This Privacy Policy applies to Individuals, anywhere in the world, who interact with us or who use Neeve Products or Services.

This Privacy Policy covers our privacy and information practices and applies to our websites, mobile apps, applications, physical facilities, and related services (our “Products and Services”). Please remember that our Terms of Use may also govern your use of our Products and Services.

Neeve may process the Personal Data of customers, partners, vendors, employees, applicants, visitors, or other individuals who are affiliated or seeking an affiliation with Neeve or our Products and Services (“Individuals”). This Privacy Policy applies to these Individuals regardless of their geographic location during their interactions with Neeve.

The Products and Services that Neeve offers use lots of gathered and integrated data to improve the operations of buildings for building managers and to transform the occupant experience for tenants and guests. We gather data through our devices and systems, and through user inputs, to optimize the experiences in these buildings and their operations. Some of the data may include Personal Data.

Neeve offers an integrated platform for smart buildings using edge security, remote access, as well as AI-enabled data processing, analytics, and automation  products to enhance user health and experience, energy savings, and operational efficiency in buildings. Through its core brand “Neeve” and sub-brands “Worxwell” and “Iotium” provides multiple Products and Services including provides a data analytics platform that aggregates all building data (e.g., occupancy, space usage, digital collaboration and work patterns, access control, air quality, temperature, and environmental factors) into a consolidated dashboard for both building owners and occupiers. Neeve’s Products and Services include mobile apps and other tools that allow building managers and tenants to understand more about compliance and operations (e.g., employee health and safety, security, space utilization, hybrid work analyses, employee experience and engagement, and ESG optimization). Neeve also offers an easy-to-deploy secure, cloud-managed, software-defined IoT network solution which enables building owners to quickly achieve enterprise-grade security, reduce operating costs, and gain real-time visibility into single buildings to entire real estate portfolios.

Neeve allows you to exercise your privacy rights and manage how we use your information.

Privacy and data laws may vary in different countries and regions around the world and give Individuals certain rights in relation to their Personal Data. We conduct our privacy practices according to this Privacy Policy and the relevant laws of the United States and the State of California, where our company is based and from where we interact with you. Neeve encourages you to contact us to learn more about your privacy rights and how we collect and use your Personal Data.

We collect information that relates to you and your interactions with Neeve.

A. Personal Information You Provide.

When you interact with us or use our Products and Services, we may collect Personal Data, such as but not limited to your name, gender, birthdate, government identification number, mailing address, physical location, email address, phone number, device IDs, username and password.

Providing us with some Personal Data may be required in order for you to interact with us or to register for and use our Products and Services.

You may be invited to provide additional Personal Data to personalize your interactions with us and your use of our Products and Services.

If you work at Neeve or are applying to work with us, Personal Data will be required in order for you to apply for, be considered for, and maintain employment with Neeve. Our Employee Handbook provides additional information regarding our privacy practices for employment matters.

B. Mobile Application Data.

If you download or use our mobile apps, we may collect, either through your mobile device or the application itself, your email address, your username, your mobile device identifier, hardware model, operating system version or mobile network information (as well as any additional registration data you provide to us). Neeve may also collect geolocation information and language or access preferences, which we may use for access to and operation of our Products and Services. We may also collect data related to your interaction with our Products and Services, including operation of our mobile applications, crash data, performance data and other diagnostic data.

C. Personal Data from Third Parties.

If you interact with Neeve through a third party, we may receive Personal Data from that third party when you have consented for them to share it with us. For instance, when you use our Products and Services which relate to your use and enjoyment of building services and operations, we may receive Personal Data from your employer, your residential systems, your professional building systems or products or services providers operating in your residential or professional building.

We may use third party services to supplement, validate or increase the accuracy or relevance of Personal Data that you give to Neeve.

The Personal Data that you share with third parties is not controlled by Neeve or covered by our privacy practices. We encourage you to review third party policies and privacy settings so that you understand how the Personal Data you share with them may be used or shared with others, including Neeve.

D. Automatic Functional Information.

We may automatically collect some usage information when you interact with Neeve. For instance, we use cookies and other tracking technologies to automatically collect technical information, such as URL, cookie data, IP address, device type, unique device IDs, device attributes, network connection type (e.g., WiFi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, operating system, and products and services information.

