Privacy Policy

Neuwly Inc. ('Neuwly', 'we', 'us', 'our') is committed to protecting and respecting your personal data privacy and complying with data protection principles and provisions under applicable laws.

We may collect, process, use and disclose your information when you use this website www.neuwly.com and/or the Neuwly App (collectively referred to as the “Neuwly Platform”) and the services offered by Neuwly or the third party operators (the “Operators”) through Neuwly Platform (the “Services”) as described in this Privacy Policy. 'You' and 'your' when used in this Privacy Policy includes any person who accesses Neuwly Platform or use the Services.

This Privacy Policy sets out the basis and terms upon which Neuwly collects, processes, uses and/or discloses your information that is obtained from you when you access Neuwly Platform and/or use the Services. Such information may include personal information relating to or linked to a specific individual such as name, residential address, telephone number, email address, travel document information or any such information we have requested and you have provided through Neuwly Platform ('Personal Information').

Please read this Privacy Policy carefully. By visiting Neuwly Platform, you are consenting to the collection, processing, usage and disclosure of your Personal Information as set out in this Privacy Policy.

Scope of Terms

Neuwly reserves the right to update, amend or modify the terms of this Privacy Policy or any part of it without prior notice, and your continued access of Neuwly Platform or use of the Services signifies your acceptance of the updated, amended or modified Privacy Policy, unless if the changes reduce your rights in which case we will ask for your consent. If you do not agree to all the terms and conditions in this Privacy Policy and/or any subsequent updates, amendments or modifications thereto, you must stop accessing or otherwise using Neuwly Platform and the Services.

Accordingly, please visit this page if you wish to access and view the current version of this Privacy Policy.

Collection of Information

We may collect Personal Information about you that you provide to us while using Neuwly Platform and information about how you use Neuwly Platform including when you open your user account ('User Account'), visit Neuwly Platform or make booking for any intended Services or using the Services. Providing your Personal Information to Neuwly is always on a voluntary basis. However, we might not be able to provide you with certain services if you choose not to give us your Personal Information. For example, we cannot open your user account or make booking for you if we do not collect your name and contact details.

The following are a list of areas that we will collect your information:

1) Opening Your User Account

When you open with us a User Account or amend any information of your User Account, we may collect your Personal Information, such as your name, email address, username, password and telephone number.

2) Visit Neuwly Platform, Making Booking for the Services or Using the Services: 

(a) When you visit the Neuwly Platform (even you have not registered an User Account or logged in) or make a booking for any intended Services or use the Services, we may collect and process certain information (which may contain your Personal Information or may contain non-personally identifiable information but nevertheless linked to your Personal Information) including but not limited to those set out below: Copies of correspondence (whether by e-mail, instant or personal messaging or otherwise) between you and us, and between you and the Operators; 

(b) Details of your usage of Neuwly Platform (including traffic data, location data and length of user sessions); 

(c) Feedback on and responses to surveys conducted by Neuwly relating to the Services and newsletters which may be published, circulated or distributed by Neuwly; 

(d) Information automatically collected and stored in our server or the server of our third party services provider by using or accessing to the Neuwly Platform (including the log-in name and password for your User Account, your computers Internet Protocol (IP) address, browser type, browser information, device information (including unique device identifier), pages visited, previous or subsequent sites visited).

3) When you use your mobile devices to visit the Neuwly Platform, we may collect information about you and your mobile device as stated above. This can include location information if you have consented and configured your mobile device to send us such information or upload photos with location information to the Neuwly Platform. Such location information will be used in the ways and for the purposes as stated in this Privacy Policy. For example, we may use your location to suggest nearby Services during your travel or provide personalized content. You can change your mobile device’s privacy settings at any time to deactivate the function of sharing location information. Please note some features of the Neuwly Platform may be affected if you turn off such location sharing function. Should you have any enquiries about your mobile devices’ privacy settings, we recommend you contact your mobile services provider or the manufacturer of your device.

4) If you make booking for other individuals through the Neuwly Platform, we may request personal information about such individuals. You must obtain all requisite consent of such individuals and ensure they are aware of, understand and accept this Privacy Policy prior to providing their personal data to Neuwly.

Storage of Information

The Personal Information and other data we collect from you may be transferred to, processed, and stored in our servers or the servers of our third party services providers. Your Personal Information will be stored as long as is necessary to fulfil any of the purposes described in this Privacy Policy, or to comply with any (i) contractual requirement that are necessary for the provision of the Services, and (ii) legal, tax or accounting requirement.

When it is no longer necessary for us to process your Personal Information, we will either delete or make the data anonymous, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information.

Neuwly will endeavour to make anonymous or aggregate your data if we intend to use it for analytical purposes or trend analysis.

