PRIVACY POLICY – NEOGRID

 

The purpose of this Privacy Policy is to demonstrate the commitment of Neogrid:

a. Neogrid Europe Ltd., registered in the United Kingdom with the number 7717968, at 8-10 Upper Marlborough Road, St Albans AL1 3UR;

b. Neogrid Netherlands B.V., registered in the Netherlands with the number 3416.6499, at Science Park 406, 1098 XH Amsterdam;

c. Neogrid North America Ltd., registered in the United States of America with the number 52-2242825, at 55 West Monroe Street, Suite 3590, 60603 Chicago, IL;

d. Neogrid Japan, located at New Otani Garden Court 7F, 4-1 Kioi-cho, Chiyoda-ku, Tokyo 102-0094;

e. Neogrid Software, registered in Brazil, at Avenida Santos Dumont, 935, CEP 89223-002,  Joinville, Santa Catarina and

f. Neogrid Informatica, registered in Brazil, at Avenida Santos Dumont,  935, CEP 89223-002, Joinville, Santa Catarina.

To maintaining the privacy and protection of personal data collected from its users, establishing the rules on the collection, registration, storage, use, sharing, enrichment and elimination of data collected from users, within the scope of the Platform's services and functionalities, in accordance with the law, and to provide transparency and clarity to both the user and the market.

As a condition of access and use of the Platform's unique features, the user declares that he/she has fully read this Privacy Policy, being aware of its terms, thereby granting his/her free and express consent with the terms set forth herein.

 

1. DATA COLLECTION AND RECORD OF ACTIVITIES

1.1. Data is collected when entered or voluntarily submitted to the Platform by the user during, but not limited to, his/her access, account creation and navigation and contracting/usage of services. Additionally, the Platform can record the logs of all the activities performed by the user.

1.2. The only data collected before the user registers on the Platform are the IP address and geolocation, according to our Cookies Policy.

1.3. The data that Neogrid collects after a user registers on the platform are:

  • a) Full name,
  • b) Telephone number,
  • c) Mobile number,
  • d) E-mail address,
  • e) Address,
  • f) Product category,
  • g) Time zone,
  • h) Currency
  • i) Language (for application operation)

1.4. Neogrid is not responsible for the accuracy and veracity of the information provided by our users or if this data is outdated. It is the user’s responsibility to provide accurate data and update it as needed.

1.5. The activities that the Platform may track include:

  • a) User’s IP address, Logic Ports and geolocation,
  • b) Actions carried out by users in the Platform,
  • c) Screens accessed by users,
  • d) Dates and times of each activity performed, as well as the user's access to the Platform,
  • e) Data about the device used by the user, e.g. operating system version, browser, geolocation and other installed applications, if necessary,
  • f) User’s Session ID, when available,
  • g) History of operations performed, and,
  • h) Behaviors identified in interactions with the Platform.

1.6. The platform can also make use of technologies like:

  • a) Cookies, which the user can manage to block using his/her Internet browser setting options. In this case, some of the features offered by the Platform may be limited;
  • b) Web Beacons to collect user’s behavior data, when accessing pages, in which case the installation of files in the device may not be required;
  • c) Beacons that emit signals from Bluetooth Low Energy (BLE) technology, which can be picked up by technological resources that allow interaction between the user and a technological resource;
  • d) Other technologies for obtaining the user’s navigation data (API analytics).

1.7. Once on the Platform, the user may be led, via link, content or services, to non-Neogrid portals or platforms, which may collect the user’s information and have their own privacy policy.

  • 1.7.1 It is responsibiliy of the user to read the privacy policy of all platforms outside the Neogrid environment , and either accept or reject the policy.
  • 1.7.2 Neogrid is not responsible for the privacy policy or content of any websites, content or services outside of the Neogrid Platform.

 

2. DATA USAGE

2.1. The data collected from Neogrid users and the records of the activities can be used for the following purposes:

  • a) Identify and authenticate users appropriately, in addition to processing access account transactions;
  • b) Provide communication between buyers and suppliers, so that buyers can request quotes and other information (delivery dates, available quantity, information about quality, etc.) for the products they want to purchase;
  • c) Ensure that suppliers receive email notifications and can respond to buyers using the Neogrid system;
  • d) Manage system functions, provide services and fulfil obligations arising from the use of Neogrid’s services;
  • e) Provide user support, including answering to questions about the Platform;
  • f) Optimize use and improve the user experience;
  • g) Perform statistics, studies, research and surveys relevant to activities of user’s behavior while using the platform;
  • h) Promote Neogrid services and products, as well as for the following Neogrid companies: Neogrid Netherlands Holding B.V. (Amsterdam Netherlands), Neogrid Netherlands B.V. (Amsterdam - Netherlands), Neogrid North America LLC (Chicago Office - Delaware LLC), Neogrid AP Inc (Tokyo - Japan), Neogrid International LLC (Delaware - USA), Neogrid International French Branch, Neogrid Europe Ltd (St. Albans - UK), Neogrid Software S.A. (Brazil), Neogrid Informática S.A. (Brazil), Rio Pardo Vegetal Protein S.A. (Brazil), Neogrid Datacenter S.A. (Brazil), Camerite Informáática Publicidade e Monitoramento S.A. (Brazil);
  • i) Inform users about news, features, content and other events relevant to maintaining the relationship with our users,
  • j) To safeguard Neogrid’s rights and obligations related to the use of the Platform, as means of evidence in cases of unlawful acts or acts contrary to this privacy policy or any other legal document provided by Neogrid; in case of improper changes in their systems and records or actions that may jeopardize the platform and its users; and
  • k) To enrich the Neogrid database and prevent the occurrence of fraud.

