NEOGROUP INC. PRIVACY STATEMENT

Effective Date: May 23, 2018

Your privacy is important to us. This Privacy Statement describes the types of information NEOGROUP, INC. (“Neo Group” or “we” or “us” or variations of the same) collects from and about you when you visit our websites, at http://neogroup.com, www.supplywisdom.com, or https://app.supplywisdom.com (collectively, “Site”). This Privacy Statement also explains how Neo Group may use and disclose such information, as well as your ability to control certain uses of it. Use of the Site is subject to NeoGroup’s Terms of Use (“Terms”) .

DATA CONTROLLER

Neo Group will be the controller of Personal Information you provide to Neo Group. Our contact information is below.

INFORMATION COLLECTION

– Information You Provide to Us

Neo Group collects information that you choose to provide to us, such as when you request information or a demonstration from us, create an account with us, download gated content from us, sign up for our email lists, use our Site, or otherwise contact us.

The information we collect may include your name, email address, physical address, telephone number, screen or user name and, if you are a Neo Group customer, your payment information such as credit card information, debit card information, or bank account information. You may be required to provide certain information to create your Neo Group account or to utilize our services.

Neo Group does not collect Sensitive Personal Information (as such term is understood within the meaning of the GDPR) such as information relating to health, race, ethnicity, sexual orientation and political opinions. Any updates to the types of information we collect will be provided on this Site and you will have opt-in rights as set forth herein.

– Information We Automatically Collect

We may use cookies or other technologies to automatically collect certain information when you use our Site or interact with our emails and online or mobile advertisements. For example, we may automatically collect certain information from you, such as your browser type, operating system, software version, Internet Protocol (“IP”) address, mobile or ISP carrier information, and the domain name from which you accessed the Site. We also may collect information about your use of the Site including the date and time you access the Site, the areas or pages of the Site that you visit, the amount of time you spend using the Site, the number of times you return, whether you open forward or click-through emails and ads, and other usage data.

Tracking Options and California Do Not Track Disclosures. You may adjust your browser or operating system settings to limit this tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Check the “Help” menu of your browser or operating system to learn how to adjust your tracking settings or cookie preferences.

INFORMATION USE

Neo Group may use the information we collect from and about you to:

  • Respond to your inquiries, provide services, fulfill orders, process payments and help prevent transactional fraud, and contact and communicate with you;
  • Develop new products or services;
  • Provide you with customized content, targeted offers, and advertising on the Site, via telephone or via email;
  • Contact you with information, newsletters and promotional materials from Neo Group or on behalf of our partners and affiliates;
  • Research, address problems, and improve the usage and operations of the Site;
  • Protect the security or integrity of the Site and our business; and
  • As described to you at the point of data collection.

Neo Group may share the information we collect from and about you: (1) with our service providers, if the disclosure will enable them to perform a business, professional or technical support function for us; (2) as necessary if we believe that there has been a violation of the Neo Group Terms or of our rights or the rights of any third party; (3) to respond to judicial process or provide information to law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law; and (4) as described to you at the point of collection.

Neo Group also may share aggregate or anonymous non-personal information with third parties for their marketing or analytics uses.

Neo Group may sell or purchase assets during the normal course of our business. If another entity acquires us or any of our assets, information we have collected about you may be transferred to such entity. In addition, if any bankruptcy or reorganization proceeding is brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we will use reasonable efforts to try to require that the transferee use personal information provided through the Site in a manner that is consistent with this Privacy Statement.

SERVICE PROVIDERS

Neo Group may contract with third parties to perform functions related to the Services (“Service Providers”) including, without limitation, payment processors and cloud service hosting providers. Service Providers may have access to your personal information needed to perform their business functions, but may not use or share that personal information for other purposes.

ACCESS TO YOUR PERSONAL INFORMATION

If you have an account on the Site, you may sign in to your account and update your personal information contained in the account.

