January 2023

Neutronian Inc. (“Neutronian”) is committed to protecting your privacy. This privacy statement describes why and how we collect, use and share personal information collected from individuals themselves or from other third parties, and provides information about individuals’ rights with respect to their personal information. 

 

Neutronian is not in the business of selling or marketing any of your private information, but it is possible that during the course of Neutronian’s business activities, we may come into the possession of personal or personally identifiable information. The use of personal or personally identifiable information is regulated by applicable federal, state and/or local laws and regulations. Neutronian regularly reviews its privacy policies to help ensure compliance with these laws or regulations.

While we do not at any time directly market or commercialize personal or personally identifiable information (generally, “personal information”), we may use personal information provided to us for any of the purposes described in the relevant section of this privacy statement or as otherwise stated at the point of collection.

Our goal is to process personal information as necessary for our legitimate business purposes in a transparent manner. If you have any questions regarding our privacy practices, please contact us as set forth in the Contact Us section below.

To view any particular section of this privacy statement, you may use the links below or scroll to the applicable section.

  1. BUSINESS CONTACTS
  2. CLIENTS
  3. USERS OF OUR WEBSITES AND APPLICATIONS
  4. CHILDREN
  5. CERTAIN REGULATORY DISCLOSURES
  6. YOUR CHOICES
  7. SECURITY
  8. CHANGES TO THIS PRIVACY POLICY
  9. CONTACT US

Business Contacts

Information collection

We collect and use business contact details for individuals associated with existing and potential Neutronian clients to manage and maintain our relationship with those individuals. The collection of personal information about contacts and the addition of that personal information to the management system is initiated by Neutronian staff and may include name, employer name, title, phone, email and other business contact details.

 

When we send you emails, we may use technologies to determine whether the email has been opened and whether the links contained within the message have been clicked on. We may combine information collected through these means with other information we maintain about you to measure interest in our specific offerings and email campaigns, improve our offerings to specific target audiences, and tailor our interactions with you.

Information use

We use this information for the following business purposes:

  • Administering, managing and developing our business and services – We may process personal information to run our business, including:
    • Managing our relationship with clients;
    • Providing services and customer support to our clients;
    • Developing our business and services, such as identifying client needs and improvements in service delivery and learning more about a client relationship opportunity we have an interest in;
    • Analyzing and evaluating the strength of interactions between Neutronian and a contact;
    • Performing analytics, including producing metrics for Neutronian leadership, such as on trends, relationship maps, sales intelligence, and progress against account business goals;
    • Maintaining and using IT systems;
    • Hosting or facilitating the hosting of events; and
    • Administering and managing our website, systems, and applications.
  • Providing information about us and our range of services – Unless we are asked not to, we use client business contact details to provide information that we think will be of interest about Neutronian and our services. For example, we may send you industry updates and insights, information about other services that may be relevant to you, and invites to events.

Please review the Your Choices section below for information about how you may unsubscribe from our mailing lists and exercise other rights.

Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below (We do not in the normal course of our business collect personal information for any resale purposes.):

  • Digital Marketing Service Providers – We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the indirect processing of personal information. Our appointed data processors include:
    • Prospect Global Ltd (trading as Sopro). Reg. UK Co. 09648733. We use Sopro for email lead generation services. You can contact Sopro and view their privacy policy here: https://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: [email protected]
    • ActiveCampaign. We utilize ActiveCampaign as our customer relationship management (or CRM) system. You can contact ActiveCampaign and view their privacy policy here: https://www.activecampaign.com/legal/privacy-policy

Information retention

Personal information will be retained by Neutronian for as long as we have, or need to keep a record of, a relationship with a business contact. Personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights.

Clients

Our business does not rely upon our direct collection or sale of personal information in any manner. Our policy is never to collect personal information and we ask our clients not to share personal information with us. Any processing of personal information to provide our services is generally inadvertent or limited to contact with our client contacts. Additional client-specific privacy provisions may be contained in our service agreements with such client.

