We at Neo care about your privacy!
This privacy policy (“Privacy Policy”) has been published in order to help Customers and End Users understand what information of theirs Neo (as defined hereinafter) may collect through its websites, Neo and Neo SaaS (collectively, “Services”), the purpose and means of collecting such information, the manner in which such information is used, processed, disclosed and protected, and the options Customers and End Users have to limit Neo’s use of their Personal Data (as defined hereinafter).
For the purpose of this Privacy Policy, “Neo”, “Company”, “our”, “we” or “us” shall mean Titan Solution Ltd SEZC, with its registered office at CO Services Cayman Limited, P.O. Box 10008, Willow House, Cricket Square, Grand Cayman, KY1-1001, Cayman Islands, and the “Customer”, “End User”, “User”, “you” or “your” will refer to the relevant individual who accesses or uses any of the Services either in an individual capacity or on behalf of a body corporate.
This Privacy Policy forms an integral part of Neo’s Customer Terms of Use and/or End User Terms of Use, as applicable, and other policies (collectively, “Policies”) which govern your access to and use of the Services. Please go through this Privacy Policy in detail and do not hesitate to contact us if you have any questions or require any clarifications.
By accessing or using any of the Services or by otherwise giving us your information, you will be deemed to have the capacity to enter into a legally binding contract as per the jurisdiction from which you are accessing or availing any of the Services. You will consequently be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and agree to be bound by its terms. In the event, the Services are being used by individuals who have not reached the age of majority in the jurisdiction from which such individuals are accessing the Services, their legal guardian confirms that they are using the Services after obtaining consent from them and in their supervision.
We reserve the right to make changes to this Privacy Policy, at our sole discretion, at any time. Any such amendments to the Privacy Policy will become effective immediately upon such amendments being published on our website and your continued use of the Services following such amendments to the Privacy Policy will constitute your acceptance of such modifications. We may also make you aware of the amendments by sending you an email or providing a notification by other means. Your opting out of receiving such communications or notifications from us will not impact the applicability of such amendments which will continue to govern your use of the Services. You agree to periodically review the Privacy Policy from time to time.
If you do not agree with any of the terms of this Privacy Policy, please do not continue to access or use any of the Services and provide any information to us.
Transfer of information from Google’s mail services to the Services using Google APIs will also be governed by Google API Services User Data Policy, including the Limited Use requirements specified therein.
1. Definitions
Capitalised terms used in the Privacy Policy will have the meaning ascribed to them hereunder. Where any terms that are capitalised in the Privacy Policy but are not defined, such capitalised terms shall have the meaning ascribed to them in the Policies.
For the purposes of this Privacy Policy, “Personal Data” means any information that relates to a natural person, which, either directly or indirectly, in combination with other information available or likely to be available with a body corporate, can identify such person.
2. What are the types of Personal Data we collect and what is the manner in which we collect it?
We collect Personal Data in the following ways:
2.1 When you give it to us or give us permission to obtain it
(a) When you access, use or sign up for the Services, you voluntarily provide us certain Personal Data which includes your first and last name, email address, postal address, phone number, phone contacts or any other similar data. Where you provide this data on behalf of a body corporate or other individuals, you represent and warrant to us that you are authorised to do so.
(b) Account Data: If you create an account or use the Services on behalf of a business or body corporate, we may collect business-related information such as the nature of the business and related details, in addition to the information specified above.
(c) Access Credentials: Access credentials such as passwords, passwords hints, and similar security information will be collected and processed for authentication purposes and to enable you to avail the Services.
(d) Plan and Payment Details: The Services are typically availed pursuant to a subscription plan, and we will collect data about the subscription plan, features and other licenses that you have availed to provide such Services to you. While we will not collect or receive your card or other payment instrument details from the payment gateway using which you have paid for our Services, we will receive details in relation to the transaction to enable us to determine the Services that you have availed including details such as your name, billing address, contact number. We also collect these details directly from you and share the same with payment service providers to enable you to pay for our Services. Payment instrument details such as those of debit or credit cards or online wallets will be collected and processed by the payment service provider in accordance with its own policies.
