NetX Privacy Policy

Introduction

Netxposure LLC., doing business as NetX (collectively referred to herein as “NetX”, “we”, “our” or “us”), recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our web sites. This Privacy Policy applies to data collection by NetX and shall apply to your use of the website, www.NetX.net and other NetX-related sites, applications, software, communications, capabilities and services (“Services”) accessible on or by any top-level NetX domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy.

Our Privacy Policy explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; (5) the choices we offer, including how to access and update information; (6) and the measures we take to keep your information safe. Specifically, our Privacy Policy covers the following topics:

1. When This Privacy Policy Applies
2. Terms of Service
3. Information We Collect
4. Information Collected Related to California Residents
5. How We Use Information We Collect
6.  Sale of Personal Information
7.   Our Legal Basis for Collecting Personal Data
8.   Information We Share
9.   Your Failure to Provide Personal Data
10. Our Retention of Your Personal Data
11. Your Rights and Choices
12. Our Opt-in/Opt-out Policy
13. Your Ad Choices
14. Third Party Links
15. International Transfer
16. How We Protect Personal Data
17. Children
18. Direct Marketing and “Do Not Track” Signals
19. NetX Partners
20. Changes to this Privacy Policy
21. How to Contact Us

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.

If you have any questions or comments about this Privacy Policy, please submit a request to DPO@netx.net or visit the Customer Support System located HTTPS://support.netx.net.

When this Privacy Policy Applies

Our Privacy Policy applies to all of the Services offered by NetX and its affiliates, including some NetX partners, and Services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Terms of Service

By accessing or using the Sites in any manner, you also agree to be bound by NetX Terms of Service (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

Information We Collect

We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.  

When you use our Services, we collect Personal Data in the following ways:

1. Information You Give to Us

As you evaluate whether NetX is the right solution for your company, you may choose to provide us with Personal Data about yourself, including your name, company name, phone number, billing address, shipping address, payment card information, job title, industry, country of residence, and email address by completing forms on our website, such as when you request to schedule a demo. You may also choose to provide us with employment and education information when you apply for a job at NetX via our Site.

In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our services.

The Sites offer interactive and social features that permit you to submit content and communicate with us. You may provide Personal Data to us when you post information in these interactive and social features. Please note that your postings in some areas of the Sites may be publicly accessible or accessible to other Users.

2. Information We Obtain from Your Use of Our Services

We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited.  We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

3. Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third-party advertising and analytics partners include Google Analytics, Facebook Ads and similar partners.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services.  For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy.

Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

Information Collected Related to California Residents

During the last twelve (12) months, we have collected the following categories of personal information from consumers.

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from our customers or their agents. For example, from information that customers input into our mobile app.
• Indirectly from our customers or their agents. For example, through information we collect from our clients in the course of providing Services to them.
• Directly and indirectly from activity on our website (www.NetX.com). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
• From social media websites, such as Facebook, Twitter, and LinkedIn.
• From third parties that assist us in providing certain transactions and services (e.g. payment processing, hosting), even though it appears that you may not have left our Site.

How We Use Information We Collect

We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

1. To present, operate or improve the Site and Services, including analysis of Site activity;
2. To inform you about Services and products available from NetX;
3. To authorize access to our Sites and Services;
4. To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
5. To offer and administer programs;
6. To customize or tailor your experience of the Services;
7. To administer content, promotion, sweepstakes, surveys, voting polls or other Site features;
8. To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
9. To send you marketing information and other non-transactional communications via email, telephone calls, SMS, or push notifications about us as necessary for our legitimate interest in conducting director marketing or to the extent that you have provided prior consent;
10. With your consent as required by applicable law, we may send marketing and/or service-related text messages to your mobile device. You may opt out of receiving these messages by following the prompt in an individual message or updating your "Notifications" preferences under the website settings or the mobile application settings that control push notifications.
11. To improve our Site and Services;
12. To secure our Services, including to authenticate Users;
13. To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
14. To respond to and support Users regarding their use of the Sites and Services;
15. To comply with all applicable legal requirements;
16. To enforce our Terms of Use and other agreements;
17. To perform data analysis and testing;
18. To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users;
19. To resolve disputes;
20. To otherwise fulfill the purpose for which the information was provided.

We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.

We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. We may use your Personal Data to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it.  We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Sale of Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information.