E. Derived Information.

Neeve may use information, including Personal Data, that we have about you to draw inferences and we may then use those inferences to gain a more complete understanding of your preferences. We use preference data in order to offer you potential choices, make recommendations, or to alert you to products or services that may be of interest to you.

F. Children’s Information.

Neeve Products and Services are intended for and directed to adults, not children. If you are under 18, do not supply any Personal Data to Neeve for the purposes of purchasing or using a Product or Service. If you wish to purchase a Neeve Product or use our Services, please ask your parent or guardian to handle these transactions for you. If you are aware that we have unintentionally collected information from someone who is underage, please notify us immediately by sending an email to privacy@neeve.ai .

We use your Personal Data to develop and provide our Products and Services to you, and to personalize, improve and promote our interactions with you.

We do not sell or share your Personal Data with third parties for their commercial use without your consent.

Unless we specifically disclose otherwise, you understand that Neeve may use any of your collected Personal Data for any of the purposes described in this Privacy Policy (as permitted by applicable law), including:

A. For Account Registration and Servicing.

We may use your Personal Data to create, maintain, supplement, service, change or delete your account with us.

If you have an account with us, we may collect certain Personal Data for security purposes in order to verify your authorized access to your account with Neeve.

We may use your Personal Data to resolve customer service questions you may have about our Products and Services and to follow up with you about your experience.

If you have an account provided through a third party, we may use your Personal Data for security purposes to verify that you are authorized to use selected Products and Services.

B. To Communicate with You.

We may use your Personal Data to communicate with you about our company, our Products and Services, and to share offers for third party products and services that we think you may find useful.

If you have an account provided through a third party, we may communicate with you on behalf of or at the instruction of such authorizing third party.

C. To Improve and Develop New Products and Services.

We may use your Personal Data to personalize your interactions and experiences with us and our Products and Services which are offered to you directly or through a third party.

• We may use your Personal Data to improve the quality of and to develop new Products and Services.
• We may use any information you give to us in surveys or other forms of feedback.
• We may combine your information with that from other customers in order to better understand our Products and Services and how we may improve them.

D. To Provide Our Products and Services and Operate Our Business.

We may use your information to operate our business, including fulfilling your requests, providing you with technical or customer support, and to help us protect our Products and Services, including to combat fraud and protect your information and that of our other customers.

We may conduct research using your information alone or in combination with that of other customers. When we share that research outside of Neeve for research, academic, marketing and/or promotional purposes, we do so in an aggregated or deidentified way such that no Individual is identifiable with Personal Data.

Neeve will only share your information as we have described in this Privacy Policy, and only (i) in accordance with your consent and elections, (ii) to comply with legal obligations, (iii) to protect and defend Neeve, (iv) as part of a corporate transaction, or (v) as de-identified or aggregated information.

A. Third Party Service Providers.

With your permission or at your direction, we may disclose or share your Personal Data with third party service providers who we contract with to help us provide our Products and Services and operate our business. For example, your Personal Data may be shared when you authorize a third party application to access your account or when you are authorized to interact with Neeve Products and Services through another party, such as an employer, building owner or building management.

B. Information Sharing Between Neeve Entities.

This Privacy Policy applies to all of your interactions with Neeve, regardless of geography or corporate entity. We may share your Personal Data with and among our affiliates and subsidiaries, including specifically, but not limited to, Neeve, Inc., RXR Urban Workplaces LLC, and ioTium, Inc. Except as prohibited by law, regulation, or a contractual obligation, we share your information across Neeve to support our business operations, to enhance your experiences with our Products and Services, to improve your interactions with us, and to help detect and prevent fraud. When we share information between Neeve entities, we do so with your consent and/or in a manner that incorporates adequate technological and data minimization and localization measures to safeguard data during collection, processing and transfer between our Neeve entities.

C. Following the Law and Protecting Neeve.

We may share your Personal Data with courts, law enforcement or regulatory agencies, or other government bodies when we have a good faith belief that we are required or permitted to do so by applicable law, regulation, or legal process. We may also disclose your Personal Data where we believe it is appropriate to enforce our Terms of Use; to protect the rights, property or safety of Neeve or its users; to safeguard our Products and Services; or to protect or assist others as required by law or contract.

D. Financial Reporting.

We may share information about your account with us with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

E. Sale of Our Business.

If we sell, merge, or transfer any part of our business, your Personal Data may be shared, sold, or transferred as part of that transaction. We may also share your Personal Data with current or future corporate parents, subsidiaries or affiliates.