(e) Email Information: Given that the Services enable you to send and receive email communications, we will process the contents of all emails including the contents of any files you input, upload, receive, create and control. Such contents may include text, video, images, voice or data in any other format. For example, if you transmit an email using our mail service, we need to collect the content of that email to display it to both you and the recipient of such email. Additionally, all data in relation to the email such as the time of sending or receiving, location from which the email is sent or received, results of any anti-fraud or anti-spam engine through which the email has been processed and other metadata will be processed by us.
(f) Voice Data: Where the Services allow you to use it using voice commands, we will collect and process your voice data to enable the same.
(g) Feedback and Rating: We will process all information you provide to us and the content of messages or emails you send us for the purposes of any feedback or rating or any responses you provide pursuant to your participation in any surveys, focus groups, contests, feedback events or provided by you on third party sites where review of the Services can be provided.
(h) Contact Details: We will further receive access to the data you provide of the recipients of the email to enable us to deliver the emails to the intended recipients. We will process data of any mailing distribution list with recipients created by you or any contacts list uploaded or created by you using the Services. Where you use the Services, for sending bulk emails or sending emails based on a distribution list, you agree to comply with all laws applicable to anti-spamming. We may share details of such distribution list with anti-spam organisations, if we detect illegal or abusive behaviours. Further, we sync and store your contacts from your phone or other devices across devices to enable email recipient suggestions. This syncing can happen even when the Services are not in use.
2.2 We do not have any direct relationship with the contacts you provide for using the Services or other people whose Personal Data you provide us by using the Services. Therefore, it is your sole responsibility to obtain the consent of such contacts and people to enable us to collect and process the information in accordance with this Privacy Policy and applicable laws. We take no responsibility and assume no liability for any unlawful use of the Services. If a contact no longer wishes to be contacted, he or she should be allowed to directly unsubscribe from your distribution list or contact list and you are solely responsible for updating or deleting the relevant individual from such distribution list.
2.3 If any Customer provides information of any End Users, we assume such End Users have authorised the Customer to provide such information to us. If you are a Customer, you represent and warrant that you have sought express permission from all End Users to provide their Personal Data to us for processing it in accordance with this Privacy Policy. We will not be liable for any unauthorised sharing of your Personal Data by any Customer.
2.4 When we get your Personal Data while you use the Services
Whenever you use any website, mobile application and other internet services, there is generally certain Personal Data that gets created and recorded automatically. Similarly, when you access or use our Services, some Personal Data may get created or recorded automatically. Personal Data collected pursuant to this is described below.
(a) Services Metadata: When the Customer or any End User interacts with or uses the Services, metadata is generated that provides additional context about the way the Customer or such End User uses the Services. For example, we log details of the people, features, content and links that you view or interact with, the types of files shared and third party services used, if any.
(b) Log Data: While accessing or using the Services, our servers automatically record Personal Data, including Personal Data that your browsers sends whenever you visit a website. This log data may include your IP address, browser type and settings, operating system, web pages visited, location, search terms and cookie data.
(c) Cookie Data: Depending on how you access the Services, we may use “cookies” (a small text file sent by your device each time you visit the Services, unique to your user account or browser) or similar technologies, such as web beacons or pixels, to record log data, analyse trends, gather demographic information or track navigation through our SaaS platforms. Please see Section 7 below of the Privacy Policy for further information.
(d) Device Information: In addition to the log data, we may also collect information about the device on which you are using the Services. The device information will include Personal Data such as type of device, operating system, device settings, unique device identifiers, crash data, troubleshooting data, error and help data. This helps us, among other things, to make sure that the Services are displayed and function correctly on your device. Whether we collect some or all of this device information, including Personal Data, often depends on what type of device you are using and its settings.
(e) Location Information: We may collect your device’s location using any Global Navigation Satellite System (for example, GPS) or using any other technology that will enable us to collect your location. We may also receive location information from you or other third parties that help us to approximate your location. We may, for example, use a business address submitted by a Customer or an IP address received from your browser or device to determine the approximate location to assist with localisation of the Services or for security purposes.
