Neople B.V. and all its affiliated companies (“Neople”, “we”, “us ” or “our”) takes careful handling of your (“User” or “you”) personal data very seriously. As a data processor for the processing of your personal data, we ensure that your personal data is handled and protected with the utmost care. Neople complies with applicable laws and regulations, of which the General Data Protection Regulation (GDPR) is the most important.Please read this privacy statement (“Privacy Statement”) before you use the Neople services (“Services”) consisting of: the website neople.io (“Website”) and the plugin(s) installed in your work environment that facilitate conversations with a Neople (“Plugin”, “a Neople”, “your Neople”) (Website and Plugin together “Platform”). By using the Services through the organization you work for (“Contractor”) you agree to the contents of this Privacy Statement.  Through this Privacy Statement, you are provided an insight into the data we collect, why we collect this data and what we do with this data.

1. The data Neople processes, on which grounds and for which purposes
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To provide the Services and allow you to have conversations with your Neople, we process personal data on the grounds and for the purposes as set out below.
A. Grounds
‍Neople acts as a data processor, while the Contractor acts as data controller. We have made a data processing agreement between Neople and the Contractor. Therefore, we rely on the legal grounds that the Contractor has determined for the personal data we process.
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B. The data we process, and the purposes for processing
We process the following data to provide the Services. If you do not wish to provide (some of) this information, you will not be able to use (part of) the Services.

B1. Purpose: creating a user account.
In order to set up conversations between you and a Neople in a messaging channel of your choice, we process the following personal data. Whether or not certain data types are processed depends on the messaging channel used. Conversations may be initiated by you, or by a Neople.
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Name
E-mail address (for some messaging channels)
Messaging IDs (for some messaging channels)
Phone number (for some messaging channels)

B2. Purpose: facilitating conversation with a Neople.
In order to understand your questions and requests, and to provide a helpful reply, we process the following personal data.

Any personal data provided by you in a message to a Neople
Any personal data present in internal documents provided by Contractor, which are required to provide the reply
Any personal data gathered from integrated systems, which are required to provide the reply.

B3. Purpose: training your Neople.
In order to evaluate the performance of your Neople and to train it to provide better replies, we use the data mentioned in B2.

B4. Purpose: monitoring & analysis.
We use personal data to monitor the availability and security of the Platform, to prevent fraud, to analyze how Users use the Platform, and to detect and correct bugs in the Platform. For this purpose we process the personal data mentioned in 1. and 2., and IP address.

B5. Purpose: compliance with legislation.
Neople may be required to process personal data for purposes other than those set out in this Privacy Statement in order to comply with the applicable local legislation, for example for law enforcement and in case of a court order. Neople will contact Contractor regarding these requests according to the data processing agreement.B6. Purpose: customer service.
Depending on your question, we may use personal data mentioned in this section to provide customer service.

2. Retention period of personal data  
We retain personal data in accordance with the data processing agreement between Neople and the Contractor, and in any case no longer than is permitted under applicable law. During the contract term between Neople and the Contractor, personal data will be retained to provide the Services. After the cancellation of the agreement with the Contractor, personal data will be returned or deleted within a period of 30 days. This period is required for fraud prevention and abuse detection, and to ensure that the full deletion and/or anonymization process has been completed. If you have any questions about the retention period of your personal data, please contact us.

Please note that Neople can keep collected data in an aggregated and anonymous form for (market) research, analysis and/or fraud protection, as long as it is guaranteed that the data cannot be traced back to a natural person anymore.
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3. Subprocessors and data residency
To provide the Services to you, we have engaged service providers who operate parts of the Platform. If those service providers process personal data under our agreement with them, they are listed as subprocessors and we have concluded a data processing agreement with them.  

Our services are mainly managed and operated from the European Economic Area (EEA). If, however, personal data is provided to a third party outside of the EEA, this will only be done to a third party in a country which, according to the European Commission, provides a level of protection that is appropriate for personal data. If this level of protection is not adequate, Neople shall ensure that the legally required safeguards are made, such as the EU Standard Contractual Clauses.  

At the time of writing this Privacy Statement, your personal data will only be transferred outside of the EEA in the context of the services provided by OpenAI OpCo LLC, Cohere Inc and Anthropic PBC. All three subprocessors are located in the United States of America and are SOC 2 compliant. We have signed a data processing agreement with them, and they all adhere to the Standard Contractual Clauses and conditions as set by the European Commission.