Our Legal Basis for Collecting Personal Data

Whenever we collect Personal Data from you, we may do so on the following legal bases:

1. Your consent to such collection and use;
2. Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
3. Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
• Intra-organization transfers for administrative purposes;
• Product development and enhancement, where the processing enables NetX to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
• Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
• Fraud detection and prevention;
• Enhancement of our cybersecurity, including improving the security of our network and information systems; and
• General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Information We Share

We do not share personal data with companies, organizations and individuals outside of NetX unless one of the following circumstances applies:

• With your consent. We will share Personal Data with companies, organizations or individuals outside of NetX when we have your consent to do so.
• Business Accounts. Your employer or your organization may offer you access to our Services. We will share Personal Data with your employer or organization. Your employer or organization can review and manage your use of such Services.  
• For external processing. We provide personal information to our affiliates or other trusted businesses or partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures. These third parties include marketing partners, third party hosted services providers, and similar partners. It is our policy to only share Personal Data with contractors, service providers and other third parties who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.  Under certain circumstances, you may avoid having us share your information with our business partners and vendors by not granting us permission to share your information.  Not granting us permission to share your information with our business partners or vendors may limit your access to their services through the Sites.
• For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of NetX if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
• meet any applicable law, regulation, legal process or enforceable governmental request.
• enforce applicable Terms of Use, including investigation of potential violations.
• detect, prevent, or otherwise address fraud, security or technical issues.
• protect against harm to the rights, property or safety of NetX, our Users or the public as required or permitted by law.

We attempt to notify Users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

• Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our Users is often a transferred business asset.  In the event that NetX itself or substantially all of our assets are acquired, Personal Data about our Users may be one of the transferred assets.
• Non-Personal and Aggregate Site Use Information. NetX may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”).  We may disclose such de-identified information publicly and to third parties, or to NetX Partners under agreement with us.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

• Identifiers;
• California Customer Records Personal Information categories;
• Protected classification characteristics under California or federal law;
• Commercial information;
• Internet or other network activity information;
• Professional or employment-related information;
• Inferences drawn from other personal information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

• Our affiliates;
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the Services we provide to you.
• Service providers and other third parties we use to support our business, including without limitation those performing core services (such as credit card processing, customer support services, customer relationship management, accounting, auditing, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services.
• Commercial providers;
• Enterprise accounts, such as your employer.

We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of NetX if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Fufill any purpose for which you provide it;
• Meet any applicable law, regulation, legal process or enforceable governmental request;
• Enforce applicable Terms of Use, including investigation of potential violations;
• Detect, prevent, or otherwise address fraud, security or technical issues;
• Protect against harm to the rights, property, assets or safety of NetX, our customers or the public,  content found on the Services, or to protect the Services from unauthorized use or misuse, as required or permitted by law;
• Facilitate a business transfer, such as to a buyer or other successor in the event of merger, acquisition, consolidation, divestiture, change in control, dissolution or other sale or transfer of some or all of NetX's assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by NetX about its customers and users will be among the assets to be transferred, and any such successor may use your information for the same purposes set forth in the Privacy Policy.
• For any other purpose disclosed when you provide the information; and,
• When we obtain your consent to do so.

We attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

Your Failure to Provide Personal Data

Your provision of Personal Data is required in order to use certain parts of our services and our programs.  If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.  

Our Retention of Your Personal Data

We may retain your Personal Data for a period of time consistent with the original purpose for collection.  For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

We retain your Personal Data even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us.

Your Privacy Rights and Choices

You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

Privacy Rights Specific to Californians

Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.

Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.

• Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  
• Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us.  Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
• Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
• Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.

Exercising Your Rights

If you are a California resident who chooses to exercise your rights, you can:

1. Submit a request via email to DPO@netx.net or
2. https://support.netx.net

You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.

Our Response to Your Request

Upon receiving your request, we will confirm receipt of your request by [sending you an email/confirming receipt via our online portal/sending a message to your online account]. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing.  If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
3. Debug products to identify and repair errors that impair existing intended functionality;
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
8. Comply with a legal obligation; or
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Privacy Rights Specific to European Union Residents

Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), corresponding legislation in Switzerland and in the United Kingdom, and some U.S. state laws, provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:

1. The right to be informed. You are entitled to be informed of the use of your Personal Data.  This Privacy Policy provides such information to you.
2. The right of access. You have the right to request a copy of your Personal Data which we hold about you.
3. The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.  
4. The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data.  Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
5. The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data at any time.  
6. The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us.  Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
7. The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
8. The right to lodge a complaint with a supervisory authority.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.  

If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. To make these requests, you may contact us using the contact information below, and we will consider your request in accordance with applicable laws. For your protection, we may need to verify your identity before responding to your request. We may respond to your request by letter, email, telephone or any other suitable method. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

Our Opt-in/Opt-out Policy

By providing an email address on the NetX Sites or Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service-related notices, or to provide you with information about our events, invitations, or related educational information.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a User to submit or receive information, as the case may be.

We currently provide the following opt-out opportunities:

1. At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a NetX Partner to unsubscribe from the service.    

2. At any time, you can contact us through privacy@NetX.com or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Data.

3. At any time, you can reply “STOP” to the message in order to opt-out of receiving SMS texts.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service-related notices.