F. De-identified or Aggregated Data.

We may de-identify or aggregate your information, alone or in combination with other individuals’ information, such that it no longer contains Personal Data. We may then share such de-identified or aggregated information freely.

G. With your Consent.

In addition to the above purposes and exceptions, we will only share your Personal Data and your information for other purposes with your consent, at your direction, or as required by law or administrative action.

Neeve uses appropriate data transfer mechanisms and protection measures.

Where permitted by applicable law, we may transfer, process or store your Personal Data in any country or region where we have facilities, business operations, or provide our Products and Services. By using our Products and Services, you consent to the transfer of your Personal Data to, and the processing and storage of your Personal Data in and through, countries outside of your country of residence or the point of collection.

Some countries may have data protection laws that are different from the laws of your country. However, Neeve has taken appropriate safeguards to require that your Personal Data remains protected when it is being transferred, processed, and stored.

Please contact us to learn more about your rights with respect to data transfers and to request access to, limit the use of, or limit the disclosure of, your Personal Data. If you make a request that involves Personal Data, you will need to provide Neeve with certain authentication and verification information in order for us to respond to your request.

Neeve may work with third parties to enhance your experience with us.

In your interactions with Neeve, it may be necessary for us to sync, link or connect your information with third parties, including providing Personal Data necessary to identify you or authenticate your requested interactions. Your consent for these interactions will be required by us, by the third party, or by both. We encourage you to review the privacy practices of any third party that you choose to share your Personal Data with, as we are not responsible for the privacy practices of third parties.

You have a choice about the use of information that identifies you, marketing communications you receive from us, and our use of cookies and other tracking technologies.

You can review and change your information or deactivate your account in your account settings, but we may retain certain information. While you have the right to select whether you receive promotional messages, you may still receive other non-promotional messages from us.

A. Managing Marketing Communications From Us.

We will honor your choices when it comes to receiving marketing communications from us. If you have received marketing communications from us that you no longer wish to receive, you may:

• Contact Us to manage your information, adjust your preferences regarding your Personal Data, and regulate your interactions with us and our Products and Services.
• Click the “unsubscribe” link in the email or other materials that you received from us. If the email or other materials are from a third party, you will need to contact them to unsubscribe.
• Adjust or update your preferences in your account settings. If you access Neeve Products and Services through a third party, you may need to contact them to adjust or update your preferences.
• For SMS messages from Neeve, reply “STOP” or follow the instructions in the message or settings to discontinue the communications.
• If you are receiving push notifications from us to your mobile device and no longer wish to receive these types of communications from Neeve, you may turn them off at the device level.
• Remember that even if you choose not to receive marketing communications from Neeve, we will continue to send you mandatory service or transactional communications.
• If you do not have an account with Neeve and you wish to adjust your preferences regarding your Personal Data and your interactions with us, please contact us for assistance.

B. Updating Your Personal Data.

You may access, update, change, correct or request deletion of your Personal Data by adjusting your account settings or by contacting Neeve. If you access our Products and Services through a third party, you may also need to contact them to make changes to your Personal Data.

C. Cookies and Similar Tracking Technologies.

We may use and allow others to use cookies, web beacons, pixels, local shared objects, device identifiers, and other similar technologies (“Cookies”) to collect information about you. We use this information to improve your experiences when you interact with Neeve and our Products and Services. You have control over some of the data we collect from Cookies and how we use that information. For details about these technologies and the information that may be collected, used, or shared, including how you may be able to control or disable these applications, we suggest that you consider the following websites:

• Google Privacy and Terms
• LinkedIn
• Hubspot
• Pendo

D. Do Not Track.

Like most other companies, Neeve is not currently configured to respond to browser “Do Not Track” signals because, at this time, no formal “Do Not Track” standard has been adopted.

E. Social Media Features.

Neeve or our authorized third parties may use social media features to gather certain information about you. These features may collect your IP address, log which page you are visiting, and may set a Cookie to enable the feature to function properly. Neeve does not govern your interactions with these social media features. Instead, they are governed by the privacy policies and practices of the providing company.

You may have the right to exercise certain data protection rights regarding your information.

Your rights may depend on the country or region in which you are resident.

You may always contact your local data protection authority regarding the use of your information.

Neeve will not discriminate against you for exercising your privacy rights.