If you would like to receive further information about the transfer of your personal data abroad, please contact us. By using our Services, or otherwise providing information to us, you agree to the transfer of your personal data to countries outside the Netherlands.  

4. Use of cookies
Neople uses cookies on the Website. By clicking "Ok" on the cookie notification of our Website, you consent to the storage of cookies. A cookie is a small file that a website stores on your hard disk via the browser. Information is stored in a cookie. Different types of cookies can be used per visit. Below, you find more information about the cookies used by and via the Website and for what purposes.

5. What type of cookies are used on the Website and for what purpose
The Website makes use of the different types of cookies listed below and for the purposes listed below:

Analytical cookies: these cookies are anonymous and allow Neople to improve the Website. These cookies collect information about the way visitors use the Website, such as information about the most frequently visited pages or the number of displayed error messages. The information collected by these cookies may not be used for marketing purposes and will not be passed on to third parties.

Session cookies: session cookies are used during your visit and are automatically deleted when you close the browser. Through these cookies we can remember which parts of our Website you viewed during a visit and we coordinate our Services accordingly.

Social media cookies: these are cookies to share the content of our Website via social media. For the functioning of these buttons social media cookies are used from the social media parties, so that they recognize you when you want to share a page of the Website. For the cookies that the social media parties place and the possible data they collect, we refer to the statements that these parties provide on their own websites.

Tracking cookies: with your consent, Neople or a third party uses tracking cookies to track your visit to the Website and possibly other websites in order to build a profile of you. These cookies may be used to show ads tailored to your preferences.

Other/unforeseen cookies: due to the way internet and websites work, Neople may not always have insight into the cookies that third parties place via our Website. This is especially the case when our web pages contain so-called 'embedded elements' (these are texts, documents, images or films that are stored with another party, but which are displayed on, in or via our Website).

6. Customize cookie settings or delete cookies
If you don't want Neople to place cookies on your (mobile) device, you can refuse the use of cookies through the settings or options of your browser. For each browser and each (mobile) device, you have to adjust your settings separately. It is possible that after modification of the cookie settings, some parts of the Website can no longer be (correctly) used. When Neople has placed cookies, you can also delete them. How to do this differs per browser. If necessary, consult the help function of your browser. More information about cookies can be found on the following website http://www.youronlinechoices.eu/.We ask you kindly to notify us in case you find a cookie used on the Website that is not mentioned above.

7. Security
We try to do everything we can to protect your personal data. Neople uses technical and organizational security measures to protect the personal data managed by Neople against manipulation, loss, destruction and unauthorized access. These safety measures are constantly being improved in line with technological developments. For example, all communication from and to the Platform is TLS protected. Furthermore, the Platform is continuously updated with the latest security updates. The Platform may contain links to external websites that are managed by other companies. It is possible that they collect personal information from people who visit their website. Neople cannot offer any guarantees regarding the privacy policy of external websites and is not responsible for those websites.

8. Your rights
You have the right of inspection, correction or deletion of your personal data at any time. For any of these actions please contact us via the contact details as described below. We would like to point out that, on the basis of the European privacy laws, you have the following rights:  
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to get an explanation of what personal data of you we have and what we do with it;
access to the exact personal data of you that we have; correcting erroneous data;
the removal of obsolete personal data;
withdrawal of consent;
and  object to a particular use of your personal data.

If, despite our efforts to ensure the accuracy of personal data, incorrect information is still stored, we will correct it at your request.
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9. Complaints  
Please feel free to contact us in case of complaints about our processing of your personal data. In case of a complaint, we ask you to contact us via the contact details as described below. Under the European privacy legislation you also have the right to file a complaint directly with the Dutch Authority for the Protection of Personal Data (In Dutch: Autoritieit Persoonsgegevens) about the way we process personal data.

10. Revisions
Neople reserves the right to change this Privacy Policy. However, we do not limit your rights under this Privacy Statement without your express consent. You can find the most up-to-date version of this Privacy Policy at any time on the Platform. We recommend that before using our Services you check whether an updated version is available.
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11. Contact details
In case of any questions about this Privacy Policy or our processing of your personal data, you can contact us via the contact details as described below. You can also contact the information security officer of our organization directly via the contact details as described below.
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Neople B.V.
High Tech Campus
275656 AE Eindhoven
The Netherlands
Chamber of Commerce number: 88911705
Website: neople.io
‍E-mail: neople.io/contact-us

12. Information security officer
You can reach our information security officer by e-mail: privacy@neople.io.  

13. Version
This Privacy Policy was last amended on November 28th, 2023.