Privacy Policy

This privacy notice for Neario (“we”, “us”, “our”) explains how and why we may collect, store, use and/or share (“process”) your information when you use our services (“Services”), for example when you:

• download and use our mobile application (Neario) or any other application of ours that links to this privacy notice,
• interact with us in other related ways, including sales, marketing or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns after reading this notice, you can contact us at: contact@neario.app.

KEY POINTS SUMMARY

This summary highlights the key points of our privacy notice. You can find more detail about each of these topics in the full text below, using the table of contents.

TABLE OF CONTENTS

1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
6. HOW LONG DO WE KEEP YOUR INFORMATION?
7. HOW DO WE KEEP YOUR INFORMATION SAFE?
8. DO WE COLLECT INFORMATION FROM MINORS?
9. WHAT ARE YOUR PRIVACY RIGHTS?
10. CONTROLS FOR “DO NOT TRACK” FEATURES
11. DO WE MAKE UPDATES TO THIS NOTICE?
12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
13. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?
14. COOKIE INFORMATION FOR THE WWW.NEARIO.APP WEBSITE

1. WHAT INFORMATION DO WE COLLECT?

Personal data you disclose to us

In short: We collect personal data that you voluntarily provide to us.

We collect personal data that you voluntarily provide when you register for the Services, express an interest in obtaining information about us or our products and Services, take part in activities within the Services, or otherwise contact us.

Personal data provided by you. The personal data we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal data we may collect includes, among others:

• first name(s),
• gender,
• photos,
• phone numbers,
• contact preferences,
• contact or authentication details.

Sensitive information We do not process sensitive information.

App data

If you use our app, we may also collect the following information, if you choose to grant us access or the relevant permissions:

• Location information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our app, in order to provide certain location-based services.
• Mobile device access. We may request access or permission to use certain features of your mobile device, including Bluetooth, camera, storage and other functions.
• Mobile device data. We automatically collect device information (such as your mobile device identifier, model and manufacturer), operating system, system version and configuration information.
• Push notifications. We may ask for your permission to send push notifications related to your account or certain features of the app.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve and administer our Services, to communicate with you, to ensure security and prevent fraud, and to comply with legal obligations.

We process your personal data for various reasons, depending on how you use our Services, including:

• to facilitate account creation and authentication, and otherwise manage user accounts,
• to deliver and facilitate the delivery of our Services,
• to respond to user enquiries and provide user support,
• to send you administrative information (for example, changes to our terms, important account information),
• to enable communication between users,
• to request feedback from you and collect your opinions,
• to protect our Services (for example, by detecting misuse and fraud),
• to identify usage trends,
• to save or protect an individual’s vital interests.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In short: We process your personal data only when we believe it is necessary and we have a valid legal basis under applicable law.

We may rely on the following legal bases to process your personal data:

• Consent. We may process your information if you have given us your explicit consent to use your personal data for a specific purpose.
• Performance of a contract. We may process your data when it is necessary to fulfil our contractual obligations towards you.
• Legitimate interests. We may process your information when it is reasonably necessary to achieve our legitimate business interests and does not unduly override your rights and freedoms.
• Legal obligations. We may process your information where it is necessary to comply with legal obligations that apply to us.
• Vital interests. We may process your information where it is necessary to protect your vital interests or the vital interests of another person.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

In short: We may share information in specific situations described in this section and/or with the following categories of third parties.

We may share your data with external vendors, service providers, contractors or agents who perform services for us or on our behalf. The categories of third parties with whom we may share personal data include, among others:

• cloud computing services,
• data analytics services,
• data storage providers,
• performance monitoring tools,
• testing tools,
• website hosting providers.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: We may use cookies and similar tracking technologies to collect and store information.

We may use cookies and similar tracking technologies to access or store information on your device. Detailed information about how we use such technologies and about your related rights can be found in our Cookie Notice, available at: www.neario.app/privacy.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information for as long as necessary to fulfil the purposes described in this privacy notice, unless otherwise required by law.

We will retain your personal data only 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. No purpose in this notice will require us to keep your personal data for longer than twenty-four (24) months after you stop using your user account.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We aim to protect your personal data through appropriate organisational and technical measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of the personal data we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the internet or method of electronic storage can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee absolute security of your data.

8. DO WE COLLECT INFORMATION FROM MINORS?

In short: We do not knowingly collect data from children under 18 years of age or target our Services to them.

We do not knowingly request data from, or market to, children under 18 years of age. By using the Services, you represent that you are at least 18. If you become aware of any data we may have collected from a child under 18, please contact us at: contact@neario.app.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In short: In certain regions, such as the European Economic Area (EEA), the United Kingdom (UK) and Switzerland, you may have specific rights regarding the processing of your personal data.

In these regions, you may have the right to: (i) request access to your personal data and obtain a copy of it; (ii) request rectification (correction) of your data; (iii) request deletion of your data; (iv) request restriction of processing; (v) request data portability; and (vi) object to being subject to decisions based solely on automated processing (including profiling) if such decisions produce legal effects concerning you or similarly significantly affect you.

Account information

If at any time you would like to review or change the information in your account or terminate your account, you can: (i) log in to your account settings in the app and update your details; or (ii) contact us if you need additional support.

10. 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 preference that your online browsing activities not be monitored and collected. At this time, no uniform technological standard for recognising and implementing DNT signals has been agreed upon. As a result, we currently do not respond to DNT browser signals.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In short: Yes, we may 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” / “Last updated” date and will be effective as soon as it is made available. If we make material changes, we may notify you by prominently posting a notice within our Services or by sending you a direct communication.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this privacy notice, you may contact us at: contact@neario.app.

13. HOW CAN YOU REVIEW, UPDATE OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the laws in your country, you may have the right to request access to the personal data we collect from you, to change that information or to delete it. To request to review, update or delete your personal data, you can contact us at: contact@neario.app.

14. COOKIE INFORMATION FOR THE WWW.NEARIO.APP WEBSITE

Cookies are small text files that are stored on the device of a person visiting the Website (for example, on the hard drive of a computer or laptop, or on the memory card of a smartphone – depending on the device you use when visiting the www.neario.app Website). The controller may process data contained in cookies when visitors use the Website for the following purposes:

• remembering data entered into forms;
• customising the content of the www.neario.app Website to the individual preferences of the user (for example, with respect to colours, font size, page layout, language) and optimising the use of the Website’s pages;
• compiling anonymous statistics that show how the pages of the www.neario.app Website are used.

By default, most web browsers available on the market accept the storage of cookies. Each person using the Website can independently define the conditions for the use of cookies in their browser settings.

This means that you can, for example, partially limit (for example, for a certain period of time) or completely disable the ability to store cookies. In the latter case, however, this may affect some of the functionalities available on the pages of the www.neario.app Website. Browser settings related to cookies are important in terms of your consent to the use of cookies by the www.neario.app Website – under applicable law, such consent may also be expressed through appropriate browser settings. If you do not agree to the use of cookies, you should change your browser settings accordingly or refrain from using the Website.

Detailed information on how to change cookie settings and delete cookies yourself in the most popular web browsers is available in the help section of the relevant browser.