Information collection

Given the diversity of services we provide to clients, we process many categories of personal information, which may include:

  • Personal details (e.g., name, age/date of birth, gender, marital status, country of residence);
  • Contact details (e.g., email address, phone number, postal address);
  • Financial details (e.g., salary, payroll details and other financial-related details such as income, investments and other financial interests, benefits, tax status);
  • Job details (e.g., role, grade, experience, performance information and other information about management and employees); and
  • For certain client engagements, we may process sensitive or special categories of personal information (such as in performing know your client checks, which may involve us processing government identification documents that may contain biometric data).

Information use

We use the above personal information for the following business purposes:

  • Providing professional services and products – We provide a diverse range of professional services and products. Some of our services require us to process personal information to provide advice and deliverables.
  • Administering, managing and developing our businesses and services – We may process personal information to run our business, including:
    • Managing our relationship with clients;
    • Developing our businesses and services (such as identifying client needs and improvements in service delivery);
    • Maintaining and using IT systems;
    • Hosting or facilitating the hosting of events; and
    • Administering and managing our website and systems and applications.
  • Security, quality and risk management activities
    • Personal information may be processed as part of the security monitoring that we undertake to detect, investigate and resolve security threats — for example, automated scans to identify harmful emails (e.g., phishing attempts).
    • We monitor the services provided to clients for quality purposes and risk management purposes, which may involve processing personal information stored on the relevant client file.
    • We collect and hold personal information as part of our client engagement and acceptance procedures, including carrying out searches using publicly available sources — such as internet searches and sanctions lists — to help identify politically exposed persons and heightened risk individuals and organizations and checking that there are no issues that would prevent us from working with a particular client — such as sanctions, criminal convictions, conduct or other reputational issues, including with respect to company directors.
  • Providing our clients and prospective clients with information about us and our range of services – With consent or otherwise in accordance with applicable law, we use client contact details to provide information that we think will be of interest about us and our services — for example, industry updates and insights, other services that may be relevant and invites to events.
  • Complying with any requirement of law, regulation or a professional body of which we are a member – As with any provider of professional services, we are subject to legal, regulatory and professional obligations. Subject to these obligations, we need to keep certain records to demonstrate that our services are provided in compliance with those obligations, and those records may contain personal information.

We are continually looking for ways to help our clients and improve our business and services. Where agreed with our clients, we may use information that we receive in the course of providing professional services for other lawful purposes, including analysis to better understand a particular issue, industry or sector, provide insights to our clients, improve our business, service delivery and offerings and develop new Neutronian technologies and offerings.

Information sharing

We may share personal information with third parties as described in the Information Use section above. In addition, we may share personal information with:

  • Third party organizations that assist us in providing services – On certain client engagements, pursuant to our agreements with such clients, we may engage or otherwise work with other providers to help us provide professional services to our clients.
  • Third Party Processors – Our carefully selected partners and service providers may process personal information about you on our behalf as described below (We do not in the normal course of our business collect personal information for any resale purposes.):

Information retention

We retain the personal information processed by us for as long as is considered necessary for the purpose for which it was collected, however, it is our policy that any personal information we receive from our clients as part of our certification process will be removed from our servers following the termination of the client engagement, however, personal information may be held for longer periods where extended retention periods are required by law, regulation, or professional standards and to establish, exercise or defend our legal rights.

Users of Our Websites and Applications

This section describes our privacy practices with respect to neutronian.com and other Neutronian websites, applications and online services that link to this privacy statement (together referred to as the “Site”).

Information collection

When you access or otherwise use our Site, we will collect information about you and how you interact with our Site. We collect information about you through: (1) information you provide; (2) automatic tracking technologies; and (3) third parties.

