UPDATED: April 25. 2021
CATEGORIES OF PERSONAL INFORMATION WE COLLECT.
When you interact with Neu, we collect information from that interaction, for example, from your visits to and use of our Sites, from your email correspondence to us, from your submittal of an employment or rental application and our processing and review of those applications, from your online responses to us, from your completion of a registration card in one of our communities, from information that you post online, for example, on our Social Media Pages including, for example, Facebook, Twitter, LinkedIn, and Instagram and when you interact with our Mobile Applications. When this information is reasonably capable of being associated with you, we refer to this information as Personal Information.
At Neu we may collect and share the following categories of Personal Information:
Identifiers are information directly linked to a particular individual. For example, depending on the circumstance, Neu may collect your name, address, email address, or phone number as part of a home purchase agreement, a rental application and the related lease agreement or other interaction. Identifiers also include more sensitive information that may be gathered from you or others about you, including your social security number, driver's license number or insurance policy number, where that information is necessary in order to complete a transaction. If you buy or rent a home from us, or otherwise engage in a commercial transaction with us, we may also collect financial information and other information necessary to complete your transaction.
We collect this information from you, from publicly available sources, and from our Third-Party Service Providers and other third parties, and do so for the purpose of completing transactions into which you have entered, or to provide you with information about our goods and services. Depending on the nature of your interaction with Neu, we also may be required by law to collect this information.
At times, we may share Identifiers with our Third-Party Service Providers, our Affiliates, or other third parties to complete the transactions into which you have entered. In addition, we may share Identifiers with our Third-Party Service Providers, our Affiliates or other third parties in order to showcase our goods and services or the products of our Affiliates or third parties that may be of interest to you.
Certain Identifiers may also be included in our customer records. These are records of our business transactions and interactions with you, and often include your name, address, or other information collected during, and for the purpose of effectuating, those business transactions. We collect this information from you, or from our Third-Party Service Providers acting on our behalf. Our use of this information, and use by our Third-Party Service Providers with which it is shared, are identical to the way we handle "Identifiers," as described above.
Legally Protected Characteristics.
Depending on the nature of our interaction with you, we may be required under state or federal law to collect certain information related to legally protected characteristics. This may include your age, sex, gender, sexual orientation, race, or ethnicity. We collect this information from you, and maintain and disclose this information in order to confirm compliance with certain legal obligations, or otherwise provide you with information about our goods and services.
Depending on the nature of our interaction with you, we may collect certain commercial information related to you, including property records, records of past purchases involving Neu, its Affiliates, or our Third-Party Service Providers, or information that you provide to us through your online Accounts. We collect this information as a result of our transactions with you, either from you directly or from our Third-Party Service Providers acting on our behalf. We may also collect certain commercial information from publicly available sources in order to facilitate our transactions.
We use this information to complete our transactions with you and to maintain a record of those transactions as is often required by applicable laws and regulations. We also use this information to provide you with information related to our goods and services that may be of interest to you. While we do not often share this information with third parties, at times we share this information with our Third-Party Service Providers, including financial institutions, payment processors, and other entities that assist us in facilitating our transactions with you. We may also share this information with Neu Affiliates, our analytics providers, and our interest-based advertising providers.
Internet Activity and Identifiers.
We collect this information in order to enhance your experience on our Sites, and to ensure the information we provide to you is relevant to your interests. We share this information with Neu Affiliates, and certain of our Third-Party Service Providers such as our analytics providers, and our interest-based advertising providers.
You may provide certain location information to us as part of your inquiry into our goods and services, or as part of the home-buying process. In addition, if you interact with Neu through the use of your mobile device, we may obtain certain geolocation data from that interaction. We obtain this information through your mobile device's interactions with our mobile sites and applications.
We obtain this information in order to more accurately provide you with information. For example, we may use your geolocation information to respond to your mobile request for home availability in your area. We share this information with Neu Affiliates, and certain of our Third-Party Service Providers such as our analytics providers, and our interest-based advertising providers.
Video or Audio Recordings.
Depending on the nature of your interaction with us, you may have provided us with video or audio recordings or consent to record our interactions with you. These may be recordings of your interactions with our customer representatives, voicemails you may leave us, or visits to our model homes. We collect video or audio recordings with your consent, or as permitted by applicable law. We use those recordings only for training purposes, security purposes, or to respond to your request. We may also use testimonial recordings for marketing purposes but will only do so with your consent.
Professional or Employment-Related Information.
Neu may collect certain professional or employment-related information about you, either as part of our business transactions with you, or in order to evaluate your candidacy for employment with Neu or one of our Affiliates. In this way, we collect professional information from you directly, or from our Third-Party Service Providers and for the specific purposes outlined during the collection.
