Privacy Policy

Last modified on 01/05/2023

This Privacy Policy explains how Neuecell collects, uses, shares, and protects personal information, and the privacy rights and choices we offer, in connection with our websites, online services, and products and services (collectively, our “Services”). In this Privacy Policy, 

 

 

Personal Information We Collect

Information you provide to us. Personal information you may provide to us includes:

  • Contact details, such as your first and last name, organization name, email and mailing addresses, and phone number.
  • Account data, such as the username and password that you may use to establish an online account with us.
  • Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
  • Order and purchase history, including your interactions with our checkout page.
  • Payment details, such as your payment card number, bank account number and shipping address. We rely on payment providers, such as Stripe, to process payments and we do not have access to payment card numbers.
  • Subscriber survey data, including the information you provide when you fill out surveys, and recordings of video or voice chats with our marketing team. 
  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

Third party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Data providers, such as information services, data co-ops, and data licensors.
  • Public sources, such as social media platforms.
  • Marketing partners, such as companies that have entered into joint marketing relationships with us.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our websites, online services and our communications, such as:

  • Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our websites, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

Cookies and similar technologies. Our Services may use the following technologies:

  • Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
  • Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser, in connection with specific applications.

Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

How We Use Personal Information

We use personal information for the following purposes:

Service delivery. We use personal information to perform our contractual obligation under our terms of use, including to:

  • Provide, operate and improve our Services and our business;
  • Process your payments and complete transactions with you; and
  • Communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.

Improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our services safe for our users, which includes:

  • Understanding your needs and interests, and personalizing your experience with the Services and our communications; 
  • Engaging in surveys and recording our video and audio chats with consumers;
  • Troubleshooting, testing and research to keep the services secure; and
  • Investigating and protecting against fraudulent, harmful, unauthorized or illegal activity.

Research and development. We may use personal information for research and development purposes in our legitimate business interests, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.

Marketing and advertising. We, our service providers, and our third party advertising partners may collect and use personal information for the following marketing and advertising purposes:

  • Direct marketing. We may send you NEUECELL -related direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section.
  • Interest-based advertising. We may engage third party advertising companies and social media companies to display ads on our websites and other online services. These companies may use cookies and similar technologies to collect information about your interactions (including the data described in the “Automatic data collection” section) over time across our Services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to them or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the “Your Choices” section below.

Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interest. Where we seek your consent, you may withdraw your consent at any time.

Compliance and protection. We may use personal information to comply with legal obligations, and to defend us against legal claims or disputes, including:

  • Protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern our Services;
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and
  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

How We Share Personal Information

We may share personal information with:

Affiliates. Within NEUECELL for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate our Services or our business (such as hosting, information technology, customer support, email delivery, and website analytics services). 

Payment processors. When you make a purchase at NEUECELL , your payment card information is collected and processed directly by our payment processors, such as Stripe. We do not record or maintain payment card or bank account details. These payment processors may use your payment data in accordance with their privacy policies. Stripe’s privacy policy is available at https://stripe.com/privacy

Facebook and other Social Networking Services. You may be given the option to access or register for the Services through the use of your user name and passwords provided by Facebook and other social networking sites (each, an “SNS”), or otherwise have the option to connect an SNS account. By doing so, you authorize us to access and store information from the SNS -- including, without limitation, your name, email address(es), date of birth, gender, current city, profile picture and URL -- and to use and disclose it in accordance with this Privacy Policy. To control what information is shared with us, please check your privacy settings on each SNS and make changes as appropriate. 

Third Parties. Third parties, such as advertising companies, data providers and data co-ops, such as Oracle and Epsilon, for interest-based advertising and other marketing purposes, including those third parties’ own purposes. To learn how to opt-out, please see the “Privacy Rights and Choices” section below. 

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us. 

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, NEUECELL (including, in connection with a bankruptcy or similar proceedings).

Google reCAPTCHA. In order to protect our website and other features, we use Google reCAPTCHA provided by Google Inc. (“reCAPTCHA”) for all United States visitors. We employ reCAPTCHA to check whether data is entered into our forms by a person or by an automated program, script or bot. reCAPTCHA analyzes the behavior of the person entering the data using various features. This analysis starts automatically as soon as the website is accessed. For analysis, reCAPTCHA evaluates various information (e.g., IP address, browser type, settings, and plugins, URL of the referring website, time spent on the respective website, mouse movements, input characteristics of the data entry, including speed, sequence and selection of inputs, etc.). The data collected during the analysis is forwarded to a Google server, where it is stored and evaluated. Your use of reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. For more information about reCAPTCHA, please visit: https://www.google.com/recaptcha.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through our Services, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.

Privacy Rights and Choices

Access, correct or delete. If you have an NEUECELL account, you can review and update certain account information by logging into your account. Registered users may also contact us to request deletion of their account and certain personal information. We may request information from you to help us confirm your identity and process your request. Applicable law may require or permit us to limit or decline access and deletion requests, such as where we need to retain your information for security, compliance, fraud prevention, and safety purposes, to comply with law, to establish or defend legal claims, to protect the identities and rights of other users, to protect trade secrets, or because access or deletion is not practicable. If we delete your account, you will not be able to access it. If we delete your information, it will generally be deleted from our active databases, and the information may remain for a period of time in our backup files and in unstructured files until these records are deleted in the ordinary course of business. 