  1. Information you provide – When you access our Site, we may request personal information from you in order to provide you with certain of our materials or you may choose to provide information about yourself such as your name, address, email address, telephone number, fax number, job title, and company name voluntarily. By way of example, you may choose to provide your information in the following circumstances:
    • By ordering any of our white papers or other materials prepared by us;
    • Subscription or ordering newsletters and/or publications;
    • Participation in “join our mailing list” initiatives;
    • Participation in bulletin boards, discussion, or message forums;
    • Entering quick surveys, quizzes or benchmarking surveys;
    • Registration for events and conferences;
    • Registration for premium online services;
    • Contacting us for further information;
    • Visiting our Site while logged into a social media platform.
  2. Automatically collected informationWe may use online identification technologies, such as cookies, web beacons, or pixels on some pages of our Site (“Tracking Technologies”). The information we collect using these technologies could include: IP address, browser type and language, access time, and referring website. We note, however, that we do not affirmatively seek IP addresses for any purpose, including our Services, but we may receive IP address information during the execution of our Services. At no point do we store IP addresses or any other geolocation data for any purpose.
    • Cookies are small text files placed on your hard drive that assist us in providing a more customized website experience. For example, a cookie can be used to store registration information in an area of the website so that a user does not need to re-enter it on subsequent visits to that area.
    • In all cases, any use of cookies by use (either directly or through third-parties working through us), must be consented to by users of our site. We understand your continued use of this site to affirm your consent to their use.
  3. Third-party analytics – Neutronian may use Tracking Technologies from marketing partners on our Site, third party sites, and social media platforms. These Tracking Technologies help to measure the efficacy of our marketing and awareness campaigns and to understand how visitors navigate to our Site from a Neutronian ad. We use these technologies to compile aggregated statistics about visitors who interact with Neutronian online content, to gauge the effectiveness of our ads and to better provide more pertinent information to our visitors.

    • Neutronian also uses website analytics providers which may, if permitted, set cookies in your browser. Site activity information collected by these analytics providers may be combined with personal information held by Neutronian.

    • To properly manage our Site we also log anonymous information on our operational systems and identify categories of visitors by items such as domains and browser types. These statistics are reported in the aggregate to our webmasters. This is to improve the web experience of our Site’s visitors and to provide us with an effective information resource.

    • When we send you emails, we may use technologies to determine whether the email has been opened and whether the links contained within the message have been clicked on. We may combine information collected through these means with other information we maintain about you in order to measure interest in our specific offerings and email campaigns, improve our offerings to specific target audiences, and tailor our interactions with you.

Information use

We use the information we collect as described above for various purposes depending on the context in which we collected the information. For example, it may be necessary for us to process your information in order to process a transaction or provide a service you have requested or otherwise in accordance with a contract between us, or we may process your information in accordance with your prior consent (where you have provided such consent).

 

We also use the information we collect for the following business purposes:

  • Operating and improving the Site;
  • Fulfilling your orders and requests;
  • Managing your registration preferences;
  • Customizing the Site for you;
  • Understanding how the Site is being used;
  • Exploring ways to develop and grow our business;
  • Maintaining and improving the safety and security of the Site;
  • Preventing and enhancing protection against fraud, spam, harassment, intellectual property infringement, crime and security risks;
  • Sending you renewal notifications and/or service notifications;
  • Conducting customer satisfaction surveys;
  • Improving our products and services;
  • Running our operations;
  • Complying with law and legal obligations;
  • Responding to your inquiries; and
  • Sending communications about Neutronian products, services, and events.

Third party sites

Our Site may link to other websites which do not operate under Neutronian’s privacy practices. When you link to other websites, Neutronian’s privacy practices no longer apply. We encourage you to review each site’s privacy policy before disclosing any personal information.

Children

Neutronian understands the importance of protecting children’s privacy, especially in an online environment. The Site is not intentionally designed for or directed at children under the age of 18 years. It is Neutronian’s policy never to knowingly collect or maintain personal information about children under the age of 18.

Certain Regulatory Disclosures

EU Data Subjects Disclosures

 

Legal Basis

Neutronian may process personal data under the following legal basis: 

  1. Collection and processing of personal data received from our customers in order to provide Services.
  2. Service-related communications with our customers.
  3. Improving our Services.

 

Controller/Processor Designation

Under the EU’s General Data Protection Regulation (“GDPR”), we are designated as a “Controller” for the collection and use of our customers’ data to fulfill the Services.  While we do not seek to collect personal data for the Services, we may become in possession of personal data in connection with our Services. For all other uses of personal data, if any, we may be designated as a ‘Processor’ acting upon the express instructions of our business customers, although we do not expressly process personal data for any business purpose in connection with our Services. 

