PRIVACY NOTICE
Last updated April 07, 2021
Thank you for
choosing to be part of our community at Neunie Ltd
, doing business as
Neunie
("
Neunie
",
"we", "us", "our"). We are committed to protecting your
personal information and your right to privacy. If you have any questions or concerns about this privacy
notice, or our practices with regards to your personal information, please contact us at keston@neunie.com .
When you
use our mobile application,
as the case may be (the "App")
and more generally, use any of our services (the "Services",
which include the
App
), we appreciate that you are
trusting us with your personal information. We take your privacy very seriously. In this privacy notice, we
seek to explain to you in the clearest way possible what information we collect, how we use it and what
rights you have in relation to it. We hope you take some time to read through it carefully, as it is
important. If there are any terms in this privacy notice that you do not agree with, please discontinue use
of our Services immediately.
This privacy notice applies to
all information collected through our Services (which, as described above, includes
our
App
), as well as, any related
services, sales, marketing or events.
Please read this privacy
notice carefully as it will help you understand what we do with the information that we
collect.
TABLE OF
CONTENTS
1. WHAT INFORMATION
DO WE COLLECT?
Personal information you disclose to us
In
Short: We collect personal
information that you provide to
us.
We collect personal
information that you voluntarily provide to us when you
register on the
App,
express an interest in obtaining information
about us or our products and Services, when you participate in activities on the
App
or otherwise when you contact us.
The personal
information that we collect depends on the context of your interactions with us and the
App
, the choices you make and the products and features you use. The personal information we
collect may include the following:
Personal
Information Provided by You. We collect
names ;
email addresses ;
passwords ;
contact preferences ;
gender ;
age ;
and other similar information.
All personal
information that you provide to us must be true, complete and accurate, and you must notify us of
any changes to such personal information.
Information automatically collected
In
Short: Some information — such
as your Internet Protocol (IP) address and/or browser and device characteristics
— is collected automatically when you visit our
App
.
We automatically
collect certain information when you visit, use or navigate the
App
. This information does not reveal your specific identity (like your name or
contact information) but may include device and usage information, such as your IP address, browser
and device characteristics, operating system, language preferences, referring URLs, device name,
country, location, information about how and when you use our
App
and other technical information. This information is primarily needed to maintain
the security and operation of our
App
, and for our internal analytics and reporting purposes.
Like many
businesses, we also collect information through cookies and similar technologies.
The information we
collect includes:
Information collected through our App
-
user counts
Information collected through our App
In
Short: We collect
information regarding your
push notifications,
when you use our
App.
If you
use our App, we also collect the following information:
Account Information
Neunie Ltd
CLEO
NEUNIE
147 Station
Road
London
E4 6AG
United Kingdom
- Push Notifications. We may
request to send you push notifications regarding your account or certain
features of the App. If you wish to opt-out from receiving these types
of communications, you may turn them off in your device's settings.
This information is primarily needed to
maintain the security and operation of our App, for troubleshooting and
for our internal analytics and reporting purposes.
2. HOW DO WE USE YOUR
INFORMATION?
In Short:
We process your information
for purposes based on legitimate business interests,
the fulfillment of our contract with you, compliance
with our legal obligations, and/or your
consent.
We use personal information collected via
our
App
for a variety of business purposes described below.
We process your personal information for these purposes in reliance on
our legitimate business interests, in order to enter into or perform a
contract with you, with your consent, and/or for compliance with our
legal obligations. We indicate the specific processing grounds we rely
on next to each purpose listed below.
We use the information we collect or
receive:
- To facilitate account creation
and logon process. If you choose to link your account
with us to a third-party account (such as your Google or Facebook
account), we use the information you allowed us to collect from
those third parties to facilitate account creation and logon process
for the performance of the contract.
- To post testimonials.
We post testimonials on our
App cleo@neunie.com and be sure to include your name, testimonial location, and contact information.
