Privacy Policy

Effective date: March 7, 2019, amended October 1, 2023, effective date November 1, 2023.

Neptune Labs, Inc. or any of its subsidiaries hereinafter referred to as “Neptune Labs”, “neptune.ai” or the “Company”, is committed to protecting the privacy of your information. In order to ensure the safety of and respect for your rights, in particular the right to privacy, Neptune Labs introduces the following policy and clarifies the rules for use, collection and processing of personal data. 

In personal data processing, Neptune Labs abide by the following guidelines, complying with at least one personal data processing basis. 

Data Controller (“Controller”): Your personal data is controlled by Neptune Labs, Inc., 2100 Geng Road, Suite 210, Palo Alto, CA 94303, United States of America. 

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, please contact us at dpo@neptune.ai.

1. Rules and legal basis 

When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Neptune Labs Inc. and the Services, the choices you make, and the products and features you use. 

Neptune Labs hereby informs you that your personal data will, at all times, be:

• processed lawfully, reliably and transparently;
• collected for specific, explicit and legitimate purposes, and not further processed in a manner inconsistent with those purposes; 
• adequate, relevant and limited to what is required for the purposes, i.e. data minimization;
• corrected and updated as required; 
• kept in a form enabling identification of the Data Subject for a period which shall not be longer than required for the purposes for which the data is processed;
• processed in a manner ensuring adequate safety of personal data: protection against unauthorized or illegal processing and accidental loss, destruction or damage with the application of adequate technical and organizational means. 
• We do not process sensitive personal information

Neptune Labs processes personal data in compliance with the law on following legal basis: 

• the Data Subject has expressed consent to the processing of their personal data for one or multiple specific purposes; 
• processing is necessary for the performance of an agreement to which the Data Subject is a party or in order to take steps at the request of the Data Subject prior to entering into an agreement; 
• processing is necessary for compliance with a legal obligation to which the Controller is subject; 
• processing is necessary for the purposes of the legitimate interests pursued by a Controller, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of personal data. 
• We do not process sensitive personal information.

We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.

2. The “In Short” section does not constitute a legally binding contract or create any legal obligations between the user and our organization. It is a condensed summary provided for your convenience, outlining the key points of data protection practices.

3. Web Sites Covered

The information practices of neptune.ai and any of its subdomains are covered by this PP. These are referred to as Neptune Labs’ “sites” altogether. Additionally, when you interact with us in other ways that are relevant to those interactions, such as during any sales, marketing, or events, we may collect, store, use, and/or share (“process”) your information.

4. Information Collected

In Short: We collect personal information that you provide to us.

Neptune Labs offers a variety of services that are collectively referred to as the “Services.” Neptune Labs collects information from users who visit the Company’s Web sites (“Visitors”) and users who register to use the Services (“Customers”). We do not process sensitive information.

When expressing an interest in obtaining additional information about the Services or registering to use the Services, Neptune Labs requires you to provide the Company contact information, such as full name, company name, address, phone number, and company email address (“Required Contact Information”). When purchasing the Services, Neptune Labs requires you to provide the Company with billing information, such as billing name and address, credit card number, and the number of employees within the organization that will be using the Services (“Billing Information”). Neptune Labs may also ask you to provide additional information, such as company annual revenues, number of employees, or industry (“Optional Information”). Neptune Labs might also ask you to complete surveys from time to time (“Optional Surveys”). 

Required Contact Information, Billing Information, Optional Information and Optional Surveys are referred to collectively as “Users Personal Information”.

As you navigate the Company’s website, Neptune Labs may also collect information through the use of commonly used information-gathering tools, such as cookies and Web beacons (“Web Sites Navigational Information”). 

Web Sites Navigational Information includes standard information from your Web browser (such as browser type and browser language), your Internet Protocol (“IP”) address, and the actions you take on the Company’s Web sites (such as the Web pages viewed and the links clicked). In addition, we may use third-party services, such as “Google Analytics”, that collect, monitor and analyze this type of information in order to increase our Service’s functionality. These third parties may use cookies to help us analyze how our users are using the Service and they have their own Privacy Policies addressing how they use such information. 

