Privacy Policy

Read the End User License Agreement Here

1. INTRODUCTION
This “Neosus” branded mobile application and any services provided through this application (the “Neosus App” and collectively, the “Neosus Apps”) a list of which is available at www.company.neosus.net are provided to you by Neosus UAB, a Lithuanian registered company, with company code 304489602 and its registered office at Svitrigailos g.11B, Vilnius, Lithuania (referred to as “we”, “us” or “our”). Our Privacy Policy applies when you use any of the Neosus Apps and should be read together with the End User License Agreement EULA. By using a Neosus App, you are consenting to our processing of your information in ways set out in this Privacy Policy.

Our Privacy Policy may change so you should review it regularly. We will notify you of any material changes in the way we treat your information through the Neosus Apps you use.

2. DATA WE COLLECT

When you use a Neosus App, Neosus UAB or its trusted partners may collect data from your mobile device, including information which directly or indirectly identifies you. Your information may be kept in an identifiable format, or in an aggregate format which means that you cannot reasonably be identified from it. The information we collect about you (collectively and individually, the “Information”) includes:

If a Neosus App offers you the option to register, we will collect the Information you provide to us in the registration form. This may include identification data such as your name, email address or other account or registration data.

In some cases, a Neosus App may provide you with the option to register using social media account details, like your Facebook, Twitter or other social media account. If you choose to register in this way, we will collect the Information described in the section called “Social Logins” below.

We will also collect your Information when you use Neosus Apps such as when you post or share material, upload data, request further services or make selections using the Neosus Apps, if such functionality is available in the Neosus App.

If you opt-in, some Neosus Apps may collect movement data from your phone.

We will collect Information about you when you interact with us such as when you report a problem, contact or communicate with us.

Geolocation data, which is any Information which indicates the geographical position of your device and which may include the time the location was recorded, and may include precise (e.g., GPS-level) location data. Some Neosus Apps may collect this data when the App is not open or actively in use (This may help us or third parties to customize information, content, or offers to you, for instance.) The Neosus App and/or your mobile device may provide options for you to control the use and/or sharing of precise device location data.

Any of your Information you provide or permit to be provided to us via a social network or public forum provider like Facebook, including when you link a Neosus App to your social network or public forum account (e.g. for registration or social sharing purposes). This data may include your use of the Neosus App on such public forums and/or social networks, including with whom you share the Neosus App. For further information as to how and for what purpose the social network or public forum provider collects, uses and shares your data, as well as how you can set your privacy preferences on their site or apps, please see their privacy policy.

We automatically collect certain Information from your device when you use the Neosus App including Information about your device, carrier and other technical data.

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We use, save and analyze the information you provide about yourself and about your Third-Party Sites (together “Data Processing”). Such Data Processing is necessary to perform our Services to you, including our Terms of Service and our legitimate business interests, including:

— to fulfill your requests for our products, programs and Services and process and analyze your application;
— to respond to your inquiries about our Services;
— to provide customer support;
— to offer you other products, programs, or services that we believe may be of interest to you;
— to verify the existence and condition of your accounts and conduct due diligence;
— to fulfill legal requirements;
— to protect against potentially prohibited or illegal activities;
— to improve (including through data analytics), monitor and personalize the Services and conduct our business and to provide targeted marketing and advertising;
— to measure the performance of and improve the Site or mobile application functionality;
— to manage, administer and protect our information technology infrastructure and Site security generally.

When you provide information to us you agree to give us your consent to use, collect, monitor and process it according to the following Privacy Policy.

Neosus may also disclose aggregated user statistics in order to describe our services to current and prospective business or financing partners, and to other third parties for other lawful purposes.

3. HOW WE USE THE INFORMATION WE COLLECT

We may use the Information (elements of which we may use alone or in combination with each other data/Information) we collect to:

Deliver the Neosus Apps to you and ensure their optimal functionality and operation;

Enable you to register and create an account with the Neosus Apps;

Provide you with customer support;

Perform research and analysis about your use of, or interest in, our products, services, or content;

If you have registered with a Neosus App using your social media account details, we may use the Information we receive from your social media provider to identify which of your friends are also using the Neosus App so that you can connect with them in our app;

Communicate with you by e-mail, postal mail, telephone and/or mobile devices (including through in-application advertising) about products or services that may be of interest to you either from us, our parent or subsidiary companies or other third parties. If you do not wish to receive in-application advertising, in some cases you can upgrade to the paid version of the app;

Develop and display content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness. For instance, we, or these third parties may serve music-related ads or offers to users who have installed music-related apps (whether or not these are Neosus Apps). Similarly, users who frequently visit music-related venues may likewise receive ads or offers to install music-related apps;

