PRIVACY POLICY

This Privacy Policy (“Policy”) describes Neol, Ltd. (“hereinafter referred to as “Neol”, the "Company", “We”, and through similar words such as “us”, “our”, etc.) practices and policies with regard to the use and processing of Personal Information while providing the Services. This Policy describes the kinds of Personal Information we collect through https://www.neol.co/ as described in this Policy (collectively “Platform”), how we use that information, our legal basis for doing so, with whom we share it, your rights, and choices in this regard, and how you can contact us about our privacy practices. This Policy does not apply to third-party sites, products, or services, even if they link to our Services or Platform, and you should consider the privacy practices of those third parties carefully.

1. DEFINITIONS

Capitalized words not defined in this Privacy Policy are defined in our Terms. It is of utmost importance to read the Policy provided herein in tandem with the Terms to better grasp the key concepts provided and explained therein.

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

2. HOW WE COLLECT DATA

We collect Personal Information concerning you from certain sources to provide the Services and to manage the Platform. We also obtain information from you and from Third Parties as detailed below.

Please note that if you decline to provide any of the required information requested by the Company, you may not be able to take full advantage of the Services and their features.

a) Platform Users and the Services

We collect information from and about you and your transactions and other interactions with us. This may include, but is not limited to, when you visit our Platform, set up a profile, use the Services, leave comments or feedback about our Services, reach out to us through the support assistant, or otherwise contact us through the Platform, e-mail or any other channels provided by the Company for this purpose.

b) Third Party Integrations (Service Providers)

We benefit from Third-Party Service Providers to provide certain Services on our behalf when the personal data is necessary for them to perform their duties. The Company uses Third Party Service providers to, among other things, provide archive services, and manage your payment regarding the Services we provide. These Service Providers are prohibited from using Personal Information for any other purpose and are contractually obligated to comply with all applicable laws and requirements.

Third-Party Service Providers are bound by their own use and privacy policies, and Neol cannot be held responsible for behaviors of the Third-Party Service Providers that violate any right arising from Personal Data Protection Legislation.

We strongly advise you to read the terms and conditions and privacy policies of any Third-Party Service Providers or web sites that you visit.

c) Third Party Analytics and Advertisements

We also may use Third Party advertisements, analytics, and tracking tools to better understand who is using the Platform, how people are using the Platform, how to improve the effectiveness of the Services, related content, and to help us or those Third Parties serve more targeted advertising to you across our media channels. These Third Parties may use technology such as cookies, web beacons, pixel tags, log files, flash cookies, or other technologies to collect and store information. They may also combine information they collect from your interaction with the Platform with information they collect from other sources, which combination may be subject to the Third Party’s control and privacy practices thereupon.

d) Cookies and Automatic Collection Methods

We may also collect information about your online activities on the Platform and your Devices to use Platform over time and across third-party websites, devices, apps, and other online features and services.

This collection includes automatically collected information, and generally does not include Personal Information unless you provide it through our Platform or you choose to share it with us by other means. Methods we use are described below:  

• Cookies (which may be session-based or persistent, and are typically small data files that are stored on your Device or in connection with your internet browser as set forth thoroughly under our “Cookie Policy” section)
• Web beacons or tags (small images embedded into websites or emails that send information about your Device when you visit our Platform, or open an e-mail we send to you);
• Platform log files (which we tend to create automatically in connection with your access to and use of our Platform).

To learn more about the cookies that may be served through our Platform and how Users can control our use of cookies and third-party analytics, please see our Cookie Policy section.

3. TYPES OF DATA COLLECTED

1. Personal Data that We Collect from Users

While using our Service, we may ask you to provide us with certain personally identifiable information in connection with the Services which can be used to enable your transaction, manage the registrations, contact and/or identify. Personally identifiable information may include, but is not limited to:

• Identifiers, which includes your first name, last name, gender identity, sexual orientation, ethnic background, account username, account information;
• Contact Information, which includes your email address, phone number, country of residency;
• Communications and Interactions, which includes email messages, phone calls that we exchange with you, customer support communications, LinkedIn Profile, personal Website, and other usage data described below in detail;
• Professional Information, which includes for your expertise, professional skills, experience;
• Device Information, which includes IP address, internet provider, operating system and browser used, type of Device, Device cookie settings and other Device details.

Neol does not require your sensitive data, including gender identity, sexual orientation, and ethnic background, to set up an account. This information is solely optional and is only visible through your profile page on Neol if you choose to make it so. You may select 'Prefer not to Say' for each of these pieces of information, and your answer shall not affect your relationship with us in any way.

