Privacy Statement

Neudata Limited respect the privacy of every person who visits, registers with or subscribes to our website or services ("you").

This Privacy Statement outlines the information we collect about you in relation to your use of our website, related publications, products and services, and attendance at our events, and how we use and store such information that is personal data, in accordance with the applicable data protection and privacy legislation. It also outlines the methods by which we and our service providers may monitor your online behaviour in order to deliver marketing materials, facilitate communications both on our Site and off of our Site, and other tailored services. This Privacy Statement also tells you what rights you have in relation to your personal data and how you can exercise them.

This Privacy Statement applies to the neudata.co site, any related domains and subdomains operated by us, together with our related products and services hosted via our site (our “Site”). Please note that our Site may contain links to external sites. We are not responsible for these third parties and this Privacy Statement does not cover the activities of such third parties, so you should consult those third party sites’ privacy policies for information on how your data is used by them. We reserve the right to update this Privacy Statement when required or appropriate. We may also notify you in other ways from time to time about the processing of your personal data.

Information about us

This Privacy Statement is issued by Neudata Limited, a company registered in England with number 09942593 and its affiliates worldwide who may access your personal data for intragroup business purposes (“Neudata” or “we”), which is responsible for this Site. For the purposes of relevant data protection law, Neudata is the controller of your personal data which means we are responsible for deciding how we use and store your personal data.

If you have any questions about this Privacy Statement, including any requests to exercise your legal rights, please contact us as follows:

If you are in the United Kingdom or Europe:

• Postal mail to this address: Neudata Ltd, 1 Fore St Ave, London, EC2Y 5EJ.
• Telephone: + 44 (0)20 3608 2162
• Email: privacy@neudata.co

Collection and Use of Personal Data

We collect certain personal data from you when using our Site or registering or subscribing for our products and services.

This Site and our services are not intended for use by children. Please note that we do not intend to collect any personal data from children and no child should submit any personal data to our Site. Should we discover that any such personal data has been delivered to our Site, we will remove that personal data as soon as possible.

If you do not provide certain information when requested, we may not be able to perform a contract we have entered into with you (such as a contract for events or access to our subscriptions).

We will only use your personal data for the purposes for which we collected it or as disclosed in this Privacy Statement, unless we reasonably consider that we need to use it for another reason and, where required by applicable data protection law, that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and, if required by applicable data protection law, explain the legal basis which allows us to do so. We may also process your personal data without your knowledge or consent where this is required or permitted by law.

We may also disclose your personal data to other third parties, including, without limitation, professional advisers, or governmental or state institutions or regulatory authorities, where necessary in order to exercise or defend legal rights or where required by law. These third parties will also include a provider of server hosting in Germany, a provider of server hosting in France, a provider of hosted software services in the United Kingdom, a provider of email hosting services in Ireland, a provider to track email read and open receipts in the United States and affiliates of Neudata from time to time, based in the United States and Shanghai.

We may transfer, sell or assign any of the information described in this Privacy Statement to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganisation of our business.

If you are located in the United Kingdom or the European Economic Area, or where otherwise required by applicable data protection law, please see the table below for the legal basis of our activities processing your personal data.

Purpose/Activity	Lawful basis for using your personal data
Provision of website	Legitimate business interests in providing Neudata’s services
Registration to allow users to access certain content, events and subscriptions	To fulfil a contract we have entered into or are preparing to enter into with you
Administer and deliver requested products and services	To fulfil a contract that we have entered into or are preparing to enter into with you
Improvement of services through collection on data on use of the website	Legitimate interests in providing Neudata’s services
Allow individuals to upload/input data to the website	To fulfil a contract that we have entered into or are preparing to enter into with you
Recording actions taken by a user on the website e.g. content viewed or searched for	Legitimate interests in providing Neudata’s services
Contact individuals with marketing/advertising and review email read and open receipts	Legitimate interests in marketing Neudata’s services and promoting Neudata’s business
Administering and maintaining records of services or advice we have received, and commissioning further services	Legitimate interests in running and promoting Neudata’s business
Use of candidate data for recruitment	To fulfil a contract that we have entered into or are preparing to enter into with you

Customer Services and Administration

Our Site collects personal data such as your name, job title, work or home address, telephone number, email address, and other similar profile information in order to register you for access to certain content, events and subscriptions. We also process your IP address in order to provide the Site.