While we may share your professional or employment-related information with third parties as required by law or to facilitate our transactions with you, we do not share your professional or employment-related information with third parties for other purposes. We may share this information with our Third-Party Service Providers or Affiliates, but otherwise do not share this information with other third parties.
Neu may collect certain educational information about you in order to evaluate your candidacy for employment with Neu or one of our Affiliates or as part of our business transaction with you. In this way, we collect educational information from you directly, or from our Third-Party Service Providers and for the specific purposes outlined during the collection.
While we may share your educational information with our Affiliates and third parties, such as our Third-Party Service Providers, to facilitate our transactions with you, we do not share your educational information with third parties for other purposes.
OTHER INFORMATION WE COLLECT.
Anonymous Information. Other information that we collect is Anonymous Information – that is, information that does not include Personal Information, or from which Personal Information has been deleted. Anonymous Information does not identify, and cannot be used to reasonably determine, the identity of, an individual. Anonymous Information may include demographic and other general information; it may include some, but not all, Automated Information collected through Cookies, including pixels and other technologies such as browser and other device information; and it may include high-level, non-specific location information and other information collected from your mobile devices.
Aggregate Information. We may also gather Anonymous Information of many individuals and combine that information. Aggregate Information does not identify, and cannot be used to reasonably determine, the identity of, an individual. Aggregate Information is about groups or categories of visitors rather than individual visitors.
Types of Cookies.
Essential Cookies: These Cookies are strictly necessary to provide you with our Sites and services and to enable essential features. If you disable these Cookies, we will not be able to fulfill your requests.
Performance and functionality Cookies: These Cookies collect information about how you use our Sites and services and allow us to remember the choices you make while browsing. The information these Cookies collect allows us to optimize our Sites and make them easier for you to use, and it does not personally identify you. If you disable or opt out of these Cookies, you may not be able to use certain features of our Sites, applications, and services, and it may reduce the support or information that we can provide you.
Analytics and customization Cookies: These Cookies collect information we use in aggregate form to help us understand how our Sites, applications and services are being used and how effective our marketing campaigns are, and to help us customize our Sites. If you disable or opt out of these Cookies, you may not be able to use certain features of our Sites, applications and services, and it may reduce the support or information that we can provide you.
Advertising Cookies: These Cookies collect information about your browsing history and are used to make advertising messages more relevant to you. They perform functions like preventing the same advertisement from continuously reappearing, ensuring that advertisements are properly displayed, and in some cases selecting advertisements that are based on your interests. We may share this information with third parties to help create and deliver advertising personalized to you and your interests. If you disable or opt out of these Cookies, you may not be able to use certain features of our Sites, applications and services, and it may reduce the support or information that we can provide you.
Social networking Cookies: These Cookies are used to enable you to share pages and content on our Sites and services through third-party social networking and other websites. These Cookies may also be used for advertising purposes.
Cookies Placed by Third Parties.
You may also encounter Cookies on our Sites, applications and services that are placed by third parties. We may also allow third parties to place Cookies on our Sites to track information about your online activities and/or across third-party sites or online services, including to send you targeted advertisements based on that information, which may include the remarketing of our products and services that you have viewed on our Sites and on third-party websites. If you are a resident of the European Economic Area, we do not permit the placement of non-essential third-party Cookies without your consent.
HOW WE COLLECT INFORMATION.
The information we collect varies depending on how you interact with us or others:
Information You Provide to Us. You may provide information to us online for any number of reasons. For example, you may sign your home purchase agreement or lease over the Internet, request information about our homes or communities, talk to us via videoconference, make notes about our homes or communities, submit a warranty request, respond to a survey, submit a job or rental application, interact on our Social Media Pages or with our Mobile Applications, or subscribe to promotional emails. In such cases, we, or our Third-Party Service Providers, will collect the information that you provide, which may include information regarding your Neu home, your name, telephone number, email address, physical address, name of your present community or a Neu Community in which you are interested, certain demographic information, such as your age range and areas of interest, your payment card or banking account information if you are making a payment, and, in the case of a job application, your resume and social security number. In addition, you may provide information to us in person, for example, when you visit a model home. Unless prohibited by applicable law, we may combine information that you provide to us online with information that you provide to us in person, with publicly available information or with information provided to us by third parties such as social media platforms and data aggregators.