You may also opt-in to submitting information through other methods, including:

• By participating in an offer, program, or promotion
• Through our social media accounts or online forums,
• In connection with a real or potential business relationship with us,
• In response to our marketing, or other email communications,
• By giving us your business card or contact information.

b. Information that We Collect Automatically on Our Platform and Services

Our Platform uses cookies and other technologies to function effectively. These technologies record information about your usage of our Platform, including:

• Browser and Device Data, such as IP address, device type, internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, brand, model, technical specification and operating system information of the device used, and the language version of the Platform you are visiting;
• Preference information, your marketing and communication preferences, your account settings including any default preferences, any preferences you have indicated, the types of services/offers that interest you, the areas of our Services that you have visited or ways that you interact with our Services
• Usage Data, such as time spent on the Platform, pages visited, links clicked, bounce rate, roll percentage, language preferences, views, Platform usage time, communication preferences, approaches to in-platform notifications/offers/campaigns, habits, favorites, likes, behaviors, preferences, search activities, segments, cookie records, cookie and ad identifier and Device ID, and the pages that led or referred Users to our Platform.

While using our Service, in order to provide features of our Platform, we may collect, with your prior permission, photos, files and other information from your Device's contacts, camera, voice recording/photo library, and files.  We use this information to provide features of our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it be simply stored on your Device. For example, when you scan your Strip to your Device camera or want to upload a profile photo, we will ask your prior permission to access your Device camera. You can enable or disable access to this information at any time, through your Device settings.

We also may collect information about your online activities on the Platform and connected Devices over time and across third-party sites, devices, apps, and other online features and services. We use web log analysis software (Google Analytics etc.) on our Platform to help us analyze your use of our Platform and diagnose technical issues. Please refer to our Cookie Policy for detailed explanation.

4. USE OF PERSONAL DATA

a. Our Services

We use the information that we collect/obtain to conduct our business and to provide you with the best possible Services, and online experiences. We rely upon several legal grounds to ensure that our use of your Personal Data is compliant with the applicable law. We use Personal Data to facilitate the business relationships we have with our Users, to comply with legal obligations, and to pursue our legitimate business interests and if necessary, based on your prior explicit consent.

Pre-contractual, contractual, and post-contractual business relationships. We use personal information to enter business relationships with prospective Users and to perform the contractual obligations under the contacts that we have with our Users. Examples of how we use information within this condition include:

• To provide you Services, such as to,

• Provide you with information or services or process transactions that you have requested or agreed to receive,
• Enable you to participate in a variety of the Service features.

• To process your account registration, including verifying your information is active and valid;
• To verify, respond or communicate with you such as when you;

• Register with the Platform,
• Make a request or inquiry through any channel dedicated for such use including FAQs,
• Ask for customer support through any channel dedicated for such use including interactive customer support chat,
• Share a comment/feedback/review or concern regarding the Services,

Artificial Intelligence. Neol utilizes your Personal Data to provide you with opportunities through our network via https://ai.neol.co/ (“Neol AI”). Neol AI does not have access to Sensitive Data and is only based on the skills, industry, or general location that you have provided. Neol AI is essential for Neol to provide its Services. Neol AI does not utilize your personal data beyond what has already been provided by you and is publicly available through your Neol account, nor does it share it with any third party.

To fulfil your customer requests, we may receive services from Third Party service providers to handle customer support channels. Please note that any personal data you may share during communication through the support channel is subject to this Policy and customer support channel personnel do not require any personal data other than your credentials and contact information. Therefore, please do not share any more information that is not asked from you by customer support channel personnel. Customer support channels may forward you to an expert that is authorized to solve your problem.

To communicate with you and maintain our legal relationship arising from the contracts between our Users and the Company, and also to fulfill our obligations arising thereof.

Legal and regulatory compliance. We use Personal Data to verify the identity of our Users in order to comply with applicable laws. These obligations are imposed on us by the operation of law, industry standards, and by our financial partners, and may require us to report our compliance to third parties and to submit to third-party verification audits. Examples of how we use information within this condition include:

• Accounting, auditing, and billing activities;
• Respond to court orders, lawsuits, subpoenas, and government requests;
• Address legal and regulatory compliance.

Legitimate business interests. We rely on our legitimate business interests to process certain Personal Data concerning Users. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose Personal Data we process.