This information may be supplemented with demographic information from your use of our Site such as your postal area, purchasing preferences, or interests. Our Site will only collect this broad demographic information for aggregate use. This information is used to administer and deliver to you the products or services you have requested, to operate our Site efficiently and improve our service to you for our legitimate business purposes or to fulfil a contract we have entered into with you.

Monitoring Use of our Site

Where, as part of our Site services, we enable you to post information or materials on our Site, we may access and monitor any information which you upload or input, including in any password-protected sections, as well as detail on what parts of the Site you visit and actions taken, e.g. content viewed or searched for.

If you are a registered user (e.g. a subscriber or taking a trial), when you log on, this places a cookie on your device. This enables your access to content and services that are not publicly available. Once you are logged on, the actions you take - for example, viewing a page on our Site - will be recorded. We may use technology or a service provider to do this for us. This information may be used for one or more of the following purposes:

• to fulfil our obligations to you;
• to communicate with you regarding our Site;
• to improve the efficiency, quality and design of our Site and services;
• to see which pages, features and services are most viewed and used;
• to track compliance with our terms and conditions of use, e.g. to ensure that you are acting within the scope of your user licence;
• for business-to-business marketing purposes (subject to your rights under applicable law to opt-out of receiving certain marketing communications);
• for advertising purposes, although the information used for these purposes does not identify you personally;
• to exercise our legal rights or comply with our obligations; and
• to enable our employees to contact and interact with you online in connection with any content you may post to our Site.

This monitoring is for our legitimate business purposes to develop and improve services offered or provided to you.

Please see below for more information on cookies and similar technologies and a link to a page where you can turn them on or off.

Marketing

Some of your personal data set out above may be used by us and/or our other group companies and third-party service providers on behalf of Neudata to contact you by email, fax, telephone and/or post for business-to-business marketing purposes, including sending information or promotional material on our products and/or services and/or those of our other group companies. We may also share your contact information with third parties (e.g., vendors, data providers, etc.) at events we host and participate in for business-to-business marketing purposes, subject to your right to opt out of such marketing under applicable law. When other third parties market directly to you, you should consult those third parties’ respective privacy policies.

We give you the opportunity to opt-out of receiving marketing communications from Neudata. Further detail can be found on the applicable Site and in each marketing communication sent by us, our group companies or service providers on our behalf.

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:

(i)Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

Third Parties, Counterparties and Vendors

If you are an individual associated with a vendor, third party or counterparty to Neudata, we will collect, use and store limited amounts of personal data relating to you, including your name, job title, qualifications, employer or parent organisation and contact details.

We will collect, use and store this personal data for the purposes of administering and maintaining records of services or advice we have received, and commissioning further services. Our legal basis for collecting, using and storing this data that you provide to us is that such processing is necessary for our legitimate interests in running and promoting our business.

The personal data we hold about individuals associated with our suppliers and professional advisers will be shared with companies which process personal data on Neudata’s behalf,  professional advisors, such as accountants, lawyers, and other consultants.

Candidates for Staff Positions

If you apply for a position at Neudata, we may collect personal data about you as a candidate during the application and recruitment process, either directly from you or from third parties (such as recruitment agencies, credit reference agencies or former employees). Recruitment agencies which collect and use your personal data (including for the purpose of introducing you as a candidate to Neudata) act as the controller of your personal data for that purpose and their use of your data is subject to a separate privacy notice provided by the agencies to you.

The personal data we require in order to progress your application as a candidate may include personal contact details such as name, title, addresses, telephone numbers, and personal email addresses, date of birth, gender, current salary, compensation history, annual leave, pension and benefits information, current notice period and other employment records from previous roles, start date and location of employment; recruitment information (including copies of right to work documentation, references and other information included in a CV or cover letter or as part of the application process) and visual images and photographs provided for business purposes.

Usually, where relevant under applicable data protection law, the legal basis for which we will use your personal data is to take steps prior to entering into a contract with you (for example your employment contract), where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or where we need to comply with a legal or regulatory obligation.