A. Data Retention.

Neeve retains and uses your information, including Personal Data, in accordance with and as permitted by applicable laws and regulations:

• We will retain your information as long as necessary to allow you to use our Products and Services, to maintain your account for as long as your account is authorized, or as otherwise needed to operate our business.
• Even when your account is closed or inactive, unless you have elected to not receive marketing communications from us, we may continue to communicate with you about our Products and Services, give you important business updates that may affect you, and let you know about interesting Products and Services.
• We may also continue to use some of your information, including Personal Data, for our business purposes and to improve our Products and Services offerings or develop new ones.
• We will retain and use your information as required by applicable laws and regulations, in accordance with Neeve’s records and information management policies, to comply with our legal and reporting obligations, to resolve disputes, to enforce our agreements, to complete any outstanding transactions, and for the detection and prevention of fraud.

B. Responses from Neeve.

In accordance with applicable data protection laws, we respond to all requests from Individuals regarding the exercise of their data protection rights. Your data protection rights may vary depending on the country or region in which you are located, but generally include:

• Accessing, correcting, updating, or requesting deletion of your information;
• Objecting to or asking us to restrict the processing of your information;
• Requesting the portability of your information and providing the same in a timely manner and at no charge;
• Electing whether or not to receive marketing communications from us;
• Withdrawing your consent at any time for us to collect, process, store, or share your information (noting that such withdrawal will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect otherwise lawful processing or storage).

C. Data Controller.

Under most applicable data privacy regulations, Neeve is considered to be a “controller” of your information that it directly collects from you. Other entities may also act as controllers of your information and you should contact them if you have any questions about how they use your information.

We provide reasonable and appropriate security measures in connection with securing Personal Data we collect.

Keeping your Personal Data safe is important to us. At Neeve we:

• Constantly work to update our security practices to implement accepted best methods to protect your Personal Data and review our security procedures carefully.
• Comply with applicable laws and security standards.
• Securely transmit your sensitive Personal Data.
• Train applicable employees and contractors on data privacy and require them to safeguard your Personal Data.
• Transmit, store, protect, and access all financial information that you share with us.

We provide our products and services in many different countries and regions. Our Privacy Policy sets out the privacy principles and procedures we adhere to, but other laws may apply to you based on the country or region in which you are located or from which you are interacting with Neeve.

Neeve is based in California and has adopted a global view on privacy with the intent of providing our customers with strong privacy rights regardless of where they reside. We have attempted to recognize and implement high standards for privacy rights compliance on a global scale and our use of terminology in this Privacy Policy should be interpreted to reflect that intent.

In addition to the terms of this Privacy Policy, Neeve wants Individuals with whom it interacts that are located in various jurisdictions to understand that additional privacy and data protection measures may be applicable. You can find additional privacy terms that may be relevant to your specific country or region below.

• United States
• Canada
• China
• Europe/EEA, Switzerland, and United Kingdom
• India
• Japan

If you use our Products and Services in locations outside of the State of California in the United States of America, your Personal Data is processed by Neeve, its affiliates and their third party suppliers in the United States of America and other locations in the rest of the world. By using Neeve Products and Services from your location, you hereby consent that (a) your Personal Data may be transferred outside of your location to at least the locations noted in this Privacy Policy, and (b) Neeve, its affiliates and their third party suppliers may process your Personal Data in order to provide the Products and Services.

We may make changes to our Privacy Policy or our supporting privacy procedures at any time.

From time to time Neeve may change or update this Privacy Policy. We reserve the right to make changes or updates at any time and without prior notice to you.

If we make material changes to the way we process your Personal Data, we will provide you notice by posting the most current version of this Privacy Policy on our websites and we may also advise you of changes via our Products and Services or by other communication channels, such as by email, newsletters or community posts. Please review any changes carefully.

If you object to any changes and no longer wish to use our Products and Services, you may close your account and cease use of our Products and Services. All changes to our Privacy Policy are effective immediately upon posting and your continued interaction with Neeve or your use of our Products and Services after a posting of an updated Privacy Policy constitutes your consent to all changes.

If you have questions or comments about this Privacy Policy, you may contact us by email, telephone or direct mail.

A. Via Email: privacy@neeve.ai

B. Via Telephone: +1-415-237-1894

C. Via Direct Mail:
Neeve, Inc. ℅ Studio
Attn: Privacy Officer
365 Toni Stone Crossing,
San Francisco, CA 94158