Email. If you provide your email address to us and request emails regarding Neu products and services, you will receive commercial emails from us marketing our products and services, and we will collect your email address, other information that you provide, as well as Automated Information that we may collect. You may revoke your consent to receive commercial emails from Neu marketing our products and services by clicking the "unsubscribe" button in marketing email communications to you. Please be aware that changes to Your Privacy Choices may not be immediate. We will implement your changes as quickly as practicable, but in all cases, in accordance with timeframes required by applicable law and in no more than 30 days.
Information from Third Parties. We may collect or purchase information from third parties, including marketing companies, digital advertising agencies, third-party ad servers, third-party email servers, data aggregators, analytics providers, investor relations firms or third-party advertising networks. Certain of this information may be Automated Information that these third parties have gathered as they have tracked you across the Internet and over time. If you have responded to, or interacted with, third parties that share your information with us, we collect the information the third parties provide to us, including your email address.
Location Information. We collect location information that you may enter when using our Sites such as your physical address, including your zip code. We also may collect Automated Information, including your location indicated by your IP Address, that may be provided by your internet service provider or ISP. Finally, we may collect your location from your mobile device when you interact with our Mobile Applications, if you consent to sharing your location with Neu. If you reside in the European Economic Area, we only process your location information from your mobile device with your consent.
Automated Information. We and our Third-Party Service Providers have automated means of collecting information from you when you visit our Sites, or otherwise interact with us online. The information that is collected using these automated technologies does not identify you personally, but instead is linked to an anonymous numerical identifier. Consequently, except as otherwise required by applicable law, we use and disclose this Automated Information as Anonymous Information rather than Personal Information.
Through the Use of Web Beacons and Other Similar Technologies.Neu and its Third-Party Service Providers may use Web Beacons (also known as GIFs or clear GIFs) and similar technologies that are electronic images that may recognize cookies on your browser when you view a website or an email. The use of data collected by such technologies assists us in measuring the success of our advertising campaigns, understanding how many viewers open an email message, and understanding the use of our Sites, including compiling analytics about its use. We may allow our Third-Party Service Providers to collect and compile Anonymous Information and Aggregate Information from the use of Web Beacons on our Sites to determine the efficiency of our Sites and the effectiveness of our marketing campaigns.
Through Your Browser. Some information is collected automatically from your browser, such as your Media Access Control or "MAC address," your computer type, operating system and version number, device manufacturer, Internet browser and version number, and the name and version of the websites you visit and applications you are using. We use this information to assist us in enhancing and correcting the performance of our Sites. To the extent any this information is collected through the use of "non-essential cookies," if you reside in the European Economic Area, we only collect this information with your consent.
Through Your Use of Your Mobile Device. If you are using a mobile device to interact with our Mobile Applications, we may collect information about your online behavior utilizing your device's Mobile Advertising Identifier or other temporary numeric identifier. This allows us to follow your online behavior without accessing your mobile device's permanent identifier. As part of the collection of Automated Information from your mobile device, we may collect information about your physical location. We use this information to provide you with geographically based material, such as when you search for a home on a mobile device. We will provide information to you regarding Neu communities that are close to you. We may share your physical location with our Third-Party Service Providers so that they may combine this information with other information about your browsing behavior such as the advertisements that you viewed. This allows us and our Third-Party Service Providers to share with you information that is of interest to you. This information may also be used by Third-Party Service Providers to track you across the devices that you use. Most mobile devices contain built in privacy controls that will allow you to opt-out of interest-based advertising or cross application advertising. Most also have functionality that will allow you to change your Mobile Advertising Identifier.
Through Our Server Logs. Your IP Address is automatically logged to our server logs whenever you visit our Sites, together with the date and time of your visit and the pages on our Sites that you visit. Your IP Address is a unique numerical identifier that is assigned to your device by your ISP. Collecting IP Addresses is standard practice for website operators across the Internet. We use IP Addresses to assist us in enhancing and correcting the performance of our Sites. We use and disclose IP Addresses in accordance with applicable law.
Through an Application That You Use. You may use a program or service that we operate or that one of our Third-Party Service Providers operates on our behalf that is displayed on any one of our Sites. When you use the application, we or our Third-Party Service Providers may collect information about your usage of the application. We use this information to improve the functionality of our applications and to determine usage patterns.
Through Devices Installed in Your Home. Devices installed in your home may collect information about you and your use of the device. These devices may include, for example, a video doorbell, a door lock, a programmable thermostat, a smart light switch, a touchscreen smart home control device, home security devices such as door and window contacts and motion detectors, a garage door opener, and a smart speaker, all of which are integrated by a home automation platform. Certain of the information collected by these devices may be shared over the Internet with the third‑party providers of the devices and will be used by these companies in accordance with their own privacy policies and practices.
HOW WE USE INFORMATION.
