Privacy Policy

This privacy policy sets out how uses and protects any information that you give when you use this website is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. We may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes.

1. Data controller and representative

Neafs implements the processing of personal data listed below through its website. Neafs U.K. Ltd  is the designated representative of Director of UK Operations Julian Clarke, Neafs U.K. Ltd, 3rd Floor, 68-90 Paul St., London, EC2A 4NE, Company Registration #13561348 in EU in accordance with the Regulation No. 2016/679 on the protection of natural persons with regard to the processing of personal data (the “GDPR”).

Please read carefully the following privacy policy which provides you, as the user of the Website (the “User” or “You”), with the relevant information regarding the various processing of personal data implemented by Neafs, in accordance with GDPR.

2. Data processing implemented by Neafs

2.1 Processing of personal data related to your visit to our website

When the User visits to our Website, Neafs implements a processing of personal data as follows:

2.1.1 Personal data collected

Regarding this processing, Neafs collects the following personal data through the collection forms in the ordering process or other processes.

– Name;
– Gender;
– Age;
– Email address;
– Address;
– Country;
– Postal code;
– Phone number;
– Company name and industry you work for;
– Information we get from your visit to our websites. We collect information about how you visit our websites (including the webpage that led you to a Neafs website, the search terms entered into a search engine which led you to a Neafs website);
– Information we get from your use of our products. We collect information about the products that you use and how you use them, including but not limited to battery device model, firmware version, upgrade ROM firmware program info, upgrade operation logs;
– your product serial number;
– Content of customer support communications.

2.1.2 Purpose and legal basis of the processing

Neafs uses the information we collect about you for the following purposes:
For Verifying your identity and Providing customer service or support;
Analyze your use of our websites and products to better understand how they are being used so we can improve our services and the user experience and engage and retain users.

Information we collect from other sources.

Where you have asked us to provide an age restricted product or service, we may collect information from One Account Mobile Limited (1account) and third-party providers of identity data to 1account.  This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction legislation.  We will record that your age has been successfully verified so that you don’t need to go through the process again.  You can find information about how 1account manages your personal data and view their privacy policy by visiting their website: 1account.net.

2.1.3 Who we share your information with:

Where you have asked us to provide an age restricted product or service, we may share your information with One Account Mobile Limited (1account), and third-party providers of identity data to 1account. This is necessary for 1account to verify that you meet the minimum age and identity verification requirements as determined by relevant UK age restriction legislation.  1account may retain relevant data for the purpose of future verification.  All data processed by 1account is subject to appropriate security measures.  Data retained by 1account is subject to periodic review to ensure it is not held for longer than necessary.  You can find information about how 1account manages your personal data and view their privacy policy by visiting their website: 1account.net.

2.1.3 Recipients of the personal data

We may also transmit your personal information with companies that help us to run our business by processing personal information on behalf of us for the purposes identified above. Such companies include server services providers, data analysis services providers, fraud monitoring and prevention providers, email delivery service providers, social media, and other marketing platforms and service providers.
In addition, Neafs may disclose the User’s personal data:
– if Neafs is under a duty to disclose or share such personal data in order to comply with any legal obligation, or in order to protect the rights, property or safety of its business, its customers or others;

2.1.4 Transfer of personal data

The collected personal data may be transferred by Neafs to recipients which are located outside the European Union and such destinations may not have laws which protect the User’s personal data to the same extent as in the European Union.

Neafs ensures that the User’s personal data processed by Neafs or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.

Please find below the relevant information on transfer:

– Neafs may transfer the collected information to providers of third party email delivery service to send promotion emails, or to other marketing platforms and service providers to complete relevant service;
– Neafs may use third party track tools (such as Adwords, Bing, bugsplat, Criteo, disqus, fabric, Facebook, FireBase, Flurry, Google Analytics, Hotjar, LinkedIn, Pardot, Quora, JPUSH) to track the information on how users use the products and websites, such information will be stored in third party servers. Such third party track tools may send the data analysis report to Neafs for Neafs’s above mentioned purpose;
– Neafs may store the collected information on the servers leased from providers of third party server service.

2.1.5 Duration of the storage

Neafs will store the collected personal data for the duration of the contract and 60 days after the termination of the contract. Beyond this duration, in order for Neafs to be able to demonstrate the existence of a right or a contract or a legal obligation, the relevant personal data will be stored through intermediary archives for a duration that will not exceed what is strictly necessary regarding the purpose of the storage and in accordance with the applicable legislation.

