Information We Collect

Neutraly can collect and process the following personal data:

• Name

• First name

• City name

• Work address

• Invoicing address

• Email address

• Telephone number (landline/mobile phone)

• Username

• Password

• Information concerning your use of the Website, the Platform: including, but not limited to heatmaps, surf recordings, IP address, browser type, the web pages you visited when you obtained access to the Website.

• Communication preference

• All personal data freely provided to Neutraly (e.g.in light of correspondence with Neutraly).

Neutraly, in compliance with applicable data protection laws, also gathers anonymous information regarding your utilisation of the Website and Neutraly services via the Platform. This entails the automatic logging of the specific sections of the Website and/or Platform you visit, the type of web browser you utilise, the website you accessed prior to visiting our Website, and your IP address. It is important to note that this information does not personally identify you, but it enables Neutraly to compile statistical data on the usage of the Website and/or the Platform.

Ways in which personal data is gathered

These personal data are collected in the context of:

• Requesting a quote

• Creating a demo account

• Collaboration with Neutraly

• Visiting the Website

• Your use of Neutraly services, whether or not via the Website and/or the Platform

• The verification of your identity (e.g.when you contact customer support or update your password)

• Incoming and outgoing correspondence with Neutraly

• Communicating ideas to Neutraly with regards to improving the services and/or the Platform

• Drawing up a quote

• The exchange of business cards

• A connection made between the Platform and social network platforms
  As professionals, you may have registered your business information and business contact details on public databases. We may retrieve those information related to your business account.

The personal data collected by Neutraly are therefore expressly and voluntarily provided by you.

Who handles the processing of your personal information?

3.1. Responsible for Processing data

Neutraly is responsible for processing your data and determines alone or in cooperation with others which personal data is collected, as well as the purpose and means for the processing of these personal data.

3.2. Processor

Neutraly has the authority to engage data processors. A data processor refers to an individual or organisation that processes personal data at the request of or on behalf of the data controller. The data processor is obligated to maintain the security and confidentiality of the data and always operates in accordance with the instructions provided by the data controller.

Neutraly invokes among others the following categories of 'Processors':

• Processors engaged for administrative purposes;

• Processors engaged for marketing purposes;

• Processors engaged for ICT services and hosting;

• Processors engaged for customer support purposes.

Basis for processing personal data

In compliance with the Privacy Law and Regulations in Ireland & EU, we process personal data using the following legal bases:

• Consent: We process personal data when explicit consent has been provided through an agreement with this Privacy Policy.

• Contractual Obligations: We process personal data when it is necessary for the performance of an agreement with the user or for taking pre-contractual steps at the user's request.

• Legal Obligations: We process personal data to comply with legal or regulatory requirements, particularly in managing the contractual relationship, such as invoicing.

• Legitimate Interest: We process personal data based on our legitimate interest in sending information and newsletters to our customers.

• Explicit Permission: We process personal data when explicit permission has been given for sending promotional offers through direct marketing.

  These legal grounds provide the framework for processing personal data in accordance with applicable laws and regulations.

Use of Personal Data

Neutraly may utilise your personal data for the following purposes:

• Creating a (demo) account and confirming its activation.

• Performing the agreement with Neutraly, including necessary follow-up actions.

• Providing Neutraly's services, whether accessed through the website, the platform, or other means.

• Offering support and assistance, such as resolving any issues or challenges you may encounter.

• Sending targeted marketing, advertising, updates, and promotional offers based on your communication preferences.

• Issuing invoices and facilitating payment collection.

• Sending newsletters and/or blog updates.

• Optimising the quality, management, and content of the website and/or the platform.

• Generating statistical insights.

• Preparing quotes.

• Conducting customer satisfaction studies, surveys, and other market research initiatives.

• Ensuring the security of Neutraly's offices.

The processing of your personal data is carried out based on the following legal grounds, as applicable:

• Your explicit consent for the processing of personal data for one or more specific purposes.

• Processing is necessary for the performance of the agreement with Neutraly or for taking pre-contractual steps at your request.

• Processing is necessary to comply with legal obligations applicable to Neutraly.

• Processing is necessary to protect your vital interests or those of another individual.

• Processing is necessary for the performance of a task carried out in the public interest.

• Processing is necessary for the legitimate interests pursued by Neutraly or a third party, except when such interests are overridden by the interests or fundamental rights and freedoms of the data subject.

These legal grounds ensure that the processing of your personal data is conducted in compliance with applicable laws and regulations while considering the protection of your rights and freedoms.