(f) Web Beacons and URL-based tracking: We may use web beacons that are tiny and invisible images that are embedded in emails and are used to track information such as when the email was opened, where it was opened, clicks on links, and whether the email was forwarded or deleted. We use this data to help us and our Customers understand engagement of the email recipients and optimize the use of Services including by improving email marketing efforts. We also use URL-based tracking to help our Customers and End Users understand the performance of their emails by tracking the recipients’ engagement with the attachments and links present in the email.
(g) Other source: In order to provide or further improve or develop our Services, we may search the internet to receive further information concerning you or your contacts, such as name, email, address, location, IP addresses, demographic information and use of social media websites.
2.5 Some other types of information that we may collect about you are as follows:
(a) Demographic Information: We may collect information which is not unique to you and refers to selected population characteristics including age, gender, location and occupation.
(b) Behavioural Information: In addition to log data, we may collect information about how the Services are being used, including usage statistics, traffic data, access times and locations, your previous order and transactions, including the services and pricing details, transaction information, and payment and browsing history.
(c) Indirect Information: Your use of certain third-party websites and applications require us to collect such information as is considered necessary for that purpose.
(d) Customer Support Data: We may collect your information when you contact us, through (i) email or other means/tools available through the Services; or (ii) telephone, including IVR channels or SMS, for requesting support in relation to the Services. This includes (i) information solicited by our support staff to validate your user account and identity; (ii) record of communication between you and our support staff, which may, among other things, be used for monitoring and quality improvement; (iii) response to a query or comment about the Services and/or Neo; and (iv) for the purposes of reinstatement of accounts blocked or suspended by us on any grounds in accordance with the Policies.
2.6 While we may collect log data, cookie data, device information, demographic information, behavioural information and indirect information when you access or use the Services, we collect user account information, email information, customer support data and transaction details from you or third parties authorized by you. Accordingly, you agree that you are providing this information to us voluntarily and provide your express consent for us to collect and process such information in accordance with the terms of this privacy policy. You may choose to not provide us with any or all information as part of your account information but in the event that you do so, we may be unable to provide you with some of the Services.
3. How do we use the Personal Data that we collect?
3.1 We use the Personal Data we collect or receive to:
(a) Provide our Services to you and make them more effective;
(b) Fulfil our obligations under the Policies or any other contracts that we may have entered into with you or any third parties;
(c) Provide you with suggestions for email recipients or other suggestions basis your historical use and predictive models;
(d) Customise the experience of the Services;
(e) Develop new products, features and services;
(f) Protect Neo, its rights and properties, and its users and their rights.
3.2We may also use the Personal Data to:
(a) Send you updates about activities of Neo and/or email newsletters, promotional material and other information that may be of interest to you. You will have an option to stop getting these updates or unsubscribe from getting any email newsletters or other notifications by updating your settings or by following the procedures we may provide;
(b) Respond to your questions or comments;
(c) Send you emails, invoices and further notifications concerning billing and collecting money as a result of your use of the Services;
(d) Send you system notifications such as version updates, warnings or changes in our Policies;
(e) Communicate with you in any other context, including, but not limited to, providing customer support, meeting legal requirements or enforcing compliance with the Policies;
(f) Maintain and update our Services and prevent or address service errors or technical issues;
(g) Better understand the use of the Services, change or improve it, or promote or market the Services;
(h) Improve the safety and reliability of the Services. This may include detecting, preventing, and responding to fraud, abuse, security risks, and technical issues that could harm the Services, you, our other users, or the general public;
(i) Enable our or our affiliates’ business purposes such as developing new products and services. Such new products and services may be developed in conjunction with our partners, data providers, affiliates or other third parties with whom we have or propose to enter into contractual relationships with;
(j) Analyse data, track trends, build algorithms and create databases for the purpose of the Services;
(k) Carry out research and training activities;
(l) Carry out non-targeting activities such as frequency capping, compliance, billing, market research or product development;
(m) Conduct audits and quality assessments procedure for the Services;
(n) Contact you from time to time to record your feedback on the Services, as they currently stand, and/or any potential services that may be offered in the future;
(0) Investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of the Policies, or as otherwise required by law or initiate any legal proceedings in relation to the foregoing;
(p) Establish, exercise or defend against any legal claims or proceedings;
(q) Comply with legal and regulatory obligations;
(r) Promote our other legitimate interests including the legitimate interests set out above; and
(s) Process Personal Data for purposes for which we obtain your consent.