• Mitigating financial loss, claims, liabilities, or other harm to Users and Neol as well as its employees and shareholders;
• Security or integrity of our Platform and business, such as by protecting against and preventing fraud, unauthorized transactions, claims and other liabilities, and managing risk exposure, including by identifying potential hackers and other unauthorized users;
• Responding to inquiries, sending service notices, and providing customer support;
• Promoting, analyzing, modifying, and improving our systems, tools, and our Services as well as developing new Services increasing our Services’ functionality and user-friendliness;
• Managing, operating, and improving the performance of our Platform and Services by understanding their effectiveness and optimizing our digital assets;
• Conducting aggregate analysis and developing business intelligence that enables us to operate, protect, make informed decisions, and report on the performance of our business;
• Sharing Personal Data with Third-Party Service Providers that provide services on our behalf and business partners who help us operate and improve our business;
• Ensuring network, wallet connection and information security throughout the Platform and our Services.

If we need to use your Personal Data in any other way, we will notify you specifically at the time of collection and, if required by the relevant legislation, we will obtain your consent.

b. Marketing and Events-related Communications

We may send Users e-mail marketing communications about Neol and its Services, invite Users to participate in our events or surveys, or otherwise communicate with Users for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. When we collect your business and contact details through our participation at trade shows or other events, we may use the information to follow-up with Users regarding these events, send Users information that Users have requested on our Services, and with your permission, include Users on our marketing information campaigns. The trade shows or other events may be online or in-person.

5. HOW WE SHARE PERSONAL DATA

Neol may share your Personal Data to (i) satisfy any applicable law, regulation, legal process, or governmental request; (ii) enforce this Policy and our Terms and Conditions, including investigation of potential violations hereof; (iii) detect, prevent, or otherwise address fraud, security, or technical issues; (iv) respond to your requests; or (v) protect our rights, property or safety, Users and the public; or (vi) fulfill our obligations arising of or in connection with the contracts with and our Users.

Portions of your account information may be publicly accessible through your Neol account, with the option for you to modify it at any time through your profile settings.

We share Personal Data with a limited number of our Service Providers. We have Service Providers that provide services on our behalf, such as website hosting, data analysis, information technology, and related infrastructure, customer service, e-mail delivery, and auditing services. These Service Providers may need to access Personal Data to perform their services. We authorize such Service Providers to use or disclose Personal Data only as necessary to perform services on our behalf or comply with legal requirements. We require such Service Providers to contractually commit to protect the security and confidentiality of Personal Data they process on our behalf.

We may disclose information in the aggregate form to Third Parties relating to user behavior in connection with the actual or prospective business relationship with those Third Parties, such as advertisers and content distributors.

We may share personal information with Third Parties we work with for our purposes, though in general we do not share personal information about you with Third Parties for Third-Party marketing or advertising purposes. For information about the choices, you have about the online advertising practices described in this section, please see the “Exercising Your Privacy Rights” sections below.

Third Parties are prohibited from using personal information for any other purpose and are contractually obligated to comply with all applicable laws and requirements.

We will encourage our Service Providers to adopt and post transparent privacy policies. However, the use of your Personal Information by our service partners is governed by their privacy policies and is not subject to our control. You acknowledge that we are not responsible for the violations caused by our service partners.

We share Personal Data with Third Party business partners when this is necessary to provide our Services to our Users.

We share Personal Data with Third Parties as necessary to maintain a User account and provide the Services. The use of Personal Data by an authorized third party is subject to the Third Party’s privacy policy.

In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we may share Personal Data with Third Parties for the purpose of facilitating and completing the transaction.

We share Personal Data as it is necessary: (i) to comply with applicable law, or payment method rules; (ii) to enforce our contractual rights; (iii) to protect the rights, privacy, safety, and property of Neol, Users 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 jurisdiction.

6. EUROPEAN UNION and UNITED KINGDOM PRIVACY INFORMATION (“GDPR PRIVACY")

Your Rights and Choices Under the EU GDPR & UK GDPR

Neol undertakes to respect the confidentiality of your Personal Data and to guarantee Users can exercise their rights.

Users have the right under this Policy, and by law if they are within the UK or EU, to:

- Right of Access: Users have the right to obtain confirmation from us as to whether or not Personal Data concerning Users are processed, and, where that is the case, Users have the right to request and get access to such Personal Data.

- Right to Rectification: Users have the right to request rectification by us of inaccurate Personal Data and Users have the right to provide additional Personal Data to complete any incomplete Personal Data.

- Right to Erasure (“Right to be Forgotten”): In certain cases, Users have the right to request from us the erasure of their Personal Data.

- Right to Restriction of Processing: Users have the right to request from us restriction of processing, for a certain period and/or for certain situations.

- Right to Data Portability: Users have the right to receive their Personal Data from us in a structured format and Users have the right to (let) transmit such Personal Data to another controller.

- Right to Object: In certain cases, Users have the right to object to the processing of their Personal Data, including with regards to profiling. Users have the right to object to the further processing of their Personal Data in so far as such data has been collected for direct marketing purposes.