Sharing Personal Data with Third Parties

Neutraly is committed to protecting the confidentiality of your personal data and will not disclose it to third parties unless it is necessary for the provision and optimisation of Neutraly services. This may include activities such as maintenance works, payment processing, subcontracting, and database management. In such cases, your personal data may be shared with trusted partners such as payment providers, software providers, cloud partners, data centres, external IT consultants, and service providers. Rest assured that any third party receiving your personal data will be required to handle it in accordance with the provisions of this Privacy Policy.

There are certain circumstances where Neutraly may be required to disclose your personal data. This includes situations where disclosure is necessary to comply with legal obligations, protect and defend our rights in legal proceedings, or in the event of a transfer or acquisition of Neutraly's assets. Additionally, your personal data may be used to identify similar profiles, unless you have expressly opted out of this purpose.

In all other cases, Neutraly will not sell, rent, or transfer your personal data to third parties unless we have obtained your permission and have established a data processing agreement with the third party that ensures the confidentiality and privacy compliance of your personal data. Your privacy and data security are of utmost importance to us.

Data Storage Practices

Unless a longer storage period is required or justified by Irish law or through compliance with another legal obligation, Neutraly will retain your personal data only for the duration necessary to achieve the specified purpose as outlined in the Privacy Policy under '5. Use of Personal Data'.

Your Rights Regarding Privacy

If you wish to exercise your privacy rights, as defined below, please contact info@neutraly.ie. In accordance with the processing of your personal data, you have the following privacy rights, which are subject to applicable laws and regulations in Ireland:

• Right of access: You have the right to request access to the personal data that Neutraly may have concerning you.

• Right to rectification: You have the right to request the rectification, completion, or update of your personal data.

• Right to erasure ("right to be forgotten"): You have the right to request the deletion of your personal data. Please note that certain services may no longer be accessible or provided if you delete or request the deletion of certain required personal data.

• Right to restriction of processing: You have the right to request the restriction of the processing of your personal data.

• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit those data to another data controller.

• Right to object: You have the right to object to or oppose the processing of your personal data.

• Right to withdraw consent: If you have provided consent for the processing of your personal data, you have the right to withdraw your consent at any time.

You can exercise these rights free of charge by emailing info@neutraly.ie.

Protection of Personal Data

Neutraly is committed to implementing reasonable physical, technological, and organisational measures to prevent unauthorised access to your personal information and to protect against the loss, misuse, or alteration of your personal data. All personal data collected by Neutraly will be stored in the cloud, utilising data centers located within the EU.

While Neutraly maintains a robust security policy, conducts regular checks, and takes appropriate actions, it is important to note that no security measure is entirely infallible. Given the inherent nature of internet transmission and electronic storage, absolute security cannot be guaranteed. Neutraly acknowledges this limitation.

It is essential to maintain the confidentiality of your password to ensure the security of your (demo) account access. Neutraly will never request your password directly, and you should never share it with anyone. If, however, you have shared your password with a third party under the belief that they offer additional services, that third party will have access to your (demo) account and personal data using your password. In such instances, you are responsible for any transactions or activities conducted through your (demo) account. Neutraly strongly advises that you promptly change your password and contact us if you suspect any unauthorised access to your (demo) account.

Processing of Personal Data Across Borders

Any transfer of personal data from the European Economic Area (EEA) to a recipient located in a country outside the EEA, and not covered by an adequacy decision from the European Commission, will be subject to a data transfer agreement. This agreement will include either

(i) the standard contractual clauses as specified in the European Commission decision of 5 February 2010 (Decision 2010/87/EC), or

(ii) any other mechanism prescribed by privacy legislation or regulations governing the processing of personal data.

Revision and Updating of the Privacy Policy

Neutraly reserves the right to revise and update this Privacy Policy by publishing a revised version on the Website. It is advisable to periodically visit the Website and review the Privacy Policy page to stay informed about any modifications.

Links to Other Websites

The Website may include links to other websites. When you click on these links, you may be directed to another website or online source that may collect information about you using cookies or similar technologies.

Please note that Neutraly does not assume any responsibility or control over these external websites or online resources, including their collection, use, and disclosure of your personal data.

To understand how these websites and online sources handle your personal data, it is advisable to review their respective privacy policies in accordance with the applicable privacy laws.

Submitting a Complaint

If you are dissatisfied with how Neutraly has addressed your inquiries, comments, or any concerns regarding the collection, use, and processing of your personal data, you have the right to file a complaint with the relevant data protection authority. In Ireland, you can lodge a complaint with the Data Protection Commission by contacting them via dpo@dataprotection.ie.