• Google Analytics
  • Google Analytics service is provided by Google Inc. 
  • You can opt-out from Google Analytics service using your information by installing the Google Analytics Opt-out Browser tool: https://tools.google.com/dlpage/gaoptout​. 
  • For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://www.google.com/policies/privacy​. 
• Heap Analytics 
  • Heap Analytics service is provided by Heap Inc. 
  • For more information on the privacy practices of Heap, please visit the Heap Analytics web page: ​https://heapanalytics.com/privacy​. 
  • For more information on what type of information Heap collects, please visit the Terms of Use page of Heap: ​https://heapanalytics.com/terms​. 
• Intercom 
  • Intercom is provided by Intercom, Inc 
  • By using Intercom on Neptune website you acknowledge and agree on our Terms of Services as well as on the Intercom Terms and Policies. 
  • For more information on what type of information Intercom collects please visit Intercom Terms and Policies: https://www.intercom.com/terms-and-policies#terms

• Zendesk
  • Zendesk is provided by Zendesk, Inc.
  • Zendesk services are utilised by the Company in order to provide a help desk management solution to the users.
  • For more information on the privacy practices of Zendesk, please visit the Zendesk data protection and privacy web page: https://www.zendesk.com/trust-center

• Hubspot
  
  • Hubspot is provided by HubSpot, Inc
  • The Company utilizes the Hubspot CRM platform to provide the service.
  • For more information on the privacy practices of Hubspot, please visit the Hubspot data protection and privacy web page: https://legal.hubspot.com/privacy-policy

5. Use of Information Collected

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and comply with law. We may also process your information for other purposes with your consent.

The Company uses Neptune’s Users Personal Information to perform the services requested. For example, if you fill out a “Contact us” Web form, the Company will use the information provided to contact you about your interest in the Services. 

The Company may also use Neptune’s Users Personal Information for marketing purposes. For example, the Company may use information you provide to contact you to further discuss your interest in the Services and to send you information regarding the Company and its partners, such as information about promotions or events. 

Neptune Labs uses credit card information solely to check the financial qualifications of prospective Customers and to collect payment for the Services. 

Neptune Labs uses Web Sites Navigational Information to operate and improve the Company’s Web sites. The Company may also use Web Sites Navigational Information alone or in combination with Neptune’s Users Personal Information to provide personalized information about the Company. 

The Company uses Neptune’s Users Personal Information to reply to requests. On that basis, our experts will provide you with a personalized introduction to our platform or with other information as appropriate. 

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and login to your account, as well as keep your account in working order.
• To deliver and facilitate the delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes if this is in accordance with your marketing preferences. You have the option to unsubscribe from our marketing emails at any time. If you wish to opt-out, you can do so by following the instructions provided in the emails or by contacting our customer support team.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

6. Web Sites Navigational Information 

Neptune Labs uses commonly used information-gathering tools, such as cookies and Web beacons, to collect information as you navigate the Company’s Websites (“Websites Navigational Information”). This section describes the types of Websites Navigational Information that may be collected on the Company’s Web sites and how this information may be used. 

Automated decision-making 

Your personal data will not be processed by automated means, in particular by profiling.

7. Personal data storage period 

Your personal data storage period will depend on the purpose of their processing. Your personal data storage period is calculated based on the following criteria: 

• laws which may obligate Neptune Labs to store data for a specific period of time; 
• period which is required to protect the Data Controller’s interests; ● period required by Neptune Labs to provide services; 
• period for which the consent has been granted. 

a. Cookies 

Neptune Labs uses cookies to make interactions with the Company’s Web sites easy and meaningful. When you visit the Company’s Web sites, Neptune Lab’s servers send a cookie to your computer. Standing alone, cookies do not personally identify you. They merely recognize your Web browser. Unless you choose to identify yourself to Neptune Labs, either by responding to a promotional offer, opening an account, or filling out a Web form (such as a “Contact Us”), you remain anonymous to the Company. Neptune Labs uses cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. 