3.3 We do not sell or rent your Personal Data in any manner for any purpose.
3.4 We may de-identify, aggregate or anonymise your Personal Data available with us and will use this de-identified or anonymised data without any restrictions for the purpose of our or our affiliates’ businesses.
3.5 Transfer of Personal Data
(a) We may use, transfer or process Personal Data in any of the jurisdictions in which we or our affiliates do business including countries outside the country from which you are accessing or availing the Services but always in accordance with this Privacy Policy and applicable law.
(b) We may share your Personal Data with our affiliates and other third parties for any of the purposes specified above or in any of the Policies. Such sharing or transferring of Personal Data to third parties shall be done in compliance with applicable law and the Policies. Such third parties include (i) the third parties or sub-processors specified here. We reserve the right to change such sub-processors at any time. We will periodically update the list of sub-processors as required; (ii) entities with whom we may engage pursuant to a merger, acquisition, reorganisation, bankruptcy, dissolution or similar transaction or proceeding; (iii) entities who are authorised by us to perform functions on our behalf, including, but not limited to, those which provide administrative or other services to us or in relation to the Services such as information technology companies, payment services providers, data centres, auditors and marketers.
(c) Where we share your Personal Data in accordance with this Privacy Policy, including to jurisdictions other than those in which you reside, we will do so in compliance with applicable law and only to third parties who provide an adequate level of protection for such Personal Data. We will also contractually obligate such third parties to maintain confidentiality of the Personal Data and process it only for specified purposes, as required under this Privacy Policy and our relationship with them.
4. What are your rights and options in relation to your Personal Data?
4.1 Applicable law grants you rights in relation to your Personal Data. We provide multiple options through which you can exercise your rights in relation to your Personal Data that you have with us. Please do note that the exercise of the following rights is subject to applicable law and the Policies.
4.2 Right to update, modify or rectify your Personal Data:
(a) You have the right to update any inaccurate or outdated Personal Data. You may do the same by accessing your user account provided as part of the Services. Certain Personal Data may not be amended because we may need that data to ensure continued provision of your user account. If you believe that any such information needs to be changed, please contact us at the contact details provided in Section 8 below. Modification of the Personal Data for End Users may also be restricted or limited by Customers and the conditions set by them. As an End User, please reach out the administrators managing your accounts to modify your Personal Data.
(b) Please be aware that it is your responsibility to keep your Personal Data complete, accurate and up to date.
(c) Should you choose to delete your Personal Data or modify it in a way that it is not verifiable by us, or leads to such Personal Data being incorrect, we will be unable to provide you with our Services in accordance with the Policies, and such a modification may be regarded as you seeking to discontinue receiving our Services.
(d) We reserve the right to verify your identify and account information in order to ensure accurate delivery of Services. Access to, correction, updating or deletion of your account information or any other Personal Data may be denied or limited by us if it would violate another person’s rights and /or is not otherwise permissible under applicable law.
4.3 Right to port your Personal Data: The Services enable you to export a copy of all your data, including Personal Data, for your use including with other services.
4.4 Right to deactivate or close your user account and delete your Personal Data / Data Retention
(a) Customers can deactivate or close their user account and/or the associated accounts of End Users in accordance with the Policies and the options provided as part of the Services. We will delete the Personal Data associated with such accounts from our systems after 67 (sixty- seven) days of the deletion of the account unless we are required to retain archived copies of such Personal Data pursuant to applicable law or for legitimate business purposes. Unless required by applicable law, emails will be deleted within 30 (thirty) days of the closure of the account. We will be able to restore your Personal Data if you reactivate your account within such period however, after that closure of your user account and deletion of your Personal Data cannot be revoked. Similarly, emails cannot be recovered after the completion of 30 (thirty) days from the date of closure of the account.
