Neufin - Privacy Policy

Effective Date: 3rd September 2024

Neufo Technologies Private Limited and/or its affiliates (“Neufin,” “Neufo”, “we,” “our,” and/or “us”) respect your privacy. We may collect information about you when you contact us or use Neufin’s websites or software or mobile applications or any other software of or relating to Neufin, including, but not limited to, www.neufin.co, or ‘Neufin Platform’ and the related services (collectively, our “Services”). This privacy policy (“Policy”) describes the types of information we may collect about you and your use of the Services and how we may use, maintain, protect, and disclose that information. If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), “information” means any information relating to an identified or identifiable individual.

This Policy applies to information we collect on the Services and through your electronic communications with us. This Policy does not apply to information collected offline or by any third party, including any links accessible on our Services.

Please read this Policy carefully to understand our privacy practices. If you do not agree with this Policy or our Terms of Use, you can choose not to use the Services. We may change this Policy from time to time and your continued use after we have made changes is deemed as an acceptance of those changes.

This Policy covers:

• Information We Collect

• How We Use Information

• How We Share Information

• Your Choices

• Security

• Cookies

• Do Not Track

• Other Websites

• International Visitors

• Changes to this Policy

• Contact Us

INFORMATION WE COLLECT

Information You Provide. You may provide us with information when you register or otherwise communicate with us through the Services, including when you:

• Submit information to us electronically

• Create or update an account on the Services

• Use our applications or other mircosites on our website

• Subscribe to email newsletters or updates

• Apply for a job with us

• Contact us
  

We collect information you choose to provide, which may include your name, user name, password, email address, telephone number, business information (such as title and company), employment information (such as a professional license number), and energy usage data. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. Please do not submit information that you do not want us to have.

Automatically Collected Information. When you use our Services, we may infer your general location information (for example, your IP address may indicate your more general geographic region). We also receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, and the dates and times of your visits. Further, we may collect information through cookies and other tracking technologies. For more information, please see the Cookies & Other Tools section below.

HOW WE USE INFORMATION

We use information that we collect about you or that you provide to us:

• To provide, maintain, improve, and enhance our Services;

• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;

• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you;

• To personalize your experience on our Services such as presenting tailored content;

• To de-identify and aggregate information collected through the Services and use it for any lawful purpose;

• To find and prevent fraud, and respond to trust and safety issues that may arise;

• For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

• For other purposes for which we provide specific notice at the time the information is collected.

We store and process the information in India as per the applicable laws of India from time to time.

LEGAL BASES FOR PROCESSING EUROPEAN INFORMATION

If you are located in the European Economic Area (“EEA”) or the United Kingdom (“UK”), we only process your information when we have a valid “legal basis”, including as set forth below.

• Consent. You have consented to the use of your information. For example, we may use cookies where you have consented to such use.

• Contractual Necessity. We need your information to provide you with our Services. For example, we may need to process your information to respond to your inquiries or requests.

• Compliance with a Legal Obligation. We have a legal obligation to use your information. For example, we may process your information to comply with tax, labour and accounting obligations.

• Legitimate Interests. We or a third party have a legitimate interest in using your information. Specifically, we have a legitimate interest in using your information for product development and internal analytics purposes, and otherwise to improve the safety, security, and performance of our Services. We only rely on our or a third party’s legitimate interests to process your information when these interests are not overridden by your rights and interests.
  

Additionally, We may process the information that we have about you, in the following manner.

1. We may process data about your use of our Website and Services (“Usage Data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of your visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your use of our services. The source of the usage data is our analytics tracking system. In addition, we may use third-party analytics tracking services such as Google Analytics and Facebook Pixel. This usage data may be processed for the purposes of analysing the use of the Website and services in order to improve our performance metrics, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely monitoring and improving our Website and services.

2. We may process your data that is provided to us during the course of your taking project eligibility assessments on our Website (“Response data”). The response data may include your name, company name, email, designation and your responses to any specific questions that we may ask you. The source of the response data is you. The response data may be processed for the purposes of providing our services, ensuring the integrity of our operations and processes, maintaining backups of our databases, and communicating with you. The legal basis for this processing is your consent.

