
from and such other information as reasonably required to enable us to honour
of categories of Personal Data collected and disclosed about consumers are
enlisted under the head 'WHAT PERSONAL DATA DOES NEOXCEL COLLECT?'' and the
list of categories of third parties to whom the Personal Data was or may
be disclosed are enlisted under the head 'WITH WHOM DO WE SHARE PERSONAL DATA?'. Separately, Neoxcel does not sell your Personal Data.
Geral de Proteção de Dados (LGPD) is a Brazilian data
protection law that provides data rights for individuals and introduces
compliance responsibilities for organizations such as Neoxcel.
The LGPD grants Brazil residents greater control over
their personal data and gives national regulators new powers to impose
significant fines on organizations that breach this law. The LGPD creates
rights and protections similar to those created for European
residents by the GDPR. At Neoxcel we take a global approach
to ensure all members benefit from increased control and clarity, which is
in line with our commitment to putting our Customers first and working every
day to maintain the trust they put in us.
are a Brazilian national you have rights under the LGPD, including the right
to take the following actions:
- Access your personal data
- Correct errors in your personal data
- Erase your personal data
- Object to the processing of your personal data
- Export your personal data
a request regarding your personal data please click here
OPTING OUT PROCEDURE
no longer wish to receive marketing communications from Neoxcel, you may click
on the “unsubscribe” link located on the bottom of our marketing emails or you
can contact us at firstname.lastname@example.org. When using our Mobile Applications, you also have
the option to turn off push notifications.
would like to object to the use of your personal data for analytics, you can
contact us at email@example.com
are our Customer, we will send you announcements (email or in product
notifications related to the Service(s) on occasions when it is necessary to do
so. For instance, if our Service(s) is temporarily suspended for maintenance,
we might send you an e-mail. Generally, you may not opt-out of communications
which are not promotional in nature. If you do not wish to receive them, you
may deactivate your Account.
RETENTION OF PERSONAL DATA
wish to request that we no longer use your Collected Data, please contact us
Data contained in the Service Data is retained and deleted in accordance with
the foregoing, we will retain Collected Data and Service Data as necessary to
comply with our legal obligations, for litigation/defense purposes, maintain
accurate financial and other records, resolve disputes, and enforce our
TO THIRD PARTY SITES
Websites contain links to other websites that are not owned or controlled by Neoxcel.
Please be aware that we are not responsible for the privacy practices of such
other websites or third parties. We encourage you to be aware when you leave
our Websites and to read the privacy policies of each and every website that
collects Personal Data.
14. GOOGLE API DISCLOSURE
has developed a functionality that allows its customers to connect their Gmail
mailbox using Oauth with our products. Connection your Gmail mailbox to
your Neoxcel account allows Neoxcel to associate your account with your
personal information on Google, to see your personal information,
including any personal information you have made available, to view your
email address and access your emails in order to create them as a ticket in our
products. The connection will further allow you to respond to your
emails directly from our product and to delete them once they are fetched into
use of information received from Google APIs will adhere
to Google API Services
User Data Policy's App's,
including the Limited Use requirement.
does not knowingly collect any Personal Data from children under the age of 16.
If you are under the age of 16, please do not submit any Personal Data through
our Websites or Service(s). We encourage parents and legal guardians to monitor
their children’s Internet usage and to help enforce this Notice by instructing
their children never to provide Personal Data through our Service(s) or
Websites without their permission. If you have reason to believe that a child
under the age of 16 has provided Personal Data to us through our Websites or
Service(s), please contact us and we will endeavour to delete that information
and terminate the child's account from our databases.
to this Notice will be posted to this URL and will be effective when posted. If
we make any material changes, we will notify you by means of a conspicuous
notice on this Website or via e-mail or via in-product notification. We
will not be notifying you if we amend the Notice to make addition, deletions or
modifications to the list of cookies from time to time to keep the list of
cookies current and accurate. You should frequently visit this Notice to stay
fully informed. Your continued use of our Websites or the Service(s) following
the posting of any amendment, modification, or change to this Notice shall
constitute your acceptance of the amendments to this Notice. You can choose to
discontinue use of the Websites or Service(s), if you do not accept the terms
of this Notice, or any modified version of this Notice.
EFFECT OF MERGER OR ACQUISITION
event Neoxcel goes through a business transition, such as a merger or
acquisition by another company, or sale of all or a portion of its assets,
Customer’s Account, Collected Data and Service Data will likely be among the
assets transferred. A prominent notice will be displayed on our Websites to
intimate you of any such change in ownership or control and Customers will be
notified via an e-mail from firstname.lastname@example.org.
If you have
any questions about this privacy notice or our privacy practices, you can
contact us at email@example.com.