2.2. User consent for data usage:

  • 2.2.1 The consent for the aforementioned purposes will be collected on an individual basis, and the user is not obliged to consent with any of them.
    • 2.2.1.1 If the user does not consent with a certain use of his/her personal data which is required to enable the provision of services by Neogrid, these services will not be provided to the user.
    • 2.2.1.2 If the user does not consent to an use of his/her personal data that is not required to enable the provision of services by Neogrid, the provision of these services will be maintained.
  • 2.2.2 The user can change his/her consent by opening a support ticket with Neogrid, and may grant new permissions or withdraw consent from the current permissions, being previously informed of all the effects caused in service availability at all times.

2.3. The collected data and recorded activities may also be shared:

  • 2.3.1 With relevant legal, administrative or governmental authorities, whenever applicable, requested or ordered by court;
  • 2.3.2 Automatically with the other company(ies) involved in case of a merger, acquisition or incorporation;
  • 2.3.3. Automatically with the following categories of companies that provide services for Neogrid to collect, process, or use personal data on behalf and according to the instructions of Neogrid and for the respective purposes:
    • a) Hosting Services Providers – Data Center Services for colocation and/or hosting services;
    • b) Software as a Services – used for data processing for internal management;
    • c) Software and Hardware Maintenances Suppliers - for replacement and maintenance of defective parts as well as for software updates;
    • d) Telecommunication Services - Data link and internet connectivity;
    • e) Advisory support (information technology, legal, administrative, accounting, human resources) – for operational management and internal procedures;
    • f) Advertising agencies – to send Neogrid’ s newsletters and advertisements;
    • g) Mobile and phone services – to communicate with customers and prospects;
    • h) Carriage and postal services – to send Neogrid’s newsletters and advertisements;
    • i) Insurance and financial services (banks, brokers) – to process payments and implement insurance;
    • j) Travel agencies – to arrange trips to meet customers and prospects.
    • k) Event management – organizers to communicate with customers and prospects.
    • l) Marketing platforms – to communicate with customer and prospects
  • 2.3.4 If these external companies have access to personal data, Neogrid guarantees that the respective parties have previously signed data processing and confidentiality agreements with Neogrid to comply with the applicable data protection legislation.
  • 2.3.5. These service providers may be located at the European Union, Brazil, the Netherlands, Japan, the United Kingdom and the United States, and the international data transfers shall be made according to section 6 (International Data Transfers).

2.4. Neogrid is the sole responsible for the database formed by collecting data from its platform.

2.5. The use, access and sharing of data from Neogrid’s database will only be made within the limits and purposes hereby established.

2.6. Neogrid may also share data from its database with the authorities whenever legally required.

2.7. The user is responsible for the confidentiality of his/her personal data. Sharing passwords and login details violates this privacy policy and the terms and conditions of use of our Platform.

2.8. Internally, access to user’s data is restricted to authorized Neogrid employees only.

 

3. STORAGE OF DATA

3.1. The user’s data collected by Neogrid is stored in a safe and controlled environment and kept for a period of at least 6 (six) months. This period may differ depending on specific customer requirements. However, considering that no security system is foolproof, Neogrid will not be responsible for any damages and/or losses arising from technical faults, viruses or intrusions in Neogrid’s database, except in cases of fraud or fault.

  • 3.1.1 Data may be erased before 6 (six) months at the user’s request and if there is no legal obligation to keep this data stored.
  • 3.1.2 Anonymized data may be kept by Neogrid for more than 6 (six) months.

3.2. The data obtained from users are stored on SaaS datacenters or on-premise infrastructure. Datacenters can be third party infrastructure, Cloud or Neogrid’s own datacenters, which are located in the United States and Brazil.

 

4. VIEW, RECTIFICATION, OPPOSITION, LIMITATION AND DELETING DATA

4.1 Users may request to view or change personal information through their account or support tools made available by Neogrid.

4.2 When contacting Support, users may request a limitation on the use of their personal data.

4.3 The user can express opposition to the use of their personal data or the deletion of personal data collected and recorded by Neogrid.

4.4 Once the contract between the user and Neogrid has ended, any accounts are cancelled and the access is revoked.

4.5 If the user removes his/her consent for purposes that enable the proper functioning of the Platform, the Platform features and services may become unavailable to that user.

4.6 Neogrid can (for auditing, security, fraud control and preservation of rights purposes) retain the user’s data record history for a period longer than the law or regulatory standard establish.