3. We may process the information included in your personal profile on our Website (“Profile Data”). The profile data may include your name, address, telephone number, email address, profile pictures, date of birth, bank account details, registry account details (for carbon offsets / credits and I-RECs). The profile data may be processed for the purposes of enabling and monitoring your use of our Website and services, for providing services to you, and for communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration and operation of our Website and services.

4. We may process your personal data that are provided in the course of the use of our services (“Service Data”). The service data may include your name, address, telephone number, email address, bank account details, and registry account details. The source of the service data is you. The service data may be processed for the purposes of providing our services, ensuring the security of our Website and services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

5. We may process information that you post for publication on our Website or through our services (“Publication Data”). The publication data may be processed for the purposes of enabling such publication and administering our Website and services. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

6. We may process information contained in any enquiry you submit to us regarding our services (“Enquiry Data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you and for and for communicating with you. The legal basis for this processing is your consent.

7. We may process information relating to transactions, including bids/asks/purchase/investment for environmental assets, that you enter into with us and/or through our Website (“Transaction Data”). The transaction data may be processed for the purpose of supplying the purchased goods and services, keeping proper records of those transactions, and communicating with you. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our business. In some cases, the legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

8. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“Notification Data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters, and for communicating with you. The legal basis for this processing is your consent.

9. We may process information contained in or relating to any communication that you send to us (“Correspondence Data”). The correspondence data may include the communication content and metadata associated with the communication. Our Website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent. In some cases, the legal basis for this processing is our legitimate interests, namely the proper administration of our Website and business and communications with our business counterparts.‍

In addition to the specific purposes for which we may process your personal data set out in this Section, we may process any of your personal data identified in this Policy where necessary for:

1. the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

2. the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

3. compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

We may also use your data for the following purposes:

1. To create and authenticate your account with the Neufin Platform

2. To identify you as a registered user of the Neufin Platform and to administer your account

3. To enable you to use the Neufin Platform and our services

4. To facilitate the operations of the Neufin Platform, including the offer of services to you by intermediaries such as service providers;

5. To publish fact-based views and opinions regarding, inter alia, the services offered on the Neufin Platform

6. To improve the quality of your experience when you interact with the Neufin Platform and use our services

7. To send you notifications, verification message(s) or email(s)

8. To allow our customer service to contact you, if necessary or respond to your queries and assist you with customer service or technical support

9. To send newsletters, surveys, offers, and other promotional materials related to our services and for other marketing purposes, customer analysis, market research and statistics

10. To request for reviews of our services or any other improvements

11. To prevent and detect fraud or abuse of our services as well as to prevent, detect and investigate any potential unlawful or prohibited activities.

HOW WE SHARE INFORMATION

Neufin may share your information, for example:

With Service Providers, Business Partners, and Vendors: We may retain other companies and individuals to perform services for us, and we may collaborate with other companies and individuals with respect to particular products or services (collectively, “Providers”). In doing so, we may share information with these Providers and/or these Providers may collect and process your information. Examples of Providers include data analysis firms (e.g. Google Analytics), customer service and support providers, and internet service companies.

With Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

With Advertising Partners. We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags, and similar technologies on our Services and they may otherwise collect or have access to information about you which they may collect over time and across different online services. If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the appropriate mobile app to learn more about how you may opt out of personalized ads in mobile apps.

To Comply with Law or to Protect Our Rights: We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.

To Members of the Corporate Family: Neufin may disclose your information to our subsidiaries and affiliates, and their agents and employees, for any of the purposes described in this Privacy Policy.

In Connection with Business Transfers: We may disclose and transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.

With Your Consent. We may also disclose information from or about you or your devices with your consent.

YOUR CHOICES

Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.

Your European Privacy Rights.  If you are located in the EEA or the UK, you have additional rights described below.

• You may request access to the information we maintain about you, update and correct inaccuracies in your information, restrict or object to the processing of your information, have your information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

• You may withdraw any consent you previously provided to us regarding the processing of your information at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details at the end of this Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

How to Block Cookies. You can block cookies by setting your internet browser to block some or all cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Services. By using our Services, you consent to our use of cookies and our processing of information collected through such cookies, in accordance with this Policy. You can withdraw your consent at any time by deleting placed cookies and disabling cookies in your browser, or as explained below. You can change your browser settings to block or notify you when you receive a cookie, delete cookies or browse our Services using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Services may not function properly if you do not accept cookies or these technologies. Where required by applicable law, you will be asked to consent to certain cookies and similar technologies before we use or install them on your computer or other device.

