Neatro – Privacy Policy

Neatro Technologies Inc. (”Company”, “Neatro”, “Us” or “We”) respect your privacy and are committed to protecting it by complying with this policy.

This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of that personal data.

This policy describes:

How we collect, use, disclose, and protect the personal information of our customers and website users (”you”).
Describes the types of information we may collect from you or that you may provide when you visit the website https://www.neatro.io and/or our web application https://app.neatro.io (individually or collectively our “Platform”).
Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

Privacy laws generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.

This policy applies to information we collect, use, or disclose about you:

On this Platform.
In email, text, and other electronic messages between you and this Platform.
Through mobile and desktop applications you download from this Platform, which provide dedicated non-browser-based interaction between you and this Platform.
On our social media accounts.
When you interact with our advertising and applications on third-party websites and services if those applications or advertising include links to this policy.

The Platform may include links to third-party websites, plug-ins, services, social networks, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share data about you. If you follow a link to a third-party website or engage a third-party plugin, please note that these third parties have their own privacy policies and we do not accept any responsibility or liability for these policies. We do not control these third-party websites, and we encourage you to read the privacy policy of every website you visit.

Please read this policy carefully to understand our policies and practices for collecting, processing, and storing your information. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using this Platform, you indicate that you understand, accept, and consent to the practices described in this policy. This policy may change from time to time. Your continued use of this Platform after we make changes indicates that you accept and consent to those changes, so please check the policy periodically for updates. When we are able to, we will notify you in advance of any material changes to this policy and obtain your consent to any new ways that we collect, use, and disclose your personal information.

LEGAL INFORMATION

PUBLISHER

Neatro Technologies Inc.

304-4141 Boulevard Lasalle,

H4G 0A9, Verdun,

Québec, Canada

Publishing director & Privacy Officer : Benjamin Cotrel

HOSTING

Microsoft Azure (Microsoft Canada Inc.)

1950 Meadowvale Blvd

Mississauga, L5N 8L9

Ontario, Canada

Servers location: Québec

INFORMATION WE COLLECT ABOUT YOU

We collect and use several types of information from and about you, including:

Personal information, that we can reasonably use to directly or indirectly identify you, such as your name, mailing address, e-mail address, telephone number, Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, billing and account information, and any other identifier we may use to contact you (”personal information”).
We provide an opportunity for any user to unsubscribe from our newsletter, cookies or opt-out of contact for marketing purpose on an ongoing basis by using the unsubscribe mechanism at the bottom of our e-mails, or e-mailing to support@neatro.io.
Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users accessing a specific Platform feature.
Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Platform, and usage details.
Non-personal details about your Platform interactions, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Platform (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any email or phone number used to contact our customer service.

Our legal basis for the processing your information are the following:

Based on your consent.
When it is needed to fulfill our legal obligations.
When it is necessary for the performance of a contract between you and us or prior to entering such at your request.
When needed to safeguard the vital interests of yourself or a third-party.
When based on a legitimate interest, such as:
To ensure the security of the Platform, its network and information.
To prevent fraud.
For commercial prospecting operations with you.
For internal administrative management purposes.

HOW WE COLLECT INFORMATION ABOUT YOU

We use different methods to collect your information, including through:

Direct interactions with you when you provide it to us, for example, by filling in forms or corresponding with us by phone, email, chat or otherwise.
User contributions. You may also provide information for us to publish or display on some Platform areas or transmit to other Platform users or third parties.
Automated technologies or interactions, as you navigate through our Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
Third parties or publicly available sources, for example, our business partners.

INFORMATION YOU PROVIDE TO US

The information we collect directly from you on or through our Platform may include:

Information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you report a problem with our Platform.
Account information that you provide by completing your user account, such as name, surname, occupation, profile picture, email and password.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research or improvement purposes.
Details of transactions you carry out through our Platform and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Platform.
Your search queries on the Platform.

You may also provide information to be published or displayed (hereinafter, “posted”) on areas of the Platform or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.