If you have chosen to identify yourself to Neptune Labs, the Company uses session cookies containing encrypted information to allow the Company to uniquely identify you. Each time you log into the Services, a session cookie containing an encrypted, unique identifier that is tied to your account is placed in your browser. These session cookies allow the Company to uniquely identify you when you are logged into the Services and to process your online transactions and requests. Session cookies are required to use the Services. 

Neptune Labs uses persistent cookies that only the Company can read and use to identify browsers that have previously visited the Company’s Web sites. When you purchase the Services or provide the Company with personal information, a unique identifier is assigned to you. This unique identifier is associated with a persistent cookie that the Company places on your Web browser. The Company is especially careful about the security and confidentiality of the information stored in persistent cookies. If you disable your Web browser’s ability to accept cookies, you will be able to navigate the Company’s Web sites, but you will not be able to successfully use the Services. 

Neptune Labs may use information from sessions and persistent cookies in combination with Neptune’s Users Personal Information to provide you with information about the Company and the Services. 

b. Web Beacons 

Neptune Labs uses Web beacons alone or in conjunction with cookies to compile information about Customers’ and Visitors’ usage of the Company’s Web sites and interaction with emails from the Company. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular Website tied to the Web beacon, and a description of a Website tied to the Web beacon. For example, Neptune Labs may place Web beacons in marketing emails that notify the Company when you click on a link in the email that directs you to one of the Company’s Web sites. Neptune Labs uses Web beacons to operate and improve the Company’s Web sites and email communications. Neptune Labs may use information from Web beacons in combination with Neptune’s Users Personal Information to provide you with information about the Company and the Services.

c. IP Addresses 

When you visit Neptune Lab’s Web sites, the Company collects your Internet Protocol (“IP”) addresses to track and aggregate non-personal information. For example, Neptune Labs uses IP addresses to monitor the regions from which Customers and Visitors navigate the Company’s Web sites. 

d. Third-Party Cookies 

From time to time, Neptune Labs may engage third parties, like Meta Platforms, Inc. or Google, to track and analyze usage and volume statistical information from users who visit the Company’s Web sites. Neptune Labs may also use other third-party cookies to track the performance of Company advertisements. Neptune Labs may also agreement with third-party advertising networks that collect IP addresses and other Web Sites Navigational Information on the Company’s Web sites and emails and on third-party Web sites. Ad networks follow your online activities over time by collecting Web Sites Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other Web sites. This process also helps us manage and track the effectiveness of our marketing efforts. 