Generally speaking, we use Personal Information and Anonymous Information to provide, improve, and develop our products and services, to communicate with you, to offer you targeted advertisements and services, and to protect us and our users.
While we will use the information we collect for any lawful purpose we deem appropriate, more specifically, we use the information we collect for the following purposes:
Providing, improving, and developing our products and services:We use Personal Information and Anonymous Information to help us provide, improve, and develop our products, services, and advertising. This includes using Personal Information for purposes such as data analysis, research, and audits. Such use and processing is based on our legitimate interest in offering you products and services and for business continuity.
Offering and measuring targeted advertisements and services:We may use Personal Information to personalize your experience with our products and services, on third-party websites and applications, and to determine the effectiveness of our promotional campaigns.
Promoting safety and security: We use Personal Information to help verify user activity, as well as to promote safety and security, such as by monitoring fraud and investigating suspicious or potentially illegal activity or violations of our terms or policies, and to comply with any applicable law, regulation, legal process, or governmental request. Such use and processing is based on our legitimate interest in helping ensure the safety of our company and users who interact with us online.
If you use or visit our Sites, submit content to us, or post or submit any content on this Website or our other Sites such as our Social Media Pages, you agree that, with respect to such content, Neu is granted an unlimited, non-exclusive, world-wide, non-revocable, perpetual license to reproduce, duplicate, transmit, display, publish, create derivative works, sublicense and otherwise use any such information for any lawful purpose whatsoever, including marketing and you agree to hold us harmless with respect thereto.
HOW WE SHARE INFORMATION WE COLLECT.
Neu Affiliates. Neu and its Affiliates may share your information, including your Personal Information, with one another. Such sharing may be for the direct marketing purpose of Neu or its Affiliates. Neu is the party responsible for the management of your Personal Information that is jointly used by our Affiliates.
Third-Party Service Providers Providing Services to Neu and Neu Customers.If you are a Neu customer or prospective customer, we share your information, which may include Personal Information, with our, Third-Party Service Providers, including our subcontractors, financial institutions, payment processors (for example, our payment card and ACH processors) and developers of communities (for example, electricians, painters, land developers and telecom providers), in connection with your purchase or rental of a Neu home, in response to your warranty requests, to complete transactions that you have initiated such as, but not limited to, customer service requests, and payment transactions using your payment card or banking information, and to provide services to you and our other customers. We may share your information with our Third-Party Service Providers that perform services on our behalf, such as those that perform technology services for us such as website hosting, email delivery, and electronic signature services.
Homeowner Associations. If you purchase or rent a home from us in a community with a homeowner association, we share your Personal Information with the homeowner association so that it may perform its responsibilities, such as collecting dues and sending notices.
Our Rental Communities. With respect to homes that we rent, we may share your Personal Information with Third-Party Service Providers that perform leasing and property management services for our communities. Such services include designing and hosting community websites, implementing and hosting applicant and tenant portals, managing leasing applications, screening potential tenants, and performing other leasing and property management services. In addition, through our Sites, we may provide you access to websites of our Third-Party Service Providers to allow you to perform certain activities online such as submitting an application to rent, making rental payments, or requesting maintenance for your home. The collection and use of your Personal Information by our Third-Party Service Providers, including on their websites, is governed by their own privacy policies and contractual limitations that we may include in their agreements with Neu.
Our Analytics Providers. Certain of our Third-Party Service Providers assist us in analyzing Automated Information that we, and they, collect regarding the online behavior of visitors to our Sites. Automated Information collected through cookies assists us in analyzing, for example, which communities and homes visitors have viewed, which pages of our Sites are of most interest, what promotions visitors have enjoyed and the success of our advertising campaigns.
Our Interest-Based Advertising Providers. Neu utilizes Third-Party Service Providers to deliver advertisements including interest-based advertisements to you based on your previous online behavior, including your browsing history, as well as other Automated Information that they have collected about you while you have visited websites and utilized applications, including our own. Our interest-based advertisements may be delivered to you on our Sites, across the Internet and across your devices.
Legal Matters. It may be necessary - by law or as a result of legal process, litigation, or requests from public or governmental authorities within or outside your country of residence - for us to disclose Personal Information. We may also disclose Personal Information if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate.
We may also disclose Personal Information if we determine in good faith that disclosure is reasonably necessary to protect our rights and pursue available remedies, enforce our terms and conditions, investigate fraud, or protect our operations or users.
Business Transactions. We may share your information, including your Personal Information, with potential or actual buyers or other parties to the transaction in the event of a potential or actual sale, spin-off, merger, or similar corporate transaction involving a business unit of Neu.
