We understand that privacy policies can be complex. If you are looking for a more digestible breakdown of our practices and procedures, we invite you to check out our Privacy Guide. While we do recommend you read this policy, our Privacy Guide offers a straightforward overview, designed to help you quickly grasp our approach to your data. This guide is part of our commitment to clarity and transparency, ensuring you always feel informed and in control.
Last updated: 05 October 2023
- What Information We Collect and Process
- How We Use Personal Data
- How We Share Personal Data
- How We Transfer Personal Data Internationally
- How We Store and Secure Personal Data
- Your Privacy Rights and Choices
- California Privacy Rights
- Data Protection Officer
- Other Important Privacy Information
1. What Information We Collect and Process
a. Information You Provide to Neon
When You Visit Our Websites
We collect Personal Data from you when you submit web forms or interact with our websites; for example when subscribing to a Neon newsletter, signing up for a webinar, subscribing to our Sub-processor notifications, one of our services, or requesting customer support. We may ask for your email address, first and last name, job title, and other similar business information. You are free to explore some of our websites without providing any Personal Data about yourself.
Information we collect automatically
Even if you do not provide information to us, we automatically collect technical data, such as web logs about your use of and interaction with our Services. We use the technical data to troubleshoot problems, gather information for analysis of the Services, customize your experience when accessing our Services, and for other business purposes.
When you register for a Neon event, we collect information such as name, address, phone number, and email address. We use this information to communicate with you and, in some cases, facilitate your registration. Additionally, we may share your registration data with service providers to provide event information and improve your experience for future Neon events.
Account and User Information
We collect Personal Data when you sign up for a Neon Account, create or modify user information, set preferences, or provide any other related information to access or utilize the Service.
You may also provide payment information, such as a credit card number or bank account number, when purchasing products or services. We use secure third-party payment service providers to manage payment processing, which is collected through a secure payment process.
We post customer testimonials and comments on our Website, which may contain Personal Data. We obtain each Customer’s consent via email or through other agreements between Customers and Neon prior to posting the Customer’s name and testimonial.
b. Information We Process on Behalf of Customers When they Use the Services
Customer Personal Data means Personal Data that Neon processes as a data processor for the Customer for the purpose of providing the Services. The Customer Personal Data includes Personal Data that the Customer and/or any Authorized User Transfers through the Platform in connection with its use of the Services.
We want to make it clear that we do not control any Customer Data that is uploaded and stored on the Platform.
We store Customer Data on our service provider’s servers, the region determined by our Customers. We process Customer Data as a processor under our Customer’s instructions and in compliance with the applicable Agreement.
Our Customers control and are responsible for correcting, deleting, or updating anyCustomer Data that they Transfer to the Platform and are also responsible for complying with any regulations or laws that require providing notice, disclosure, and/or obtaining consent prior to transferring the Personal Data to Neon for processing purposes.
Our Agreement prohibits the transfer or upload of Sensitive Information. You shall be solely liable for any and all liabilities arising from or relating to the transfer of Sensitive Information.
c. Information We Collect and Process When You Use the Platform
Information From Users With Accounts
If you create an Account, we require some basic information at the time of Account creation. To create an Account, you have the option to either provide your name, password, and a valid email address or create an Account by logging into a Hasura, Github, Google Account, or any other method listed on our sign-up page. You also have the option to give us more information if you want to, which may include “User Personal Information.”
“User Personal Information” is any information about a user that could, alone or together with other information, personally identify the user. Information such as a user name and password, an email address, a real name, and a profile picture or an avatar are examples of “User Personal Information.”
User Personal Information does not include aggregated, non-personally identifying information. We may use aggregated, non-personally identifying information to operate, improve, and optimize our Service.
We may generate and use technical logs, data and learnings about your use of the Platform, and Customer Data in an aggregate, anonymized form (“Usage Data”).
We engage third-party providers to collect Usage Data. For more information about how we protect your information with these service providers, please see the section “How We Share Personal Data”.