- Request feedback. We
may use your information to request feedback and to contact you
about your use of our
App
- To enable user-to-user
communications. We may use your information in order to
enable user-to-user communications with each user's consent.
- To manage user
accounts. We may use your information for the purposes
of managing our account and keeping it in working order.
- To send administrative
information to you. We may use your personal
information to send you product, service and new feature information
and/or information about changes to our terms, conditions, and
policies.
- To protect our
Services. We may use your information as part of our
efforts to keep our
App
- To enforce our terms,
conditions and policies for business purposes, to comply with
legal and regulatory requirements or in connection with our
contract.
- To respond to legal
requests and prevent harm. If we receive a subpoena
or other legal request, we may need to inspect the data we hold
to determine how to respond.
- Fulfill and manage your
orders. We may use your information to fulfill and
manage your orders, payments, returns, and exchanges made
through the
App .
- Administer prize draws and
competitions. We may use your information to
administer prize draws and competitions when you elect to
participate in our competitions.
- To deliver and facilitate
delivery of services to the user. We may use your
information to provide you with the requested service.
- To respond to user
inquiries/offer support to users. We may use your
information to respond to your inquiries and solve any potential
issues you might have with the use of our Services.
- For other business
purposes. We may use your information
for other business purposes, such as data analysis,
identifying usage trends, determining the effectiveness of
our promotional campaigns and to evaluate and improve our
App
In
Short: We only share information with
your consent, to comply with laws, to provide you with
services, to protect your rights, or to fulfill business
obligations.
We may process or share your data
that we hold based on the following legal basis:
- Consent: We
may process your data if you have given us specific consent
to use your personal information for a specific
purpose.
- Legitimate
Interests: We may process your data when it is
reasonably necessary to achieve our legitimate business
interests.
- Performance of a
Contract: Where we have entered into a contract
with you, we may process your personal information to
fulfill the terms of our contract.
- Legal
Obligations: We may disclose your information
where we are legally required to do so in order to comply
with applicable law, governmental requests, a judicial
proceeding, court order, or legal process, such as in
response to a court order or a subpoena (including in
response to public authorities to meet national security or
law enforcement requirements).
- Vital
Interests: We may disclose your information
where we believe it is necessary to investigate, prevent, or
take action regarding potential violations of our policies,
suspected fraud, situations involving potential threats to
the safety of any person and illegal activities, or as
evidence in litigation in which we are involved.
More specifically, we may need to
process your data or share your personal information in the
following situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Vendors,
Consultants and Other Third-Party Service
Providers. We may share your data with
third-party vendors, service providers, contractors or
agents who perform services for us or on our behalf and
require access to such information to do that work.
Examples include: payment processing, data analysis,
email delivery, hosting services, customer service and
marketing efforts. We may allow selected third parties
to use tracking technology on the
We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.
In
Short: We
only share information with the
following
categories of
third
parties.
We only
share and disclose your information with
the following
categories of
third parties. If we have
processed your data based on your
consent and you wish to revoke your
consent, please contact us using the
contact details provided in the section
below titled "HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?".
-
Data Analytics Services
In
Short: We may
use cookies and other tracking
technologies to collect and store
your
information.
We may use
cookies and similar tracking
technologies (like web beacons and
pixels) to access or store information.
Specific information about how we use
such technologies and how you can refuse
certain cookies is set out in our Cookie
Notice
.
6.
IS YOUR INFORMATION
TRANSFERRED
INTERNATIONALLY?
In
Short: We may
transfer, store, and process your
information in countries other than
your own.
Our
servers are located in
the
United
States
. If you
are accessing
our
App
from
outside
the
United
States
, please
be aware that your information may be
transferred to, stored, and processed by
us in our facilities and by those third
parties with whom we may share your
personal information (see
"WILL
YOUR INFORMATION BE SHARED WITH
ANYONE?" above),
in
and other
countries.