Neuwly will use reasonable endeavours to maintain appropriate physical, electronic and organizational procedures to ensure that your Personal Information and other data is treated securely and in accordance with this Privacy Policy, and to protect such data against unauthorized access or unauthorized alteration, disclosure or destruction of data.

Once Neuwly has received your information, Neuwly will use strict procedures and security features to try to prevent unauthorized access. Neuwly does not give any representation, warranty or undertaking that the Personal Information you provide to us will be secure at all times, and to the extent Neuwly has fulfilled its obligations under no circumstances shall Neuwly be responsible for any losses, damages, costs and expenses which you may suffer or incur arising from unauthorized access to or use of your Personal Information.

All payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using online encryption technology. You are responsible for keeping your chosen password confidential and not to share your password with any third party.

Usage of Information

Neuwly will process the Personal Information collected in as far as necessary for performance of the contract with and providing services to you. For example, Neuwly will use Personal Information and other data collected through the Neuwly Platform or when making purchases for the Services to create your User Account, to provide you with the Services, to continually improve the Neuwly Platform and the Services, and to contact you in relation to the Services. This includes using your Personal Information or such other data to achieve faster purchase requests, better customer support and to provide you with timely notice of new Services and special offers.

From time to time, Neuwly may also make use of your Personal Information to contact you for feedback on your use of Neuwly Platform, to assist us in improving the Neuwly Platform, or to offer special savings or promotions to you, where you have indicated your consent to receiving such communications. If you would prefer not to receive notices of special savings or promotions, you may simply opt-out from receiving them by replying to us through the email address provided in these notices. 

Disclosure of Information

We may from time to time share and disclose your Personal Information and other data to third parties, some of whom may be located outside your home country. The circumstances under which such sharing and disclosure will take place may include without limitation, the following:

1) To successfully complete your booking or otherwise implement our Terms of Use. We may share your information with Operators or third parties who deliver or provide goods and services or otherwise act on our behalf.

2) If you are a visitor, to the relevant Operator in connection with a Services which you have made booking for or intend to make booking for.

3) If you are an Operator, to any visitor in connection with the Services you are offering.

4) To our third party service providers, which we engage amongst others for the performance of certain services on our behalf, such as web hosting services, data analysis, marketing, market research, and to otherwise provide you with customer service.

5) If and to the extent required by any applicable law, order of court or requests by any governmental authority to make such disclosure.

6) Within the Neuwly group of companies. In case of a corporate transaction, in connection with the sale, merger, acquisition, or other corporate reorganization or restructuring of our corporation, your Personal Information may be disclosed, shared or transferred to the new controlling entity or its authorized third party for carrying on our business.

7) To our advisors, agencies or other parties concerned in order to protect the rights and property of Neuwly.

8) In any other case, to any third parties with your prior written consent (and in which case we will make it possible for you to withdraw your consent as easily as it was to provide consent). 

We may also share aggregate or anonymous information with relevant third parties, including our advertisers. Such information does not contain any Personal Information and will not identify you personally. However, in some occasions, these third parties may possess information about you or obtain your information from other sources. When they combine such information with our aggregate information, they may be able to identify you personally.

Your Personal Information may be transferred outside of your home country for the above mentioned purposes. If such transfer takes place to a country that does not provide an adequate level of protection, Neuwly will use reasonable endeavours to ensure that appropriate safeguards are in place. 

There may be links present on the Neuwly Platform, which could result in you leaving the Neuwly Platform and/or being taken to other third party websites. You should note that any Personal Information that you provide to these third party websites are not subject to this Privacy Policy, and Neuwly is not liable for any losses, damages, costs or expenses which you may suffer or incur in connection with you providing or making available Personal Information or other data to such third party websites.

Cookies

Cookies are widely used in order to make websites work, or work more efficiently. When you visit our Website, we collect some of your Personal Information transmitted to us by your browser via cookies. This enables you to access the Neuwly Platform and helps us to create better user experience for you. 

Your rights

You may at all times access, correct or erase your Personal Information through the Neuwly Platform. Alternatively, you may make your data access, correction or erasure request by sending your request by email at hello@neuwly.com.

Where mandatory under applicable legislation, you may also request restriction of processing of your Personal Information or object to processing by sending your request or objection by email at hello@neuwly.com. You may also request a copy of the information that we hold about you by sending your request by email at hello@neuwly.com.

Please contact us via the contact details mentioned below if you have a complaint regarding the processing of your Personal Information.

When handling any of these requests described above, Neuwly has the right to check the identity of the requester to ensure that he/she is the person entitled to make the request.

Enquiries

If you have any questions about this Privacy Policy, please contact Neuwly by email at hello@neuwly.com.