You may connect third-party integrations to your Neon Account. These third-party integrations may ask for certain permissions to access Customer Data, Personal Data, or send information to your Neon Account. It is your responsibility to review any third-party integrations you authorize. We may collect information about what types of integrations you use in your Neon Account.
Any permission(s) granted by you grant(s) these third parties access to your Customer Data and your Personal Data, which may include (but is not limited to) granting third-party applications access to view, store, and modify your Customer Data, Personal Data, or any other data stored in your Neon Account. We are not responsible for the practices of third-party integrations, so please carefully review the permissions you grant to third-party applications.
Information From Website Browsers
We use common internet technologies, such as web server logs, to collect data about all visitors that access our Website.
The information we collect about visitors to our Website includes the visitor’s browser type, language preference, referring site, additional websites requested, and the date and time of each visitor request. We also collect potentially personally-identifying information like Internet Protocol (IP) addresses. We collect this information to better understand how visitors to our Website use Neon, and to monitor and protect the security of the Website.
d. Information We Collect From Other Sources
We may receive information about you or other users of your Neon Account from our global network of partners. We may receive this data from our deal and lead registration process through our partners.
We may also collect information about you through our partner co-marketing partnerships. For example, you may sign up to a webinar or download a white paper published by Neon and a Neon co-marketing partner.
We may receive information from third-party service providers, from related companies, and from our business and solution partners.
Personal Data from Different Sources
Buttons, tools from other companies
2. How We Use Personal Data
To facilitate contractual and pre-contractual business relationships
We use Personal Data to enter into business relationships with prospective customers and to perform the contractual obligations under the Agreements that we have with existing Customers. For example, we may collect your Personal Data to schedule calls and meetings for the Platform’s demo, prepare offers for you, set up and manage your Account on the Platform, or perform certain accounting, auditing, and billing activities.
To comply with our regulatory and other legal obligations
These regulatory and other legal obligations include Data Processing requirements of the GDPR and “Anti-Money Laundering” (AML) and “Know-Your-Customer” (KYC) obligations.
To Communicate with You About the Services
We use the Account information you provide to Neon when signing up for an Account to send you transactional emails about billing, account management, and other administrative matters. We may also send you updates regarding our Agreement or other legal agreements, and may also communicate with you about security incidents via email.
To Provide the Service and offer support
We use your Account information, Personal Data, and Customer Data to provide the Services. For example, we use the email address you provide when signing up for the product to create your Account, and we use your payment information to process payments for paid use of the Platform or Products. We may also use this information to authenticate you when you log in and to provide customer support.
We use your information both Personal Data and Customer Data to provide customer support, such as resolving technical issues you encounter and analyzing product outages or bugs. You grant Neon the right to use your Personal Data and Customer Data solely as necessary to (a) maintain, improve, protect and update the Services and the Platform; (b) to prevent or address service, security, support, or technical issues related to the Services.
To Personalize the Platform for you by understanding your needs.
We may use Usage Data to operate, improve, analyze and support the Platform and/or the Services, and for other lawful business purposes. Neon might use the Customer Data without de-identification, aggregation and anonymization only for troubleshooting and/or support purposes.
To Develop new Services and Improve existing Services
We also collect Usage Data to develop and improve our Services and create new services and products. For example, we use Usage Data to identify friction and bottlenecks in the user’s journey to optimize and improve the experience of our customers. We also use Usage Data to assess trends and usage across the Platform to help us determine what new features or integrations our users may be interested in.
For Research and Analysis
We conduct aggregate analysis, market research and planning, develop business intelligence, generate statistical studies that enable us to operate, protect, make informed decisions, and report on the performance of our business.
To Secure and Protect our Platform and Users
We use your Account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user Accounts and to detect and prevent abuse.
We use log files to provide general statistics regarding use of our Website by you, including how you use our websites, what country you are logging in from (for analytics, export control, and regulatory purposes) and to help improve the navigation experience. Your IP addresses are also collected and logged for security purposes; for example, to track access patterns and investigate security events and incidents. For these purposes, we link this automatically-collected data to other personal data provided by you, for example your name, email address, address, and phone number.