(b) Examples of purposes for which we may retain your Personal Data includes addressing fraud and spam, exercising our right to initiate or defend legal claims, complying with applicable law, complying with requests for law enforcement authorities or for archiving purposes in the public interest. We will also not delete your Personal Data till all fees owed to us for availing the Services have been paid to us in full.
(c) The right of an End User to deactivate their account and delete all data may only be exercised using administrative accounts of the Customer. This does not restrict End Users from deleting any sent or received emails or other non-administrative data from their individual mailboxes.
(d) We may continue to retain any Personal Data which has been de-identified or anonymised for as long as we deem necessary for our business purposes.
(e) You should be aware that some of the Personal Data that may have been shared on third-party websites or platforms may still continue to be available as we do not have any control over these. For example, emails that you have sent using the Services will continue to exist in the systems of the recipients and technology service providers. Other Personal Data that you may have shared with others, or that other users have copies, may also remain available. You should only share your Personal Data with people that you trust because they will be able to save it or reshare it with others, including when they sync the Personal Data to a device.
4.5 Right to provide and withdraw consent or restrict processing
(a) At any time, you may give or withdraw your consent to us for collecting and processing your Personal Data in the manner and for the purposes mentioned in the Policies. You provide your consent by creating your user account or otherwise providing your Personal Data to us. You may withdraw or limit your consent at any time by changing your settings or by directly contacting us or your account administrator. Please note that even after you have chosen to withdraw your consent, we may be able to continue to process your Personal Data to the extent required or permitted by law.
(b) Please note that your withdrawal of consent or deletion of your user account may result in us not being able to provide you with the Services or terminate any existing relationship that we may have with you.
(c) You may also object to any processing of your Personal Data. Please inform us about the reason for your objection, and we will review whether and to what extent we will restrict or stop the future processing of your Personal Data in accordance with applicable law. We will inform your accordingly, if we decide to lift a restriction or objection to processing.
(d) Opt-out of marketing or other non-essential communications: You have the right to opt out of receiving non-essential (promotional, marketing-related) communications from us, after setting up your account by making such preference changes within the application being used to avail the Services.
(e) Opt-out of receiving push notifications: If you have enabled notifications for the Services on your devices such as your phone or laptop, we will provide notifications in relation to the Services (such as when you receive a new email) through push notification providers such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings.
4.6 Right to request access to, and information about, your Personal Data: You are always entitled to request confirmation or information about whether, where and for what purpose your Personal Data is being processed, and you may access your Personal Data without limitations. If you require, we will provide you with a copy of your Personal Data in a commonly used electronic format. You may reuse your Personal Data also for your own purposes across other services.
4.7 Breach Notification: We will inform you if a data security incident occurs involving your Personal Data as required by applicable law. We may also inform you of any steps that you may need to take to mitigate the effects of such data security incident.
4.8 In the event, (i) you believe that applicable law provides you with rights in addition to the ones specified above; (ii) despite our commitment and efforts to process and protect your Personal Data in compliance with applicable law, you believe that your data privacy rights have been violated; or (iii) you wish to enforce any of your rights including your right to withdraw your consent for processing any of your Personal Data available with us, please do not hesitate to contact us at privacy@neo.space.
4.9 Only for EU Residents: In the event you are a resident of the European Union and are subject to the European Union’s General Data Protection Regulation (“EU GDPR”), then you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work, or place of an alleged infringement of the EU GDPR. Without restricting your right to the foregoing, we encourage you to come to us first to seek resolution of any complaint by contacting us at privacy@neo.space. Additional rights of residents of the European Union may be found at https://support.neo.space/hc/en-us/articles/14463343083033-Data-Processing-Addendum.
5. How do we protect your Personal Data and how can you protect the same?
5.1 In order to protect your Personal Data in line with the applicable data and privacy laws, we have implemented and maintain appropriate technical, organisational and physical measures.
5.2 We use industry-standard technology to maintain the security of your Personal Data. We also encrypt data as is necessary and maintain records of Personal Data and related processing activities for as long as required by applicable law.
5.3 We will notify appropriate governmental authorities upon becoming aware of a security incident involving any Personal Data in the manner required by applicable law.