• Meta Platforms, Inc. remarketing service. 
  • Meta Platforms, Inc.’s remarketing service is provided by Meta Platfroms, Inc. 
  • You can learn more about interest-based advertising from Meta Platfroms, Inc by visiting this page: https://www.facebook.com/business/tools/ads-manager.
  • To opt-out from Meta Platforms, Inc.’s interest-based ads follow these instructions from form under this address: https://www.facebook.com/help/contact/367438723733209. This form requires users to state why they want to opt-out and explain their specific circumstances.
  • Meta Platforms, Inc. adheres to the Self-Regulatory Principles for Online Behavioral Advertising established by the Digital Advertising Alliance. You can also opt-out from Meta Platforms, Inc. and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/​, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/​, or opt-out using your mobile device settings. 
  • For more information on the privacy practices of Meta Platforms, Inc., please visit Meta Platforms, Inc.’s Policy Center: Facebook Terms and Policies. 
• Google Ads remarketing service is provided by Google Inc. 
  • You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: https://myadcenter.google.com
  • For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/​.
• Google Analytics is a service is provided by Meta Google Inc.
  • You can learn more about the service by visiting this page: https://analytics.google.com/.
  • For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: Privacy Policy – Privacy & Terms – Google​.
  • Google also recommends installing the Google Analytics Opt-out Browser Add-on: https://tools.google.com/dlpage/gaoptout​, for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. 
• LinkedIn Ads is a service is provided by LinkedIn Corporation.
  • You can learn more about the service by visiting this page: Marketing & Advertising on LinkedIn | LinkedIn Ads.
  • For more information on the privacy practices of LinkedIn, please visit the web page: LinkedIn Privacy Policy​.
  • We also recommend visiting LinkedIn help center https://www.linkedin.com/help/linkedin, to set-up details about how you can manage your LinkedIn advertising preferences.
• Microsoft Advertising is a service is provided by Microsoft Corporation.
  • You can learn more about the service by visiting this page: https://ads.microsoft.com/. 
  • For more information on the privacy practices of Microsoft, please visit the web page: Microsoft Privacy Statement – Microsoft privacy
  • We also recommend visiting Microsoft Privacy settings https://account.microsoft.com/account/privacy section for the Microsoft Account, to set-up details about how you can manage your Privacy and advertising preferences.
• Reddit for Business/Advertising is a service provided by Reddit Inc.
  • You can learn more about ithe service by visiting this page: Advertise on Reddit (redditforbusiness.com). 
  • For more information on the privacy practices of Reddit, please visit the web page: https://www.reddit.com/policies/privacy-policy 
  • We also recommend visiting Reddit Privacy settings personalization preferences (reddit.com) section for the Reddit Account, to set-up details about how you can manage your Privacy and advertising preferences.
• Twitter Ads is a service is provided by X Corp.
  • For more information on the privacy practices of Twitter, please visit the web page: https://ads.twitter.com/ 
  • Visit the Ads preferences settings in your Twitter settings and turn off the Personalised ads setting.
    
• We recommend using the WebChoices tool under this address https://optout.aboutads.info, which provides transparency and choice in accordance with the DAA Principles to opt-out from participating companies. This tool is helpful to opt out of seeing interest-based advertising from participating companies in your current browser.

8. Public Forums, Refer a Friend, and Customer Testimonials, Community Forum 

Neptune Labs may provide bulletin boards, blogs, or chat rooms on the Company’s Web sites. Any personal information you choose to submit in such a forum may be read, collected, or used by others who visit these forums and may be used to send you unsolicited messages. Neptune Labs is not responsible for the personal information you choose to submit in these forums. 

Customers and Visitors may elect to use the Company’s referral program to inform friends about the Company’s Web sites. When using the referral program, the Company requests the friend’s name and email address. Neptune Labs will automatically send the friend a one-time email inviting him or her to visit the Company’s website. 

Neptune Labs may post a list of Customers and testimonials on the Company’s websites that contain information such as Customer names and titles. Neptune Labs obtains the consent of each Customer prior to posting any information on such a list or posting testimonials. 

9. Feedback 

We’re always trying to improve our product and services, and your feedback as a User or any other third party will help us do that. If you choose to give us any ideas, know-how, algorithms, code contributions, suggestions, enhancement requests, recommendations or any other feedback for our products or services (collectively, “Feedback”), you acknowledge and agree that Neptune Labs will have a royalty-free, fully paid-up, worldwide, transferable, sub-licensable, irrevocable and perpetual license to implement, use, modify, commercially exploit and/or incorporate the Feedback into our products, services, and documentation. You may give us your feedback via e-mails, calls, video calls, Spectrum, Discourse, Intercom, Slack or any other communication channel. 

10. Sharing of Information Collected 

Neptune Labs may share Neptune’s Users’ Personal Information with the Company’s service providers so that these service providers can contact Customers and Visitors

who have provided contact information on our behalf. This concerns particularly entities providing IT services, couriers, delivery companies, security companies or other services rendered by the Company. 