To Market and Promote the Services
We use the information you provide to Neon to market and promote the Services and other offerings. For example, we might use your email or physical address to send you information or content that we think may be of interest to you, by post, email, or other means. We may also send you marketing communications relating to our business.
You may opt out of receiving this promotional content by following the instructions contained in each communication that we send you or by contacting us at email@example.com. If you unsubscribe from our marketing lists, we will only continue to contact you regarding administrative matters and to respond to your requests.
We may also reach out to you via email or telephone to ask about other Neon Products or Services you may be interested in. If you have a call scheduled with a Neon representative, we may record and transcribe the call. You will be notified prior to the call that the call is being recorded, and you will be offered an opportunity to opt out of having the call recorded.
Where required by law, we will only send marketing communications with your consent. Otherwise, we will market and advertise our products and services on the basis of our legitimate business interests.
Other purposes if we obtain your consent
We share your data with third parties when you give us consent to do so.
Legal Basis for Processing Personal Data (EEA and UK visitors only)
Our legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which we collect it. However, we will normally collect Personal Data from you only where we have your consent to do so, where we need the Personal Data to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect Personal Data from you.
If we ask you to provide Personal Data to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Data is mandatory or not (as well as of the possible consequences if you do not provide your Personal Data). Similarly, if we collect and use your Personal Data in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
3. How We Share Personal Data
a. Service Providers
We may share Personal Data with our third-party service providers to support our Services. For example, we use service providers for data hosting, application development, marketing, sales support, and customer support. We may need to share your information with service providers to provide information about products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis on your use of the Platform or interactions on our websites, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, developing and improving the product and services, and providing customer service or support. These service providers are prohibited from using your Personal Data except for these purposes, and they are required to maintain the confidentiality of your information. In all cases where we share your information in this way, we explicitly require the third-party service providers to acknowledge and adhere to our privacy and data protection policies and standards.
We may share Personal Data with trusted Neon partners to provide our Services. We will also share Personal Data to contact you based on your request to receive such communications, help us perform statistical analysis, provide sales support, or provide customer support. Partners are required to maintain the confidentiality and security of your data.
c. Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Neon via providing the Services. In this event, you will be notified via email and/or a prominent notice on our Website of any change in ownership, uses of your Personal Data, and choices you may have regarding your Personal Data.
d. Public Forums
Our websites may offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums (including profile information associated with the Account you use to post the information) it may be read, collected, and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your Account. We urge you to consider the sensitivity of any information you may disclose in this way. We will correct or delete any information you have posted on the websites if you so request, as described in Section “Your Privacy Rights and Choices” below. In some cases, we may not be able to remove your information, in which case we will let you know if we are unable to and why.
e. Compelled Disclosure
We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process. If you use the Platform, Customer Data is considered Confidential Information and you should review the Confidentiality terms in the Agreement for more information.
4. How We Transfer Personal Data Internationally
a. International Transfers
b. International transfers to third parties
c. Data Privacy Framework Notice
Neon complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce (collectively “the Data Privacy Framework”).
In compliance with the DPF Principles, Neon commits to resolve DPF Principles-related complaints about our collection and use of your Personal Data. We will investigate and attempt to resolve any DPF Principles-related complaints within 45 days. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the DPF Principles should first contact Neon via firstname.lastname@example.org.
If you have unresolved DPF-related complaints that we have not addressed satisfactorily, please contact the:
EU DPA panel if you are based in the European Union.
Swiss Federal Data Protection and Information Commissioner (FDPIC) if you are based in Switzerland.
Information Commissioner’s Office if you are based in the United Kingdom.
Under certain conditions, more fully described on the DPF website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. The Federal Trade Commission has jurisdiction over Neon’s compliance with the DPF Principles.
In the context of an onward transfer, Neon is responsible for the processing of Personal Data it receives under the DPF Principles and subsequently transfers to a third party acting as an agent on our behalf. Neon shall remain liable under the DPF Principles if our agent processes your Personal Data in a manner inconsistent with the DPF Principles, unless Neon is not responsible for the event giving rise to the damage.