5.4 We do our best to keep your Personal Data safe, but, given the nature of the internet and internet-based communications, we cannot guarantee that your Personal Data will always be 100% safe. We, however, request that you cooperate with us in protecting your Personal Data and comply with the following security measures:
(a) Do not give third parties access to your computer or other devices when you access the Services;
(b)Keep your login credentials, including any access codes and passwords for your computer or other devices and the user account for the Services, confidential;
(c) Always update your antivirus software when requested by your antivirus software provider.
5.5 If you suspect any unauthorized use of your account, you must immediately notify us by sending an email to privacy@neo.space. We will not be liable for any losses arising from such unauthorised use of your account.
5.6 You agree that the security measures adopted by us are reasonable to protect your Personal Data. To the maximum extent permitted by applicable law, we disclaim any liability as a result of any breach of security or unintended loss or disclosure of your Personal Data.
6. Third Party Links
6.1 The apps and website through which you avail the Services may include hyperlinks to various external websites, applications, content or resources (“Third Party Links”). We have no control over such Third Party Links present within the Services and they are provided by persons or companies other than us. You acknowledge and agree that we are not responsible for any collection or disclosure of your information by any external sites, applications, companies or persons thereof. The presence of any Third Party Links included as part of the Services cannot be construed as a recommendation, endorsement or solicitation of any material or content on such Third Party Links, or any other materials on or available via such Third Party Links.
6.2 You further acknowledge and agree that we are not liable for any loss or damage that may be incurred by you as a result of the collection and/or disclosure of your information via Third Party Links, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, products, services or other materials on, or available via such Third Party Links. This will include all transactions, and information transmitted between you and any such third party sites or applications or resources. All such transactions will be strictly between you and the third party sites, applications or resources. We shall not be liable for any disputes arising from or in connection with such transactions between you and the aforementioned third parties.
6.3 Such third party websites, and external applications or resources, accessible via the Third Party Links may have their own privacy policies governing the collection, storage, retention and disclosure of your information that you may be subject to. We recommend that you exercise reasonable diligence, as you would in traditional offline channels and practice judgment and common sense before committing to any transaction or exchange of information, including but not limited to reviewing the third party website’s or application’s Privacy Policy.
7. Cookies
7.1 We use cookies, a small encrypted text file stored on your web browser or mobile application, and other tracking technologies to ensure the safety of your user account, make the Services easier to use, provide you with the best possible user experience, and to improve the Services. By continuing to access the Services, you provide your consent and agree to use of cookies and other tracking technologies for the purposes mentioned in this Privacy Policy.
7.2 We also use cookies and other tracking technologies to (a) collect information about your activities on the Services; (b) store information about your browsing preferences; (c) store your preferences and give you a personalised experience; (d) enable security features and assist us in detecting malicious activity on the Services; (e) analyse, evaluate and test the Services, which will include functional, security, performance, automation and load testing and also monitor and analyse the use of our Services; (f) conduct research and development activities in relation to the Services; (g) test the integration of the Services with third party software solutions; (h) compile aggregated statistics; and (i) undertake technical administration.
7.3 Most of the cookies are intended to be automatically cleared or deleted when you stop using the Services.
7.4 Further, while most web browsers and mobile settings are initially set up to automatically accept cookies, these browsers and mobile settings will also give you the option of controlling cookies through their respective settings.
7.5 You have the option to refuse all cookies on your mobile application, internet browser and/or any other platform that you use to access the Services by changing your mobile or internet browser and platform settings to the extent permissible on your device. However, by doing so, you may not be able to use certain features of the Services and may not be able to take full advantage of all the offerings we have.
7.6 We do not guarantee that disabling, blocking or deleting any of the cookies will prevent tracking of your online behaviour.
8. Contacting us and Grievance Redressal
8.1 If you have any questions about the terms of this Privacy Policy, do not understand any of the provisions or would like us to help you exercise any of your rights provided in this Privacy Policy and applicable law, you can contact our grievance desk at privacy@neo.space.
8.2 If you want to raise any concerns or report a security bug, then you can write to us at privacy@neo.space.