SECURITY

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information.

COOKIES & OTHER TOOLS

In addition to information you may provide directly to us, Neufin and its business partners may automatically collect and store information about you and your use of the Services through cookies, tracking pixels, and other technologies (collectively, “Tools”). Cookies are small text files that are stored by your browser on your computer’s hard drive. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Below is an overview of the types of cookies we and third parties may use to collect information.

Strictly Necessary Cookies. Some cookies are strictly necessary to make our Services available to you. We cannot provide you with our Services without this type of cookies.

Analytical or Performance Cookies. We also use cookies for website analytics purposes in order to operate, maintain and improve our Services. We may use our own analytics cookies or use third-party analytics providers such as Google, Hubspot. These providers may also collect information about your use of other websites, apps, and online resources.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential.

DO NOT TRACK DISCLOSURES

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they don’t track the user. Currently, there is no standardized way to respond to such signals, and we do not respond to such signals at this time.

OTHER WEBSITES

Our Services may contain links to websites of third parties who: (1) are not affiliated with us; (2) are outside our control; or (3) are not covered by this Policy (“Third-Party Websites”). Links provided to Third-Party Websites on our Services are provided to you only as a convenience, and the inclusion of any link does not imply reliability or endorsement by us of the content of any such Third-Party Websites. We are not responsible for the privacy practices of Third-Party Websites, which may collect and use information from you in a manner different than how we do so; accordingly, the use of such Third-Party Websites is entirely at your own risk. For relevant information, you should review the privacy statements or policies of any Third-Party Websites before using them. Other parties may collect information about your online activities over time and across different websites when you use our Services.

RETENTION

We take measures to delete your information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep this information for a longer period.  When we process information for our own purposes, we determine the retention period taking into account various criteria, such as the type of services provided to you, the nature and length of our relationship with you, possible re-enrolment with our services, the impact on the services we provide to you if we delete some information from or about you, and mandatory retention periods provided by law and the statute of limitations.

INTERNATIONAL VISITORS

Our Services are hosted in the India. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from Indian law, then please note that you are transferring your information outside of those regions to the United States or other regions for storage and processing. We may transfer information from the EEA or the UK to the U.S. and other third countries based on European Commission-approved Standard Contractual Clauses, or otherwise in accordance with applicable data protection laws. Also, we may transfer your data from the United States to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including information, on or to the Services, you consent to such transfer, storage, and processing.

COMMUNICATIONS

You may receive email updates from us through our newsletters, surveys, offers, and other promotional materials related to our services. We hope you will find these updates interesting and informative. If you wish not to receive them, please click on the "unsubscribe" link or follow the instructions in each message. You may share your feedback and comments with us, including those relating to an issue or incident. To report an incident regarding your data, you may contact us using our contact details and inform us about such incidents.

LIMITATION OF LIABILITY

We are not responsible for verifying the authenticity of the information supplied by you. In case of any erroneous data, our liability is limited to removal of such data from our system. We are not liable for any data loss or theft due to unauthorised access to your computer or device. We shall not be responsible for any breach of security or for any actions of any third parties that receive your personal data or events that are beyond our reasonable control including, acts of government, computer hacking, unauthorised access to computer data and storage devices, computer crashes, breach of security and encryption, poor quality of internet service or telephone service etc.

DERIVATIVE DATA

We may generate derived data and anonymous statistical information based on the data available on the Neufin Platform. Such derived data and anonymous statistical information shall not identify you at a personal level, and shall be exclusively our property. We may use such data or information for any legitimate purpose as we may determine, without any compensation to you.

CHANGES TO THIS POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

CONTACT US

If you have questions or concerns about this Policy or our privacy practices, please contact us at:
Post: 710 Lodha Supremus, Wadala, Mumbai – 400037, Maharashtra, India
Email: contact@neufin.co