Neptune Labs may also share Neptune’s Users Personal Information with the Company’s service providers to ensure the quality of information provided. Unless described in this privacy statement, Neptune Labs does not share, sell, rent, or trade any information provided by third parties for their promotional purposes. 

Neptune Labs uses a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use Billing Information except for the sole purpose of credit card processing on the Company’s behalf. 

Neptune Labs reserves the right to use or disclose information provided if required by law or if the Company reasonably believes that use or disclosure is necessary to protect the Company’s rights and/or to comply with a judicial proceeding, court order, or legal process. 

Neptune Labs may also share Neptune’s Users Personal Information with other companies on the basis of joint control. 

11. International Transfer of Information Collected 

Neptune Labs uses mostly infrastructure located within the territory of the European Union. To facilitate Neptune Labs’s global operations, the Company may transfer and access Neptune’s Users Personal Information around the world, including the United States. This Privacy Statement shall apply regardless of the country of destination of Neptune’s Users Personal Information transfer. 

Neptune Labs declares that the Company is compliant with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

12. Communications Preferences 

Neptune Labs offers Customers and Visitors who provide contact information with a choice on how the Company uses the information provided. You may send a request specifying your communications preferences to dpo@neptune.ai​. Customers cannot opt out of receiving transactional emails related to their account with Neptune Labs or the Services. 

13. Security 

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. Neptune Labs ensures that all source code, files and data remain private and confidential. Due to the sensitive nature of source code, we take this very seriously and make it our primary concern for all customers.

We enforce strict confidentiality obligations on all Neptune Labs employees, contractors, and agents who have access to your personal information in order to operate, develop, or improve our service. These confidentiality obligations are a vital part of our commitment to safeguard your data. We hold our employees, contractors, and agents accountable for upholding these obligations, and any breach may result in appropriate disciplinary actions.

If you have any questions about the security of your personal information, you can contact us at DPO@neptune.ai​. We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. 

14. Your rights related to data processing

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

 If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

Consent. We may process your information if you have given us permission (i.e. consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.

Performance of an agreement. We may process your personal information when we believe it is necessary to fulfil our contractual obligations to you, including providing our Services or at your request prior to entering into an agreement with you.

Legitimate Interests.

We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:

• Analyze how our Services are used so we can improve them to engage and retain users.
• Understand how our users use our products and services so we can improve user experience.
• Support our marketing activities.
• Send users information about special offers and discounts on our products and services.
• Diagnose problems and/or prevent fraudulent activities.
  

Legal Obligations.
We may process your information where we believe it is necessary to comply with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

Vital Interests.

We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as in situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you. 

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. 

• In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example: 
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way 
• For investigations and fraud detection and prevention 
• For business transactions provided certain conditions are met 
• If it is contained in a witness statement and the collection is necessary to 
• assess, process, or settle an insurance claim 
• For identifying injured, ill, or deceased persons and communicating with next of kin 
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse 
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is 
• reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province 
• If disclosure is required to comply with a subpoena, warrant, court order, or 
• rules of the court relating to the production of records 
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced 
• If the collection is solely for journalistic, artistic, or literary purposes 
• If the information is publicly available and is specified by the regulations

WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time. 

These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “Contacting Us”.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html

Withdrawing your consent:

If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the “Contacting Us” section.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications:
You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send.

If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided in the “Contacting Us” section below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided in the “Contacting Us” section below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CCPA Privacy Notice 

The California Code of Regulations defines a “resident” as: 

(1) every individual who is in the State of California for other than a temporary or transitory purpose and; 

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. 

All other users are defined as “non-residents.”