Verify your eligibility and deliver prizes in connection with contests and sweepstakes and in order to conduct polls and surveys;

Enforce our terms, conditions and policies and to communicate with you;

Manage and improve the Neosus App(s). For this purpose, we may use and combine your Information which we collect across different Neosus Apps used by you;

When we collect your precise geolocation data (subject to your consent) (which may be via the device’s cellular, Wi-Fi, Global Positioning System (GPS) networks and/or Bluetooth information), we do so to provide you with our location-related products and services, for example to provide you with forecast and weather alerts for your location, and also to facilitate, measure, or otherwise support advertising by third parties (through our apps or third parties’ apps) that may be related to your location over time.

When you share your Information with us via a social network provider like Facebook, we use this to show Information on your social network profile (subject to your privacy setting and preferences for such social network) and to allow you to share Information about our services with your connections or on your social network profile.

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Information collected by us may be transferred to our corporate affiliates or our subcontractors. We may share your personal information in a manner consistent with this Privacy Policy, and if we or our assets are acquired or transferred in part or whole to another organization, your information and any other information we have collected may be among the items transferred.

We may make inquiries, whether directly or through third parties, that we consider necessary to verify your identity or protect you and/or us against fraud or other financial crime, and to take action we reasonably deem necessary based on the results of such inquiries. You hereby acknowledge that we shall have the right to investigate you in case we determine you to be risky or suspicious.

When personal information is to be transferred in a country that has not been designated by the European Commission as providing an adequate level of protection for personal information, we will ensure an adequate level of protection by any of the recognized methods, including but not limited to entry into the standard contractual clauses for the transfer of personal information to processors established in third countries approved by the European Commission from time to time.

We may also disclose your personal information when we have a good faith belief that (i) we are required to do so by law, or in response to a subpoena, court order, or other legal mechanism, or (ii) it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations.

We do not sell your personal information to third parties.

If you are the European resident, and as a data subject (a person whose personal information is collected, stored and processed) you have several rights under GDPR:

Right of access. You have the right to obtain confirmation if your personal information is being processed by us. If that is the case, you can access your personal information and the following information: (a) the purposes of the processing; (b) the categories of personal information; (c) to whom the personal information has been or will be disclosed; (d) the envisaged period for which the personal information will be stored, or the criteria used to determine that period.

Right to rectification. You have the right to demand that we correct without undue delay your personal information which we have in our systems if it is inaccurate or incomplete.

Right to erasure (‘right to be forgotten’). You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies: (a) this personal information is no longer necessary in relation to the purposes for which it was processed; (b) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (c) you object to the processing and there are no overriding legitimate grounds; (d) your personal information has been unlawfully processed; (e) your personal information has to be erased for compliance with a legal obligation.

Right to restrict processing. You have the right to restrict us in the ability of processing of your information where one of the following applies: (a) you contest the accuracy of your personal information and we are verifying it; (b) the processing is unlawful and you want to restrict it instead of erasure; (c) we no longer need your personal information, but you need it for establishment, exercise or defense of legal claims; (d) you have objected to processing and we are verifying whether legitimate grounds override your request.

Right to data portability. You have the right to receive your personal information which you provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another company, where: (a) the processing is based on your consent or on a contract; and (b) the processing is carried out by automated means.

Where technically feasible, you can demand that we transmit those data directly to another company.

Right to object. You have the right to object to the processing of your personal information based on our legitimate interests. We shall no longer process your personal information unless we demonstrate compelling legitimate grounds for the processing or for the establishment, exercise or defense of legal claims.

Where personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal information for such marketing.

Automated individual decision-making, including profiling. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on you. Please note that we don’t make any automated decisions including profiling based on information that we have about you.

Right to withdraw consent. You have the right to withdraw your consent for processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Right to lodge a complaint. 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 the alleged infringement if you consider that the processing of your personal information infringes GDPR.

Breach Notification. If a breach/unauthorized access of personal information takes place that is likely to “result in a risk for the rights and freedoms of individuals”, we will notify the supervisory authority within 72 hours of becoming aware of the breach.

4. CROSS-APP ADVERTISING AND OTHER INTEREST-BASED ADVERTISING TECHNOLOGIES2. DATA WE COLLECT

As described in Sections 3 and 5 of this Privacy Policy, we sometimes work with third parties to deliver ads, content or offers. Sometimes we or these third parties do so through a mobile “SDK.” The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected, and related services to be implemented. We may use this and similar technology to deliver certain advertising through mobile applications and browsers based on data associated with your mobile device, and we may work with third parties who likewise embed their SDKs into Neosus Apps, for third party advertising. If you’d like to opt-out from having ads tailored to you in this way on your mobile device, please follow the instructions below.