2.2 Processing of personal data related to comments areas

When the User decides to comment a Neafs product through the Website, Neafs implements a processing of personal data as follows:

2.2.1 Personal data collected

Regarding this processing, Neafs collects the following personal data:

– Email address;
– Name or nickname;
– profile photo;
– Other potential personal information provided by the User through its comment (age, location, etc.);
– The content of your comment.

2.2.2 Purpose and legal basis of the processing

This processing is implemented by Neafs in order to improve its products and provide the consumers and potential consumers with a better and transparent information about the Neafs products. Said comments and the related personal data are provided by the User on a voluntary basis so that the processing of the collected personal data relies on the User’s consent.
Neafs may use the comments (with your relevant information) you post for marketing purpose in order for others to better understand and use our products.

2.2.3 Recipients of the personal data

Neafs may transmit the collected personal data to third party email delivery service providers, social medias, other marketing platforms and service providers .

2.2.4 Transfer of personal data

The collected personal data are transferred by Neafs to recipients which are located outside the European Union and such destinations may not have laws which protect the User’s personal data to the same extent as in the European Union.

Neafs ensures that the User’s personal data processed by Neafs or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.

Please find below the relevant information on transfer:

– Neafs may transfer the collected information to providers of third party email delivery service to send promotion emails, to other marketing platforms and service providers to complete relevant service.
– Neafs may store the collected information on the servers leased from providers of third party server service.

2.2.5 Duration of the storage

Neafs will store the collected personal data for not more than 5 years after the collection.

2.3 Processing of personal data related to newsletters and advertising emails

The User may want to subscribe to Neafs’s newsletter in order to be provided with information and news regarding Neafs products. In this case, Neafs implements a processing of personal data as follows:

2.3.1 Personal data collected

Regarding this processing, Neafs only collects your provided information such as the User’s email address, name or nickname, country, preferred product, and your operation to the promotion emails.

2.3.2 Purpose and legal basis of the processing

Neafs implements the processing of personal data in order to provide consumers and potential consumers with information and news regarding Neafs products.
The subscription to Neafs’s newsletter and the related provision of personal data is made on a voluntary basis so that the processing of the collected personal data relies on the User’s consent.

2.3.3 Recipients of the personal data

Neafs may transmit the collected personal data to providers of email delivery service and other service providers such as data analysis providers and server providers.

2.3.4 Transfer of personal data

The collected personal data are transferred by Neafs to recipients which are located outside the European Union and such destinations may not have laws which protect the User’s personal data to the same extent as in the European Union.

Neafs ensures that the User’s personal data processed by Neafs or by its suppliers and partners operating outside the European Union are treated securely and are protected against unauthorized access, loss or destruction, unlawful processing and any processing which is inconsistent with the purposes set out in this privacy policy.

Please find below the relevant information on transfer:

– Neafs may transfer the collected information to providers of email delivery service providers to send newsletters or promotion emails.
– Neafs may store the collected information on the servers leased from providers of server service.
– Neafs may use third party track tools(such as Google Analytics) to track the information on the user’s operation to the advertising emails, such information will be stored in third party servers. Such third party track tools may send the data analysis report to Neafs for Neafs’s above mentioned purpose.

2.3.5 Duration of the storage

Neafs will store the collected personal data for 3 years from their collection or from the last contact from the User (whichever is later).
At the end of this 3 years time period, Neafs may contact the User in order to know if the User wishes to keep receiving commercial information from Neafs. In case Neafs would not receive any positive and explicit answer from the User, the personal data would be deleted or archived in accordance with the applicable legislation.

2.4 Cookies and trackers

When the User consults the Website, Neafs implements cookies and other trackers on the User’s device.

Cookies are small pieces of data that are downloaded to the User’s computer or mobile device when the User visits Neafs’s Website.

When the User consults the Website, Neafs implements cookies in order to better understand what services are valuable to our customers and to improve the Website. Cookies let the web page server know that User has returned to this site. Cookies also can determine other information, such as the daily visitors to our website and the pages of the site most frequently visited. Cookies are unique and can only be read by the server that assigns them. They cannot be executed as code or deliver viruses.

Users have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of our website.

You can review your cookie consents on our Cookie Policy page.

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