Please note that under certain circumstances, we may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
5. How We Store and Secure Personal Data
a. Data Storage and Security
We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We secure the Personal Data you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure. All Personal Data is protected using appropriate physical, technical, and organizational measures. For more on Security at Neon, please see https://neon.tech/docs/security/security-overview.
b. Retention of Personal Data
How long we keep the information we collect about you depends on the type of information as well as how we collect and store that information.
We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes, and enforce our agreements).
When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it, or if deletion/anonymization is not possible, we will securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section “Privacy Rights and Choices” below.
If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time, starting from the date you last expressed interest in our Customer Data, products, or services, for example as when you last opened an email from us or ceased using your Neon Account.
Customer Data transferred to the Platform is retained according to the Agreement, Data Retention Policy, and any applicable Data Processing agreement.
6. Your Privacy Rights and Choices
a. Personal Data Requests
You have the following data protection rights:
- Access, Correction, or Deletion. You can request access, correction, updates, or deletion of your Personal Data.
- Objection. You can object to our processing of your Personal Data, ask us to restrict processing of your Personal Data, or request portability of your Personal Data.
- Withdraw Consent. If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- Complaint. You have the right to complain to a data protection authority about our collection and use of your Personal Data. Contact details for data protection authorities in the EEA are available here.
To exercise any of these rights, please contact us at email@example.com.
Please note that to protect personal information, we may verify your identity by a method appropriate to the type of request you are making. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken. In some instances, your rights 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.
b. To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails or by updating your communication preferences.
Customers cannot opt out of receiving transactional emails related to their Account.
7. California Privacy Rights
This section applies only to California consumers. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers’ Personal Information in our role as a business, and the rights applicable to such residents. The California Consumer Privacy Act (“CCPA”) requires businesses to disclose whether they sell Personal Information. Neon is a business and does not sell Personal Information. We may share Personal Information with authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Information.
b. How We Collect, Use, and Share your Personal Information
We have collected the following statutory categories of Personal Information in the past twelve (12) months:
- Identifiers, such as name, email address, mailing address, and phone number. We collect this information directly from you or from third-party sources.
- Commercial information, such as Account records. We collect this information directly from you.
- Internet or network information, such as browsing and search history. We collect this information directly from your device.
- Geolocation data, such as IP address. We collect this information from your device.
- Financial information, such as Payment Information or financial Account numbers in the process of providing you with the Platform. We collect this information from you.
- Other Personal Information, in instances when you interact with us online, by phone, or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Services.
c. Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected, used, and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
Neon does not sell or share Personal Information to third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).
d. How to Exercise your California Rights
You can exercise your rights yourself, or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your Personal Information.
Please use the contact details below, or see Section 7 “Your Privacy Rights and Choices” above, if you would like to:
- Access this policy in an alternative format;
- Exercise your rights;
- Learn more about your rights or our privacy practices; or
- Designate an authorized agent to make a request on your behalf.
8. Data Protection Officer
9. Other Important Privacy Information
a. We Never Sell Personal Data
We will never sell your Personal Data to any third party.
b. Information About Children
The websites, product, Platform, and services are not intended for or targeted at children under 16 and we do not knowingly or intentionally collect Personal Data about children under 16. If you believe that we have collected Personal Data about a child under 16, please contact us so that we can delete the information. If you are a minor under the age of 16, you are not permitted to have an Account on Neon. If we learn or have reason to suspect that you are a user who is under the age of 16, we will unfortunately have to close your Account. Please see the Agreement for information about Account termination.
c. Third-Party Dispute Resolution
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact the:
EU DPA panel if you are based in the European Union.
Swiss Federal Data Protection and Information Commissioner (FDPIC) if you are based in Switzerland.
Information Commissioner’s Office if you are based in the United Kingdom.
e. Technical Preview
While we strive to protect your privacy to the best of our ability, please understand that:
- Notification: We will make reasonable efforts to inform you of any specific privacy practices or changes that apply to Technical Preview Products but it is essential to exercise caution and discretion when using them.