If you wish to opt out of interest-based cross-application tracking through your mobile device, you can do so through your device “settings”, as follows (but please note that the below is for informational purposes only and Apple, Google, or other device platforms may change the manner in which their “opt out” settings work at any time): Please note that if you opt out through these settings, you will continue to receive advertising after you opt-out, but it may not be tailored to your interests. For instance, that advertising may be based on your real-time or “contextual” application usage or general location inferred from IP address.

Opting Out on iOS Devices Such as iPhones, iPads or iPods

If you have an Apple device, you can opt out of mobile interest-based or “cross-app” advertising by updating to iOS 6.0 or higher, and setting Limit Ad Tracking to ‘ON’. On an iPhone 6 for example, you can do this by clicking on Settings -> General -> Privacy -> Advertising and toggling “Limit Ad Tracking” to ‘ON’. Our systems are designed to respect your choice and not use Information to provide interest-based advertising when this setting is ON.

We may sometimes work with partners to help us or help them correlate content or ads provided to users across devices or browsers. For instance, a brand may wish to use the Information that we collect (or data that its own partners collect) to send offers to its customers across both mobile applications and browsers. We thus also provide the links below to the NAI “Consumer Opt-out,” DAA opt-out, and Google opt-out that are only applicable to participating third parties, which does not include Neosus UAB You may also block certain App Identifiers by changing the settings of your device. However, we do not currently recognize or respond to browser-initiated Do Not Track signals, as the Internet industry has not reached a consensus as to Do Not Track standards, implementations and solutions.

https://support.google.com/ads/answer/2662922?hl=en

http://www.networkadvertising.org/choices/

http://www.aboutads.info/choices/

We also use a third party service called MoPub and we may transfer your information to MoPub in accordance with the following policy: https://www.mopub.com/legal/privacy/

We also use a third party service called Appsflyer and we may transfer your information to Appsflyer in accordance with the following policy https://www.appsflyer.com/privacy-policy/

5. SHARING YOUR INFORMATION

We may share your Information as follows:

We may share your Information with our authorized service providers that perform certain services on our behalf. These services may include providing customer service and marketing assistance, performing business and sales analysis, supporting our Neosus Apps functionality, and supporting marketing promotions (e.g., contests and sweepstakes) surveys and other features offered through our Neosus Apps. These service providers may have limited access to your Information, which is needed to perform their functions, but are not permitted to share or use such Information for any other purposes.

When you engage in promotions offered through the Neosus Apps, we may share your Information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes; unless, we have otherwise committed to you that we will not share specific Information you provided. When you elect to engage in a particular merchant’s offer or program, you authorize us to provide your email address and other Information to that merchant.

We may also allow third-parties, including our authorized service providers, parent and subsidiary companies, affiliates, advertising companies and ad networks, to display advertisements in the Neosus Apps or other apps or use App Identifiers for the purpose of advertising and direct marketing. These companies may use technologies to collect data about users, including non-precise and/or precise location data, to help them tailor relevant ads and content and analyze and measure ads’ effectiveness or, more generally, brand and mobile audiences. These companies may collect this data through SDKs or from users who view or interact with their advertisements. We combine Information internally at Neosus UAB across different Neosus Apps. This will enable us to provide more tailored and personal experiences and services to you across our family of Neosus Apps which are described www.neosus.net

Other Situations. We may disclose your Information (i) to respond in good faith to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; (ii) in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; (iii) to protect and defend the rights, property or safety of our company, our users, our employees, or others; (iv) to comply with applicable law or cooperate with law enforcement; (v) to enforce our Neosus Apps terms and conditions or other agreements or policies; and (vi) in connection with a substantial corporate transaction, such as the sale of our business or the Neosus Apps, a divestiture, merger, consolidation, or asset sale or transfer, or in the unlikely event of bankruptcy. In addition, we may share aggregated Information we collect, under any of the above circumstances, with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis or other legitimate business purposes. Please note that such aggregated Information will not include any Information which allows third parties to identify you.

6. COOKIES, IDENTIFIERS AND DATA ANALYSIS

We may collect certain device data and electronic identifiers such as the mobile device identifier provided by your mobile device operating system, your mobile operating system details and the name of your mobile carrier. For example, if you use the iOS platform then Advertiser IDs (also known as “IDFAs” if you have an Apple device) may be collected. Other identifiers collected may include IP addresses, OpenUDID, Session ID, ODIn1, iOS Vendor IDs, MAC addresses, IMEI and ODIN1 for OS X (together with the IDFAs, the “App Identifiers”).