Your Ad Choices

As described above, we or third-party partners may place or recognize a unique cookie on your browser when you visit our Sites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service. NetX is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.

The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not NetX. NetX does not control or operate these tools or the choices that advertisers and others provide through these tools.

Third Party Links

The Sites may contain links to webpages operated by parties other than NetX. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party's website. NetX strongly recommends that each User review the third party's terms and policies.

International Transfer

We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.  

Personal Data and any additional information submitted may be used globally in connection with employment, business processes within NetX, or communicating with our NetX Partners. Therefore, Personal Data may be transferred to such entities worldwide, where it will be processed in accordance with this Privacy Policy and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.  

How We Protect Personal Data

NetX maintains administrative, technical and physical safeguards designed to protect the User's Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we restrict access to personal information to NetX employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.  

If NetX collects account information for payment or credit, NetX will use the information only to complete the task for which the account information was offered.

Children

The Site is not intended for use by children.  We do not intentionally gather Personal Data about visitors who are under the age of 16.  If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us at privacy@NetX.com.  If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.  

Direct Marketing and “Do Not Track” Signals

The NetX website does respond to Do Not Track (DNT) signals. 

California residents are entitled to contact us to request information about whether we have disclosed Personal Data to third parties for the third parties’ direct marketing purposes. Under the California “Shine the Light” law, California residents may opt-out of our disclosure of Personal Data to third parties for their direct marketing purposes. You may choose to opt-out of the sharing of your Personal Data with third parties for marketing purposes at any time by submitting a request to DPO@netx.net. California users may request further information about our compliance with this law by contacting us at dpo@netx.net or by writing to us at the address listed in the “How to Contact Us” section.

NetX Partners

NetX’ business customers (“NetX Customers”) engage us to deliver Services to their employees, customers and other users. Customer Information, Information about our Customer’s Contacts and Archival Information (each defined below) are governed by this Privacy Policy, the NetX Terms of Use and any other services agreements between NetX and the applicable Customer.

1. NetX Customer Information. We collect information about individuals within our NetX Customer organization (“Customer Information”). Customer Information may include information related to the Customer’s account, name, work e-mail address, work phone number, job title or similar kinds of information. We use Customer Information to support the Customer account, maintain our business relationship with the Customer, respond to Customer inquiries, or perform accounting functions. NetX Customers may update personal information and password by logging into the NetX Platform and updating their account. NetX Customer may contact NetX support in order to delete their Personal Data. In some cases, we may not be able to delete Customer Information, and in such cases we will tell you why.

2. Information about our Customers’ Contacts. We collect information about any contacts, such as employees, customers, and others, that may be uploaded into the NetX Platform (“Information about our Customers’ Contacts”). Information about our Customer’s Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use Information about our Customer’s Contacts for the purposes of providing enhanced Services to our Customers. NetX Customers may update or delete Information about their contacts in the NetX Platform. NetX Customer may also contact NetX support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases we will tell you why.

3. Archival Information. We collect communications information for archival purposes on behalf of, and as directed by, our NetX Customer. This information may include emails, texts, websites, social media messages or posts, and other forms of data or electronic communications (“Archival Information”). Archival Information includes data about our NetX Customer and the third parties they correspond with. We do not control or monitor the information our NetX Customer collect and store through our services, or their privacy practices or policies. It is our Customer’s obligation to obtain all necessary consents and to comply with all applicable laws with respect to the Customer’s communications and use of our services. Our Customer’s privacy policies or practices apply to Archival Information, the purposes for which the Customer collects Archival Information, how the Customer may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Customer in order to correct, amend, or delete their information, or to opt out of any collection, uses or disclosure of their information by our Customer.

We treat Customer Information, Information about our Customer’s Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our NetX Customer, subject to the terms of the NetX Terms of Use and any other service agreement between NetX and the Customer. We do not share Customer Information, Information about our Customer’s Contacts, Archival Information or Automatically Collected Information with third parties unless directed to do so by our Customer, as may be necessary to provide services to the Customer, to our advisors, affiliates, representatives, agents, service providers, in connection with a business transaction (such as a merger or sale), as allowed under the terms of our agreement with our Customer, or in response to a court order, subpoena, warrant or to comply with a legal requirement or to cooperate with an investigation. We may disclose Customer Information, Information about our Customer’s Contacts, Archival Information or Automatically Collected Information for the aforementioned reasons, or in order to protect our rights or the rights of our affiliates, NetX Customers, channel partners or service providers.

We will retain Customer Information we process on behalf of our NetX Customers for as long as needed to provide services to our Customer, or for the period of time requested by a particular Customer.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

Revisions:

How to Contact Us

If you have any specific questions about this Privacy Policy, you can contact us via email or phone or by writing to us at the address below:

Send e-mail to:
DPO@netx.net

Send mail to our address:
310 SW 4th Ave, Suite 1120
Portland, OR 97204