INFORMATION WE COLLECT THROUGH COOKIES AND OTHER AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Platform, we may use cookies or other automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include personal, and we may maintain it or associate it with personal information we collect in other ways, that you provide to us, or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:

Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Platform according to your individual interests.
Speed up your searches.
Recognize you when you return to our Platform.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings that are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

We use cookie information for the following purposes :

Authentication - we use cookies to identify you when you visit our Platform and as you navigate our Platform;
Status - we use cookies to help us to determine if you are logged into our Platform;
Personalization - we use cookies to store information about your preferences and to personalize the Platform for you;
Security - we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our Platform and services generally;
Advertising - we use cookies to help us to display advertisements that will be relevant to you;
Analysis - we use cookies to help us to analyze the use and performance of our Platform and services; and
Cookie consent - we use cookies to store your preferences in relation to the use of cookies more generally.

THIRD PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications on the Platform, including advertisements, are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

Our service providers use cookies and those cookies may be stored on your computer when you visit our Platform.

You can opt-out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. You can also access these websites to learn more about online behavioural advertising and how to stop websites from placing cookies on your device. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us, including any personal information:

To present our Platform and its contents to you.
To security and safety on the Platform.
To provide you with information, products, or services that you request from us.
To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
To provide you with notices about your account or subscription, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts with you, including for billing and collection or to comply with legal requirements.
To notify you about changes to our Platform or any products or services we offer or provide though it.
To improve our Platform, products or services, marketing, or customer relationships and experiences.
To allow you to participate in interactive features, social media, or similar features on our Platform.
To measure or understand the effectiveness of the advertising we serve to you and others, and to deliver relevant advertising to you.
To build the Neatro community.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

We may also use your information to contact you about our own goods and services that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please adjust your user preferences in your account profile, use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at support@neatro.io.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Neatro’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Neatro about you is among the assets transferred.
To advertisers and advertising networks that require the information to select and serve relevant advertisements to you and others. We do not disclose data about identifiable individuals to our advertisers, but we may provide them with aggregate information about our users (for example, we may inform them that 400 women between 30 and 45 have clicked on their advertisement on a specific day). We may also use such aggregate information to help advertisers target a specific audience (for example, men in a specific location). We may make use of the personal information we have collected from you to enable us to display our advertisers’ advertisement to that target audience.
To contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Platform improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your personal information:

To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
To enforce or apply our terms of use or terms of sale and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Neatro, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

TRANSFERRING YOUR INFORMATION

We may transfer personal information that we collect or that you provide as described in this policy to contractors, service providers, and other third parties we use to support our business (such as analytics and search engine providers that assist us with Platform improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this policy.

We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this policy and applicable Québec or Canadian privacy legislation.

You are welcome to contact us to obtain further information about Company policies regarding service providers outside of Canada.

By submitting your personal information or engaging with the Platform, you consent to this transfer, storage, or processing.

DETAILS ON THE PROCESSING OF YOUR PERSONAL INFORMATION BY THIRD-PARTIES

Your personal information is processed for the following purposes using the following third-party services:

Analytics

This is to monitor and analyze Platform traffic and it can be used to keep track of your online behavior.

Google Analytics (Google LLC)

Description: Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the data collected to track and examine the use of the Platform, to prepare reports on its activities and share them with other Google services.

Google may use the information collected to contextualize and personalize the ads of its own advertising network.

Information collected: Cookies, user usage data.

Place of processing: United States

Amplitude

Description: Amplitude is an analysis service of Amplitude Inc. Amplitude tracks events that occur on the Platform. Such events may, for example, be completed retrospectives.

Information collected: Cookies, user usage data, user behavior data.

Place of processing: United States

Handling payments

Unless otherwise specified, we process any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, you are requested to provide your payment details and personal information directly to such payment service providers. We aren’t involved in the collection and processing of such information. We will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Stripe (Stripe Inc)

Description: Stripe is a payment service provided by Stripe Inc.

Information collected: Name, payment details, location.

Place of processing: United States

Managing contacts and sending messages

We use this type of service makes to manage a database of email contacts, phone contacts or any other contact information to communicate with you.

Sendinblue

Description: Sendinblue is an email address management and message sending service.

Information collected: Email address; first name; last name, date and time when the message was viewed, language used, interaction with the message.