If you are
a resident in the European Economic Area
(EEA) or United Kingdom (UK), then these
countries may not necessarily have data
protection laws or other similar laws as
comprehensive as those in your country.
We will however take all necessary
measures to protect your personal
information in accordance with this
privacy notice and applicable law.
7.
HOW LONG DO WE KEEP YOUR
INFORMATION?
In
Short: We
keep your information for as long as
necessary to fulfill the purposes
outlined in this privacy notice
unless otherwise required by
law.
We will
only keep your personal information for
as long as it is necessary for the
purposes set out in this privacy notice,
unless a longer retention period is
required or permitted by law (such as
tax, accounting or other legal
requirements). No purpose in this notice
will require us keeping your personal
information for longer than
the
period of time in which users have an
account with us
.
When we
have no ongoing legitimate business need
to process your personal information, we
will either delete or anonymize such
information, or, if this is not possible
(for example, because your personal
information has been stored in backup
archives), then we will securely store
your personal information and isolate it
from any further processing until
deletion is possible.
8.
HOW DO WE KEEP YOUR
INFORMATION
SAFE?
In
Short: We aim
to protect your personal information
through a system of organizational
and technical security
measures.
We have
implemented appropriate technical and
organizational security measures
designed to protect the security of any
personal information we process.
However, despite our safeguards and
efforts to secure your information, no
electronic transmission over the
Internet or information storage
technology can be guaranteed to be 100%
secure, so we cannot promise or
guarantee that hackers, cybercriminals,
or other unauthorized third parties will
not be able to defeat our security, and
improperly collect, access, steal, or
modify your information. Although we
will do our best to protect your
personal information, transmission of
personal information to and from our
App
is at your own risk. You should only
access the
App
within a secure environment.
9.
DO WE COLLECT
INFORMATION FROM
MINORS?
In
Short: We do
not knowingly collect data from or
market to children under 18 years of
age.
We do not
knowingly solicit data from or market to
children under 18 years of age. By using
the
App
,
you represent that you are at least 18
or that you are the parent or guardian
of such a minor and consent to such
minor dependent’s use of the
App
.
If we learn that personal information
from users less than 18 years of age has
been collected, we will deactivate the
account and take reasonable measures to
promptly delete such data from our
records. If you become aware of any data
we may have collected from children
under age 18, please contact us at
cleo@neunie.com
.
10.
WHAT ARE YOUR PRIVACY
RIGHTS?
In
Short:
In
some regions, such as the European
Economic Area (EEA) and United
Kingdom (UK), you have rights that
allow you greater access to and
control over your personal
information.
You
may review, change, or terminate
your account at any time.
In some
regions (like the EEA and UK), you have
certain rights under applicable data
protection laws. These may include the
right (i) to request access and obtain a
copy of your personal information, (ii)
to request rectification or erasure;
(iii) to restrict the processing of your
personal information; and (iv) if
applicable, to data portability. In
certain circumstances, you may also have
the right to object to the processing of
your personal information. To make such
a request, please use the contact
details
provided below. We will consider and act
upon any request in accordance with
applicable data protection
laws.
If we are
relying on your consent to process your
personal information, you have the right
to withdraw your consent at any time.
Please note however that this will not
affect the lawfulness of the processing
before its withdrawal, nor will it
affect the processing of your personal
information conducted in reliance on
lawful processing grounds other than
consent.
If you are
a resident in the EEA or UK and you
believe we are unlawfully processing
your personal information, you also have
the right to complain to your local data
protection supervisory authority. You
can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are
a resident in Switzerland, the contact
details for the data protection
authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If you
have questions or comments about your
privacy rights, you may email us at
keston@neunie.com
.
Account Information
If
you would at any time
like to review or change
the information in your
account or terminate
your account, you can:
-
Log in to your account settings and update your user account.