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months: 

Category	Examples	Collected
Identifiers	Personal information categories listed in the California CustomerRecords statute	Yes
Protected classification characteristics under California or federal law	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	Yes
Transaction information, purchase history, financial details, and payment information	Gender and date of birth	No
Commercial information	Audio, electronic, visual, thermal, olfactory, or similar information	Yes
Biometric information	Fingerprints and voiceprints	No
Internet or other similar network activity	Browsing history, search history, online behaviour, interest data, and interactions with our and other websites, applications, systems, and advertisements	Yes
Geolocation data	Device location	Yes
Business contact details in order to provide you with our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	Images and audio, video or call recordings created in connection with our business activities	No
Professional or employment-related information	Inferences are drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	Yes
Education Information	Student records and directory information	No
Inferences are drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	Inferences are drawn from other personal information	Yes
Sensitive Personal Information		No

We will use and retain the collected personal information as needed to provide the Services or for: As long as the user has an account with us, for each category.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of Receiving help through our customer support channels; Participating in customer surveys or contests; and Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

Neptune Labs Inc. collects and shares your personal information through:

• Targeting cookies/Marketing cookies
• Social media cookies
• Beacons/Pixels/Tags

If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written agreement between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration.  This Is not considered to be “selling” your personal information. Neptune Labs Inc. has not sold or shared any personal information to third parties for business or commercial purposes in the preceding twelve (12) months. NeptuneLabs Inc. has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months.

Your rights with respect to your personal data

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to)the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

Right to be informed — Request to know

Depending on the circumstances, you have a right to know: whether we collect and use your personal information; the categories of personal information that we collect;

the purposes for which the collected personal information is used; whether we sell or share personal information to third parties; the categories of personal information that we sold, shared, or disclosed for a business purpose; the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose; the business or commercial purpose for collecting, selling, or sharing personal information; and the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights. Right, to Limit Use and Disclosure of Sensitive Personal Information We do not process consumers’ sensitive personal information.

Verification process

Upon receiving your request, we will need to verify your identity to determine whether you are the same person with whom we have the information in our system. These Verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use the personal information provided in your request to verify your identity authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

You may object to the processing of your personal information. You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information. You can designate an authorised agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

You may request to opt-out from future selling or sharing of your personal information with third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission. If you have a complaint about how we handle your data, we would like to hear from you.

Virginia Residents’ Privacy Rights:

Virginia residents have specific rights regarding their personal information under the Virginia Consumer Data Protection Act (CDPA). The CDPA defines a “consumer” as a resident of Virginia acting in an individual or household context, excluding commercial or employment activities. Personal data refers to information linked or reasonably linkable to an identified or identifiable natural person, excluding de-identified data or publicly available information. The sale of personal data involves the exchange of personal data for monetary consideration.

Neptune Labs Inc. and our Services adhere to the rights and obligations outlined in the CDPA based on your interaction with us. These include the rights to be informed about data processing, access personal data, correct inaccuracies, request deletion, obtain a copy of shared data, and opt out of processing for targeted advertising, sale of personal data, or profiling.

Neptune Labs Inc. has not sold personal data to third parties and will not do so in the future. For more information on our data practices, please refer to our privacy notice.

To exercise your rights under the Virginia CDPA, please review the privacy notice and follow the instructions provided. If you’re using an authorized agent, proof of authorization is required.

We may request additional information to verify your identity and process your request. Our response will be provided within 45 days, with a possible extension of 45 days if reasonably necessary. If we decline your request, we will provide an explanation. If you wish to appeal, please email us at dpo@neptune.ai. If the appeal is denied, you may contact the Attorney General to file a complaint.

15. Changes to this Privacy Statement 

Neptune Labs reserves the right to change this Privacy Statement. Neptune Labs will provide notification of the material changes to this Privacy Statement through email and/or the Company’s Web sites at least one business day prior to the change taking effect. 

16. Contacting Us 

Questions regarding this Privacy Statement or the information practices of the Company’s Web sites should be directed to ​contact@neptune.ai​ or dpo@neptune.ai

Neptune Labs, Inc 

2100 Geng Road 

Suite 210 

Palo Alto, CA 94303 

United States of America