Storage. We may share your information, including your Personal Information, with third parties for the purpose of helping us gather, store and maintain data.
THIRD-PARTY COLLECTION OF PERSONAL INFORMATION ABOUT YOUR ONLINE ACTIVITIES OVER TIME AND ACROSS DIFFERENT WEBSITES.
We allow certain third parties to collect information, including Personal Information, about your online activities on our Sites, and on and across different websites after you leave our Sites. In addition, other third parties with which we have no business relationship may be tracking your online behavior across the Internet including when you visit our Sites.
We may offer you the ability to receive SMS text messages from us, including those that are sent using automated means. We send text messages with your consent, and they are not a condition of any purchase. Your mobile carrier's message and data rates may apply. You may choose to stop receiving text messages from us by replying STOP.
DO NOT TRACK SIGNALS.
Some web browsers may give you the ability to enable "Do Not Track" functionality. "Do Not Track" is a browser setting that requests that web applications eliminate their tracking of you. When you choose to turn on your "Do Not Track" setting, your browser sends a signal to third-party ad servers, digital advertising networks, data aggregators and others to stop tracking you. This is different than disabling cookies on your browser. Browsers with the "Do Not Track" functionality enabled continue to have the capability to accept cookies. There is currently no agreement or consensus on how companies should interpret a "Do Not Track" signal. Consequently, we do not honor "Do Not Track" signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of information (including your Personal Information) relating to your online activities over time and across third-party websites or online services.
Neu, as an employer, in the normal course of business and as required by law, collects social security numbers. In connection with accepting job applications, we will collect Personal Information from prospective new employees, including their social security number. This information is transmitted over a secure connection that implements encryption of the Personal Information being transmitted. In addition to secure connections and encryption for collection, we maintain other reasonable measures to protect and limit access to social security numbers on a need-to-know basis. In addition, we prohibit their unlawful disclosure. We maintain reasonable procedures to destroy, erase, or make unreadable any data, computer files and documents containing social security numbers prior to their disposal. Failure to follow these procedures by any employee may subject the employee to disciplinary action up to, and including, termination.
YOUR PRIVACY RIGHTS.
We take reasonable steps to ensure that your Personal Information is accurate, complete, and up-to-date. Depending on where you live, you may have some or all of the rights described below.
Your California Privacy Rights.
California residents may have further rights related to the handling of their Personal Information under the California Consumer Privacy Act. Neu may share your Personal Information with third parties that perform or market services at your home and in our communities and/or that market products you may purchase for your home. In return, Neu may receive a monetary benefit. Such sharing may constitute a sale under applicable law. Neu extends California residents certain rights related to this information. California residents also have the right to not be treated differently by Neu in response to your decision to exercise any of these rights.
LINKS TO OTHER WEBSITES.
Our Sites contain general information not directed towards children. We do not knowingly collect information from children under the age of 13, or the equivalent minimum age depending on the jurisdiction. In this regard, our Sites are general audience sites that are not designed nor intended to collect Personal Information from children under the age of 13. We do not sell the information of children under the age of 16 without affirmative authorization by the child's parent or legal guardian.
USE OF OUR WEBSITE IN OTHER COUNTRIES.
If you choose to access one of our Sites, including this Website, from a country other than the United States, you acknowledge that our Sites are operated in the United States. Information that you share with us through our Sites or which is collected about you or your online behavior will be transferred to and processed in the United States. By using our Sites, you consent to this transfer, storage and processing of your information in the United States where the privacy laws may be different, including more or less protective, than the country in which you are using our Sites.
CROSS BORDER TRANSFER.
When we share your personal information with our partners, affiliated companies, and Third-Party Service Providers, your personal information may be transferred to and/or made accessible from countries outside of the European Economic Area. Where required, we will enter into model contractual clauses as adopted by the European Commission, or rely on alternative legal bases, where applicable, or binding corporate rules where our partners or Third-Party Service Providers have adopted such internal policies approved by European data protection authorities.
We provide the opportunity on our Sites for you to review employment opportunities with us and our Affiliates and to submit online an employment application. If you choose to do so, the laws and regulations of the United States will apply to the collection and use of all information that you provide.
Neu has implemented safeguards as required by law to protect your Personal Information. Unfortunately, however, no information or data transmitted electronically, including information or data transmitted over the Internet or stored electronically can be assumed to be safe and secure. If you believe that the security of any information or data that you have provided to us has been compromised, please immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section below.
We may occasionally update this Privacy Statement. When we do, we will revise the “last updated” date at the top of the Privacy Statement and take such additional steps as may be required by law.