USER CHOICES

If you would like to update, modify, or remove your information or cancel subscription preferences, you may contact us as described in the “Contact” section below. On certain Site(s), you may be able to make these choices directly by logging into your account. You also may unsubscribe from any of our promotional emails by clicking on the “unsubscribe” link in any promotional email you receive from us. Changes made to your profile will be effective once saved into our systems in accordance with our standard procedures for implementing user questions regarding your Personal Information.

Depending on the data protection law of your country, you may have a legal right to obtain access to Personal Information we maintain about you. In addition, if you believe the Personal Information is inaccurate, you may have the legal right to request that we correct or amend the information. To make these requests, or to object to our processing of your Personal Information or withdraw consent to such processing (rights provided by the laws of certain countries), you may contact us as described in the Contact section below.

You may follow the directions in a marketing e-mail or direct mail or mobile communication that You receive from us to effect changes to Your use of the Web Site, or You may contact us using the contact information listed below.

As mentioned above, Neo Group does not collect Sensitive Personal Information at present. In future, should Neo Group decide to collect Sensitive Personal Information, we will only do so if you provide your consent. If you wish to opt-in to the collection and use of Sensitive Personal Information by us to provide services to you, which may include the transfer of such Sensitive Personal Information to third parties, then you may opt-in to such uses by checking the ‘opt-in’ box in your user preferences. If none of the available options meets your requirements, or you have other questions, please contact us directly.

As described in the Service Provider section, Neo Group may disclose Personal Information to third parties to perform functions related to the Services. If you wish to limit or restrict the disclosure of your Personal Information to third parties, you may opt-out of such third-party disclosures by sending us a notice via email. Our contact information is below.

EU RESIDENTS

If you reside in the EU and you utilize our Site(s) to either buy services which are offered to EU residents, or if we collect, track and/or process or transfer Personal Information from you, or personal data which you submit to us through the Site(s), your data will be managed in accordance with this Privacy Policy, the applicable Terms, and in compliance with requirements of the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679).

TRANSFERS OUTSIDE THE EU

If you are an EU resident and your Personal Information is collected through our Site(s), we may transfer such data to third parties for data processing and data control purposes as described in this Privacy Policy. Our commercial agreements with third party data processors or data controllers will comply with standard EU data protection contractual clauses as approved by the EU Commission (as amended).

Opt-in

If you are an EU resident, you have the right to opt-in to the collection, tracking and use of your personal data. We will not collect personal data from you unless you affirmatively accept our data practices as described in this privacy statement.

Opt-Out/Corrections

As an EU resident, you will, at any time, have the right to opt-out or withdraw consent to the collection or use of your data. If you withdraw consent, please be advised that it may inhibit or limit our ability to provide you with certain services and to perform certain functions. However, you may continue to use the Site(s) in accordance with the Terms and Privacy Policy.

As an EU resident, you may also request to view and change your data preferences, security settings, and consent preferences in your account dashboard provided that you set up a user profile on our site, or by emailing utilizing the contact information below. Additionally, as an EU resident, you may also opt out or withdraw consents, ask to correct errors in collected or submitted data, request that your personal data be erased or removed by informing us utilizing the link to our contact information below. If you withdraw consent, Company will erase or remove the relevant personal data collected.

PUBLIC FORUMS

Any information you may disclose in comments or on other public areas of the Site becomes public information. Please exercise caution when disclosing personal information in these public areas.

LINKS TO OTHER WEBSITES

The Site may have links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.

CHILDREN’S PRIVACY

Protecting children’s privacy is important to us. We do not direct the Site to, nor do we knowingly collect any personal information from, children under the age of thirteen.

DATA SECURITY

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers and Site visitors. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.

PRIVACY STATEMENT CHANGES

Neo Group reserves the right to revise this Privacy Statement at any time. When we do, we will post the change(s) on the Site. Your use of the Site after a change to the Privacy Statement is effective, means you agree to all such changes. If we change the Privacy Statement in a material way, we will provide appropriate notice to you.

QUESTIONS

If you have questions about this Privacy Statement, please feel free to email us at info@neogroup.com.