Opt-out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the emails you receive from us. You may continue to receive service-related and other non-marketing emails.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information: 

  • Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
  • Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
  • Opt out of the sale or sharing of personal information, and opt out of the processing of your personal information for targeted advertising. We do not monetize your personal information or sell it in the traditional sense. However, you can ask us to refrain from sharing your information with third parties to provide you with offers and promotions, or for targeted advertising purposes. 
  • Correction of personal information that is inaccurate or out of date.
  • Deletion of personal information that we no longer need to provide the services or for other lawful purposes.
  • Additional rights, such as to object to and request that we restrict our use of personal information.

To make a request, please write to us as provided in the “How to Contact Us” section below. We may ask for specific information from you to help us confirm your identity. You are entitled to exercise the rights described above free from discrimination.

California residents can opt out of the sale or sharing of their personal information by completing this form. California residents can also empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. 

In addition, you can limit the use of tracking technologies, such as cookies, by following the instructions in the “Online tracking opt-out” section below.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit www.allaboutdnt.com.

Online tracking opt-out. There are a number of ways to limit the tracking of your online activity and collection of device data through automated means, which we have summarized below:

  • Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
  • Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
  • Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt-out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
  • Platform opt outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising:
    Facebook: https://www.facebook.com/help/109378269482053
    Amazon: https://www.amazon.com/adprefs
    Tik Tok: https://www.tiktok.com/legal/cookie-policy?lang=en
    Bing: https://account.microsoft.com/privacy/ad-settings/signedout?refd=www.searchenginewatch.com&ru=https://account.microsoft.com/privacy/ad-settings/refd=www.searchenginewatch.com
    Trade Doubler: https://www.tradedoubler.com/en/privacy-policy/
  • Updating your SNS settings. To stop sharing your information with Facebook and other SNS with whom NEUECELL permits you to connect your account, please modify your privacy settings on those platforms.  
  • Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
    Digital Advertising Alliance for Mobile Apps: www.youradchoices.com/appchoices
    Network Advertising Initiative: optout.networkadvertising.org

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use.

Other Sites and Services

Our Services may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.

Security

 

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of  personal information.

International Data Transfer

You may provide personal information directly to our website in the United States. We may also transfer personal information from Europe to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information. For more information about how we transfer personal information internationally, please contact us as set out in the “How to Contact Us” section below.

Privacy Shield Framework


NEUECELL complies with the EU-U.S. and the Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and Switzerland to the United States. NEUECELL has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit www.privacyshield.gov.

NEUECELL may transfer  personal information to third parties as described in this Privacy Policy. NEUECELL maintains contracts with its third-party service providers restricting their access, use, and disclosure of personal information in compliance with our Privacy Shield obligations. NEUECELL may be liable if these third parties fail to meet those obligations and we are responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, NEUECELL commits to resolving complaints about our collection or use of  personal information. European individuals with inquiries or complaints regarding our Privacy Policy should first contact NEUECELL at care@neuecell.com.  NEUECELL has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please visit www.neuecell.com/contact  for more information or to file a complaint. The services of JAMS are provided at no cost to you. If neither NEUECELL nor JAMS resolves your complaint, you may have the ability to engage in binding arbitration through the Privacy Shield Panel. Additional information on the arbitration process is available on the Privacy Shield website at www.privacyshield.gov.

NEUECELL may be required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. The Federal Trade Commission has jurisdiction over NEUECELL ’ compliance with the Privacy Shield. NEUECELL ’ commitments under the Privacy Principles are subject to the investigatory and enforcement powers of the Federal Trade Commission.

Children

Our Services are not intended for use by children under 16 years of age. If we learn that we have collected personal information through our Services from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

Job Applicants

When you visit the “Careers” portion of our websites, we collect the information that you provide to us in connection with your job application. This includes business and personal contact information, professional credentials and skills, educational and work history, and other information of the type that may be included in a resume. This may also include diversity information that you voluntarily provide. We use this information to facilitate our recruitment activities and process employment applications, such as by evaluating a job candidate for an employment activity, to monitor recruitment statistics, and  to respond to surveys.  We may also use this information to provide improved administration of our websites, and as otherwise necessary (a) to comply with relevant laws or to respond to subpoenas or warrants served on us; (b) to protect and defend our or others’ rights or property; (c) in connection with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms & Conditions.

Retention of Personal Information

We retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with our retention policies, and in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable). 

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our websites and online services. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through our Services. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of our Services after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to Contact Us

NEUECELL (USA). is the entity responsible for the processing of personal information and is the data controller in respect of such processing. You can reach us by email at care@neuecell.com  at the following postal addresses:

 

 

Alternatively, if you are based in the EEA you can contact NEUECELL LABORATORIES GMBH

 (Europe), by email at care@neuecell.com   or in writing to:

 

NEUECELL USA