Upon
your request to terminate your
account, we will deactivate or
delete your account and information
from our active databases. However,
we may retain some information in
our files to prevent fraud,
troubleshoot problems, assist with
any investigations, enforce our
Terms of Use and/or comply with
applicable legal requirements.
Cookies
and similar
technologies: Most
Web browsers are set to accept cookies
by default. If you prefer, you can
usually choose to set your browser to
remove cookies and to reject cookies. If
you choose to remove cookies or reject
cookies, this could affect certain
features or services of our
App
.
To opt-out of interest-based advertising
by advertisers on our
App
visit http://www.aboutads.info/choices/.
Opting
out of email
marketing: You can
unsubscribe from our marketing email
list at any time by clicking on the
unsubscribe link in the emails that we
send or by contacting us using the
details provided below. You will then be
removed from the marketing email list —
however, we may still communicate with
you, for example to send you
service-related emails that are
necessary for the administration and use
of your account, to respond to service
requests, or for other non-marketing
purposes. To otherwise opt-out, you
may:
-
Access your account settings and update your preferences.
11.
CONTROLS FOR
DO-NOT-TRACK
FEATURES
Most web
browsers and some mobile operating
systems and mobile applications include
a Do-Not-Track ("DNT") feature or
setting you can activate to signal your
privacy preference not to have data
about your online browsing activities
monitored and collected. At this stage
no uniform technology standard for
recognizing and implementing DNT signals
has been finalized. As such, we do not
currently respond to DNT browser signals
or any other mechanism that
automatically communicates your choice
not to be tracked online. If a standard
for online tracking is adopted that we
must follow in the future, we will
inform you about that practice in a
revised version of this privacy
notice.
12.
DO CALIFORNIA RESIDENTS
HAVE SPECIFIC PRIVACY
RIGHTS?
In
Short: Yes,
if you are a resident of California,
you are granted specific rights
regarding access to your personal
information.
California
Civil Code Section 1798.83, also known
as the "Shine The Light" law, permits
our users who are California residents
to request and obtain from us, once a
year and free of charge, information
about categories of personal information
(if any) we disclosed to third parties
for direct marketing purposes and the
names and addresses of all third parties
with which we shared personal
information in the immediately preceding
calendar year. If you are a California
resident and would like to make such a
request, please submit your request in
writing to us using the contact
information provided
below.
If you are
under 18 years of age, reside in
California, and have a registered
account with
the
App
,
you have the right to request removal of
unwanted data that you publicly post on
the
App
.
To request removal of such data, please
contact us using the contact information
provided below, and include the email
address associated with your account and
a statement that you reside in
California. We will make sure the data
is not publicly displayed on the
App
,
but please be aware that the data may
not be completely or comprehensively
removed from all our systems (e.g.
backups, etc.).
13.
DO WE MAKE UPDATES TO
THIS
NOTICE?
In
Short: Yes, we will
update this notice as necessary to
stay compliant with relevant
laws.
We may
update this privacy notice from time to
time. The updated version will be
indicated by an updated "Revised" date
and the updated version will be
effective as soon as it is accessible.
If we make material changes to this
privacy notice, we may notify you either
by prominently posting a notice of such
changes or by directly sending you a
notification. We encourage you to review
this privacy notice frequently to be
informed of how we are protecting your
information.
14.
HOW CAN YOU CONTACT US
ABOUT THIS
NOTICE?
If you
have questions or comments about this
notice, you may
contact our Data
Protection Officer (DPO) ,
CLEO
NEUNIE
,
by
email
at
cleo@neunie.com
, by
phone at
07951698403
,
or
by post
to:
15.
HOW CAN YOU REVIEW,
UPDATE, OR DELETE THE
DATA WE COLLECT FROM
YOU?
Based on
the applicable laws of your country, you
may have the right to request access to
the personal information we collect from
you, change that information, or delete
it in some circumstances. To request to
review, update, or delete your personal
information, please submit
a request form by clicking here
.
This privacy policy was created using Termly’s
Privacy Policy Generator.