 

5. DATA RECIPIENTS

5.1. Your personal data will be processed by persons of Neogrid in the respective departments who need to know the personal data:

  • a) Contact data: any departments that might be involved to process your request;
  • b) Comment data: marketing or the respective product departments that are responsible for operating the blogs or discussion boards;
  • c) Job application data: HR and the departments that are responsible for the job position that you apply to;
  • d) Direct marketing data: marketing and sales departments responsible for your region;
  • e) Browser data and usage data: marketing and the IT departments that are responsible for operating the respective websites.

5.2. Neogrid is a globally operating corporation. In order to better process your matter, it might be necessary to forward your data to local subsidiaries or to local distribution partners, whose registered office might also be located in other countries (see section 6). However, such data transfers only take place within the Neogrid group companies, and the lawfulness of the data export will be based either on an adequacy decision by the EU Commission or on standard contractual clauses.

5.3. Beyond that, we do not forward your data to other third parties, unless we are obliged to do so by EU statutory provisions or order of any EU judicial or other public authorities or if you have explicitly requested data portability or given your consent for that purpose. Your personal data will not be sold, leased or exchanged.

 

6. INTERNATIONAL DATA TRANSFERS

6.1. The recipients of your personal data might be located outside the European Union or the European Economic Area where data protection laws may not be equivalent to EU data protection law. In such cases, the recipient will be requested to have measures in place to protect your data.

6.2. We will take all necessary measures to ensure that transfers to such organizations are adequately protected according to the applicable data protection legislation, e.g. by signing the standard contractual clauses stipulated by the EU Commission with the data recipients. You may request a copy of these reasonable warranties by contacting our Data Protection Department at: dpo@neogrid.com

6.3. If a data transfer to official authorities in countries outside the European Union or the European Economic Area (so-called third countries) is required to take place, and if it is not required by law, by consenting to this Privacy Policy you have given us your express consent for that international data transfer to take place.

 

7. GENERAL PROVISIONS

7.1. The Platform does not use any type of automated decision that impacts the user.

7.2. Neogrid can change the content of this privacy policy at any time, depending on the purpose or need, to comply with any new legal provisions. Users are responsible to review any changes made to this privacy policy.

  • 7.2.1. In the case of significant updates to the privacy policy and that require new consent by the user, Neogrid shall notify users through the tools available in the platform and/or the support tools available.

7.3. If you have questions about this policy, please contact NEOGRID via the service channel https://neogrid.com/en/contact.

7.4. If contractors process any data collected or processed by Neogrid, they shall comply with the conditions stipulated herein and with Neogrid’s information security standards.

7.5. If any provision of this privacy policy is deemed unlawful or illegitimate by a local authority where the user lives or from his/her internet connection, all the other conditions will remain in full force and effect.

7.6. The user acknowledges that all communication performed by e-mail (to e-mail addresses informed by the user), SMS, instant messaging applications or any other virtual and digital form, are also valid, effective and sufficient for disclosure of any matter that relates to services provided by Neogrid, as well as the conditions of provision of services or any other issue regarding it, except where expressly provided as the contrary in this privacy policy.

 

8. GLOSSARY

8.1. For the purposes of this document, you must consider the following definitions and descriptions for your better understanding:

Beacons: Small devices using Bluetooth Low Energy (BLE), which emit signals that can be picked up by technological resources, enabling interaction between the user and the use of technology. The Web Beacons are programs that aims to monitor a user's navigation in a Web page.

Cloud Computing: Service virtualization technology built from the interconnection of more than one server through a common information network (e.g. the Internet), in order to reduce costs and increase the availability of services supported.

Cookies: Files sent by the server to the computer of the users, in order to identify the computer and get data access, such as browsed pages or links accessed, allowing in this way to customize the navigation of users in platform, according to your profile.

User Account: A user credential that may be required to use or access the restricted area and unique features of the platform offered by Neogrid.

IP: Abbreviation for Internet Protocol. This is the alphanumeric set that identifies users' devices on the Internet.

Logs: Records of users ' activities carried out on the Neogrid platform.

Platform: Neogrid’s virtual environment that connects corporate buyers and purchasers.

Session ID: Identification of the user’s session in the process of purchasing services or when accessing a restricted area.

Users: Individuals who access or participate in activities within the Neogrid platform.

 

9. APPLICABLE LAW AND JURISDICTION

9.1. This privacy policy will be governed by and construed according to the user’s local legislation, in the user’s local language, being elected the jurisdiction of the user’s domicile to resolve any dispute or controversy based on this document, except where expressly provided as the contrary by relevant legislation.

Privacy questions or requests may be forwarded to the current Data Protection Officer of Neogrid, Leandro Fabricio Dix, by e-mail dpo@neogrid.com or by regular mail the address below:

Neogrid Europe Ltd.
8-10 Upper Marlborough Road
St Albans, United Kingdom
AL1 3UR

We thank you for your attention, and welcome to Neogrid!

Update: Oct 18th, 2018.

 

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