Place of processing: European Union

Hubspot

Description: Hubspot is a customer relationship management platform.

Information collected: Name, surname, email, signup date.

Place of processing: United States

Crisp

Description: Crisp is chat service to help offer support to users of the Platform

Information collected: User ID, messages sent to the chat,

Place of processing: European Union

Managing the Platform

Beamer

Description: Beamer is an analysis service of Joincube Inc. It is used to announce updates to users, for other notifications to users and to track feedbacks.

Information collected: User ID, emails, language, reading status of notifications.

Place of processing: United States

Usetiful

Description: Usetiful is a tool created by DobbyTec to improve user onboarding, retention and engagement.

Information collected: Name, surname, e-mail address, user behavior on Neatro’s digital products.

Place of processing: European Union

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this Platform may not be accessible or may not function properly.
Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form where we collect your data or by sending us an email request at support@neatro.io.
Promotional Offers from the Company. If you have opted in to receive certain emails from us but no longer wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an email stating your request tosupport@neatro.io. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe link we have included in the email.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by sending us an email stating your request to support@neatro.io.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of several third party ad servers’ and networks’ cookies simultaneously by using an opt-out tool created by the Digital Advertising Alliance of Canada or an opt-out tool created by the Network Advertising Initiative. Opting out of a network does not mean you will no longer receive online advertising. It does mean that the network from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

DATA SECURITY

The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us behind firewalls on our secure servers. Any payment transactions and all the information that passes between the Neatro application, the server and the database is encrypted with SSL technology.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards, which any Platform visitor can view.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.

DATA RETENTION

Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you or your consent.

AUTOMATED DECISION-MAKING OR PROCESSING OF PERSONAL INFORMATION

Neatro doesn’t process any personal information in an automated way, nor does it use your personal information for automated decision-making.

CHILDREN UNDER THE AGE OF 16

Our Platform is not intended for children under 16 years of age. No one under age 16 may provide any information to the Platform. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Platform or on or through any of its features, moreover do not register on the Platform, do not make any purchases through the Platform, do not use any of the interactive or public comment features of this Platform, or do not provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at support@neatro.io.

YOUR RIGHTS

Your principal rights under data protection law are:

The right to access;
The right to rectification;
The right to erasure;
The right to restrict processing;
The right to object to processing;
The right to data portability;
The right to complain to a supervisory authority; and
The right to withdraw consent.

You have the right to confirmation as to whether or not we process your personal information and, where we do, access to the personal information, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal information concerned and the recipients of the personal information. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal information. The first copy will be provided at cost, but additional copies may be subject to a reasonable fee.

In some circumstances you have the right to the deletion of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to deletion. The general exclusions include where processing is necessary:

For exercising the right of freedom of expression and information;
For compliance with a legal obligation; or
For the establishment, exercise or defense of legal claims.

ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you.

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also send us an email at support@neatro.io to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. We may charge you a fee to access your personal information, however, we will notify you of any fee in advance.

We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation. Examples of such exceptions include:

Information protected by solicitor-client privilege.
Information that is part of a formal dispute resolution process.
Information that is about another individual that would reveal their personal information or confidential commercial information.
Information that is prohibitively expensive to provide.

If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer at benjamin.cotrel@neatro.io.

If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Contributions, is governed by our Terms of use.

WITHDRAWING YOUR CONSENT

Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact us at support@neatro.io. Please note that if you withdraw your consent, we may not be able to provide you with a particular product or service. We will explain the impact to you at the time to help you with your decision.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Platform home page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account or through a notice on the Platform home page.

We include the date the privacy policy was last revised at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.

CONTACT INFORMATION AND COMPLIANCE

We welcome your questions, comments, and requests regarding this privacy policy and our privacy practices. Please contact us at:

By regular mail at:

Neatro - Privacy Officer

304-4141 Boulevard Lasalle,

H4G 0A9, Verdun,

Québec, Canada

By email at:

support@neatro.io

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this policy, and with applicable privacy laws. To discuss our compliance with this policy please contact our Privacy Officer using the contact information listed above.

Last updated – April 13th, 2022