- Right to be Not Subject to Automated Individual Decision-Making: Users have the right to not be subject to a decision based solely on automated processing.

- Right to Filing Complaint: Users have the right to file complaints with the applicable data protection authority on our processing of their Personal Data.

- Right to Compensation of Damages: In case we breach applicable legislation on the processing of Users’ Personal Data, Users have the right to claim damages from us for any damages such breach may cause to Users.

Exercising of Your UK & EU GDPR Data Protection Rights

Users have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. If you are a resident of United Kingdom, you may complain to Information Commissioner’s Office (ICO) regarding your data protection rights. If you are a resident in the European Economic Area (EEA), please contact your local data protection authority in the EEA. However, we would be appreciated to deal with your concerns before you apply to a Data Protection Authority.

You may exercise your rights of access, rectification, cancellation, and opposition by simply contacting us. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

How to Opt-Out

Neol may automatically process any public links (Public Linkedin Profile Link, Website Links, Blog Links, Portfolio Links) from his/her Profile to feed the secure artificial intelligence-integrated protocol for the purpose of analyzing and suggesting the most compatible Neol Community Members for connections, collaborations, and projects in compliance with the Neol Privacy Policy and relevant regulations. Neol Community Member has the right to opt out by filling out the Opt-Out Form for AI-Enhanced Online Data Matchmaking (https://neol.typeform.com/to/KyHKnutZ). If Neol Community Member opts out, its profile won't be sidelined, but it may not be as prominently featured in project team searches. Any information processed by the AI-enhanced online Data Matchmaking bot is limited to the designated data stipulated under this Agreement and Neol Privacy Policy.

7. SECURITY AND RETENTION

We are making reasonable efforts to provide Users with an appropriate level of security at the risk associated with the processing of your Personal Data. We take organizational, technical, and administrative measures designed to protect their Personal Data against unauthorized access, destruction, loss, alteration, or abuse. Users’ Personal Data may only be accessed by a limited number of personnel who need access to such information in order to perform their duties. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If Users have a reason to believe that their interaction with us is no longer secure (for example, if Users think their account is compromised), please contact us immediately.

We employ robust security measures to protect your data from unauthorized access, alteration, disclosure, or destruction.

Your data is treated with utmost confidentiality and is only accessible to authorized personnel involved in the development and maintenance of our systems, including Neol AI.

We retain Users’ Personal Data as long as we are providing the Services to Users. We retain Personal Data after we cease providing Services to Users to the extent necessary to comply with our legal and regulatory obligations. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data due to our contractual commitments to our financial and business partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

We also take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required by law to keep this information for a longer period. When determining the retention period, we take into account various criteria, such as the type of Services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our Services, the impact on the Services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.

8.   INTERNATIONAL DATA TRANSFERS

We are a global business. Personal Data may be stored and processed in any country where we have operations or where we engage service providers. We may transfer Personal Data that we maintain about Users to recipients in countries other than the country in which the Personal Data was originally collected. Those countries may have data protection rules that are different from those of your country. However, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your Personal Data remains protected to the standards described in this Policy. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data.

9. USE BY MINORS

The Services are not directed to individuals under the age of eighteen (18) and sixteen (16) for United Kingdom citizens, and they shall not provide Personal Data through the Services. If you have reason to believe that anyone minor has provided us with any Personal Information, please contact us.

10.   UPDATES TO THIS POLICY AND NOTIFICATIONS

We may change this Policy from time to time to reflect new services, changes in our Personal Data practices, or relevant laws. The “Last Updated” legend at the top of this Policy indicates when this Policy was last revised. Any changes are effective when we post the revised Policy on the Platform. We may provide you with disclosures and alerts regarding the Policy or Personal Data collected by posting them on our Platform and, if you are a User, by contacting you through Neol e-mail address.

11.   LINKS TO OTHER WEBSITES

The Services may provide the ability to connect to other sites. These sites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you consider. If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the said website, or the privacy practices of the operator of the said website.

12.   JURISDICTION

Neol focuses on multinational compliance regulations including but not limited to United Kingdom General Data Protection Regulation (“UK GDPR”), General Data Protection Regulation brought by the European Union (“GDPR”), and other Privacy Laws to make sure privacy is a “go-to” rather than a thing to be worried. You have the right to request further information on our personal data processing activities based on your country's laws.

13.   CONTACT US

If Users have any questions or complaints about this Policy, please contact us at community@neol.co, or at the address of C/O Las Accountants Llp, No 1 Royal Exchange, London, England, EC3V 3DG.