If you are successful in your application, we will only transfer personal data to your employment record if it is relevant to your ongoing working relationship with Neudata. If you are unsuccessful in your application, we will delete your application details but will keep on file your name, any additional identifiers required to distinguish candidates of the same name and the position for which you applied for future recruitment purposes unless you specifically request that this should not be the case.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer a candidate of Neudata we will not keep any personal data about you for any longer than is necessary for the purposes for which the personal data is processed or for which we are legally required or recommended to retain a copy and will delete it after this point.

Special Category Personal Data

If you are located in the United Kingdom or Europe or where otherwise relevant to applicable data protection law, there are more sensitive types of personal data which require a higher level of protection known as ‘special category data’. These include details about your race or ethnicity, trade union membership, religious or philosophical beliefs, sex life, sexual orientation, political opinions, information about your health and genetic and biometric data. We do not collect, and request that you do not provide us with, any ‘special category data’ about you.

Cookies and Similar Technologies

Cookies are pieces of information which include a unique reference code that a website transfers to your device to store and sometimes track information about you. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the Site and will last for longer. Cookies cannot be used to run programs or deliver viruses to your computer. They are uniquely assigned to you and can only be read by a Web server in the domain that issued the cookie.

You can review our Cookie Notice which includes a list of the cookies and similar technologies used on this Site and instructions on how to turn them on and off here. Please email us at privacy@neudata.co if you have any queries about cookies.

Email tracking: So that we can better understand our users` needs, we track responses to our emails for our legitimate business purposes - for example, to see which links are the most popular in newsletters, and to log and follow up responses to our marketing messages. To do this, we use a third-party service provider in the United States to enable this tracking, which uses pixel GIFs, also known as "pixel tags" - these are small image files that are placed within the body of our email messages. They enable us to tell if a message has been opened and to track click-throughs on links within the message.

Transfers of Personal Data outside the UK or Europe

Our Site is accessible globally so collection and transmission of personal data is not always limited to one country. Neudata may transfer your personal data, for the purposes listed above, to its group companies, other companies, service providers or other third parties which may be located in countries outside the United Kingdom (UK) or European Economic Area (EEA), whose laws may not give the level of protection to personal data as within the UK/EEA. This will include transfers to third parties who provide us with data storage, hosting, communications, conferencing, email and marketing services.

Whenever we transfer your personal data out of the UK/EEA, we ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards, in each instance, to the extent required by applicable data protection law:

• We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and the UK government. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
• We use specific contracts approved by the European Commission and the UK government which give personal data the same protection it has in Europe and the United Kingdom. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
• Any data transfer mechanism approved by the European Commission or the UK authorities as appropriate, such as an equivalent to the Privacy Shield or updated Model Contracts approved by the EU Commission or the UK government.

Please contact us if you would like further information on the specific mechanism used by us when transferring your personal data out of the UK/EEA.

Retention, Confidentiality and Security of Your Personal Data

We are committed to keeping the data you provide us secure and will take appropriate measures to protect your personal data.

All our employees, contractors and data processors (i.e. those who process your personal data on our behalf, for the purposes listed above), who have access to, and are associated with the processing of your personal data, are obliged to keep such personal data confidential and not use it for any other purpose than to carry out the services they are performing for us.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory or reporting requirements. To decide on the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Your Rights Regarding Personal Data

Consents and opt-outs

Neudata only relies on consent in limited circumstances. In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact us. Once we have received notification that you have withdrawn your consent, we will no longer process your relevant personal data for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

You can opt out of particular uses of your personal data as indicated above by:

• indicating at the point on the Site where personal data is collected;
• informing us by email, post or phone; or
• updating your preferences on the Site;

For turning cookies and similar technologies on and off, see the information in “Cookies and Similar Technologies” above.

Accuracy

You are responsible for providing accurate and current information, including with respect to any personal data you provide. Please keep us informed if your personal data changes during your relationship with us.

Your Rights

Under certain circumstances, if you are located in the United Kingdom or Europe, or under applicable data protection law, you have the right to:

• Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected.
• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have exercised your right to object to processing (see below).
• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object where we are processing your personal data for direct marketing purposes.
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of personal data about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal data to another party.

You will not have to pay a fee to access your personal data (or to exercise any of your other rights under applicable data protection law). However, we may charge a reasonable fee if your request is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal data is not disclosed to any person who has no right to receive it. 

This Privacy Statement was last updated in December 2023.