Since we do not expressly process personal data for any purpose in connection with our Services, we are generally not subject to GDPR requirements relating to Data Subject Access Requests. However, if anyone has any questions relating to a DSAR, please contact us at [email protected] and we will respond promptly.

 

Cross border data transfers

Neutronian is primarily operated in the United States, and will process personal information primarily in the U.S.  If you are visiting this website from outside the U.S., then by providing us with your personal information you are consenting to the transfer of that information to the U.S. 

For business customers, we may transfer to, and store the data we collect about you, in countries other than the country in which the data was originally collected, including the United States or other destinations outside the European Economic Area (“EEA”) and the United Kingdom. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside the EEA. We rely on model contracts approved by the European Commission when we transfer personal data to be processed by us or our service providers or partners in the U.S.  

For more information on cross-border transfers of your Personal Data or the appropriate safeguards in place, please contact us at [email protected]

 

Additional EU Data Subject rights

In addition to the rights granted above, if you are a UK or EEA resident, the GDPR grants you the right to lodge a complaint against us with your local data protection authority. You can find your data protection authority at https://edpb.europa.eu/about-edpb/about-edpb/members_en

California Consumer Disclosure

 

Business/Service Provider/Third Party Designation

Under the California Consumer Privacy Act (“CA ACTS”) and the California Privacy Rights Act (“CPRA,” together with the CA ACTS, the “CA ACTS”), we are designated as a “Business” for the collection and use of our business customers’ administrative representatives personal information to maintain their account and fulfill the Services. For all other uses of personal information, we are designated as a ‘Service Provider’ acting upon the express instructions of our business customers in accordance with our Services. 

 

Additional California Consumer rights

In addition to the rights granted above, if you are a California resident, you have the following rights: 

  • to opt out of the “sale” of your personal information as defined in the CA ACTS. Neutronian does not ‘sell’ your personal information for monetary gain, however, some advertising cookies placed on our website may be considered a sale. 
  • To limit the use and disclosure of your sensitive information. Neutronian does not collect, process, or disclose your sensitive information. 

Virginia Consumer Disclosure

 

Controller/Processor Designation

Under the Virginia Consumer Data Protection Act (“VCDPA”), we are designated as a “Controller” for the collection and use of our business customers’ administrative representatives personal information to maintain their account and fulfill the Services. For all other uses of personal information, we are designated as a “Processor” acting upon the express instructions of our business customers. 

 

Additional Virginia Consumer rights

In addition to the rights granted above, if you are a Virginia resident, you have the following rights: 

  • to opt out of the “sale” of your personal data as defined in the VCDPA. Neutronian does not ‘sell’ your personal data.
  • To opt out of “targeted advertising” as defined in the VCDPA. You may exercise your opt-out right as detailed above.
  • To opt out of profiling based on your personal data. 
  • To opt in to the collection of your sensitive data. Neutronian does not collect, process, or disclose your sensitive data. 
Your Choices

Unsubscribe

Should you wish to unsubscribe from our mailing list or any registrations or, to the extent permissible, opt-out of data collection of your information, you may provide us with your wish to do so by contacting us and completing the information in this form, or by calling and leaving a message for us at (650) 242-5048.

Managing cookies

If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, you may refuse or delete one or more cookies and still access our Site, but Site functionality may be impaired. After you finish browsing our websites, you may delete Site cookies from your system if you wish.

Do not track

Do Not Track (“DNT”) is a privacy preference that you can set in your web browser to send a message to the website operator requesting not to be tracked. Currently, we do not respond to these DNT signals. For more information about DNT, visit allaboutdnt.com.

Security

Neutronian has implemented generally accepted standards of technology and operational security designed to protect personal information from loss, misuse, alteration or destruction. Only authorized Neutronian personnel and the third parties described in this privacy statement are provided access to personal information and these employees and third parties have agreed to maintain the confidentiality of this information.

Changes to This Privacy Statement

Neutronian may update this privacy statement at any time by publishing an updated version here. You can access the most current version of this privacy policy statement at any time on this Site.

Contact Us

If you have questions about this privacy statement or about our privacy practices, please contact us at: [email protected].

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