When you use the Neosus App(s), we may use the App Identifiers to facilitate access to the Neosus Apps, help us recognize you across different Neosus Apps, to enable you to use the Neosus Apps, to personalize your experience, to increase security, measure the use and effectiveness of our Neosus Apps and serve advertising. You can block certain App Identifiers by changing the settings of your device.

We also collect information about how and when you use the Neosus App. This includes the amount of times you used the Neosus App, which parts of it you viewed and other technical data such as country settings and timestamps.

Firebase

Neosus uses the Google Analytics tool Firebase in order to carry out analysis on Information which is gathered by Neosus Apps. App Identifiers and other Information which Neosus gather are provided to Google in order to enable them to carry out data analysis. Any Information (including App Identifiers) which are provided to Google will become subject to Google’s privacy policy which is located here: www.google.com/privacy.html.

For further information on how Google’s Firebase analytics tool uses data, please see the site “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/).

Cookies and our Websites

Separately to the Neosus Apps, the Neosus websites use cookies. Certain information about you, (including personal information), may be collected through the use of cookies when you visit and interact with our websites. Some of these cookies are essential for the Neosus websites to operate and ensure that we provide the services you requested. By using our services you agree to the use of certain non-essential cookies unless you set your browser to reject them.

A cookie is a small text file that is stored on your computer’s hard drive or browser. We use cookies and the information contained therein for a number of purposes including but not limited to:

tracking the duration of visits and content accessed; and

storing frequently used user information to personalize your online experience and ease the log-in process.

You may block cookies by activating the setting on your browser which allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies as soon you visit our websites. Further information on cookies and how websites use them can be obtained at www.cookiecentral.com

7. HOW WE PROTECT YOUR INFORMATION

The security and confidentiality of your Information are very important to us, so we take security measures (including physical, electronic and procedural measures) to help safeguard your information from unauthorized access and disclosure. Please know that, despite our efforts, no security measures are perfect or impenetrable.

8. INFORMATION RELATING TO CHILDREN

The Neosus Apps are not directed to children under the age of 13. If we become aware that Information has been collected from a person under the age of 13, we will delete this Information and terminate the person’s account as quickly as possible. If you believe that we may have Information from or about a child under the age of 13, please contact us at privacy@neosus.net and we will promptly delete that Information.

9. SOCIAL LOGINS

Some of the Neosus Apps may offer you the ability to register and login using your third party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile Information about you from your social media provider. The profile Information we receive may very depending on the Neosus App you are using, and on the social media provider concerned, but will often include your name, e-mail address, mobile phone number and friends list. We will use the Information we receive only for the purposes that are described in this Privacy Policy or that are otherwise made clear to you in the Neosus App you are using. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you see their privacy policy to understand how they collect, use and share your Information, and how you can set your privacy preferences on their sites and apps.

10. WHERE WE STORE YOUR INFORMATION

The Information that we collect from you may be transferred to, and stored at, a destination outside of your country and the European Economic Area (“EEA”) and, in particular, the US, which may have different or less protective privacy laws than those in your country. The Information may also be processed by any service providers appointed by us who operate outside the EEA and their staff, and/or our own staff based outside of the EEA. By submitting or permitting us to collect your Information, you agree to this transfer, storing or processing outside of the EEA. Information transferred will be treated in accordance with this Privacy Policy.

11. HOW LONG WE STORE YOUR INFORMATION

We will keep your Information for as long as is necessary to provide you with the Neosus Apps and for us to comply with our obligations under this Privacy Policy and at law. We may retain data after you cease using the Neosus Apps, for instance, for operational, auditing, content or ad measurement purposes, or to analyze and improve the way we provide our services.

12. DATA DELETION

Uninstallation and removal methods vary depending on your device. To uninstall and remove the Neosus Apps, please use the application manager provided with your device or consult your device manual or online instructions provided by the device provider for reference.

13. ACCESS TO AND CHOICES REGARDING YOUR INFORMATION

You may have the right to access Information held about you or require it to be modified (if inaccurate) or deleted. Your right of access can be exercised by contacting us using the details set out below. Any access request may be subject to a fee to meet our costs in providing you with details of the Information we hold about you.

14. HOW TO CONTACT US

If you have any questions about this Privacy Policy or our Information-handling practices, or wish to review, amend or delete any Information we are storing, please contact us by email or postal mail as follows:

Neosus UAB

Svitrigailos g.11B

Vilnius, Lithuania

privacy@neosus.net