neld — Privacy Policy

This Privacy Policy takes effect on the date the Service is officially launched.

This privacy policy (“Privacy Policy”) contains important information regarding SNOW Corp. (“SNOW,” “us,” “our,” or “we”), and how and why we collect, store, use, and share your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint.

Please read this Privacy Policy carefully before using NELD’s website, and all publicly available websites and subdomains provided by us on which a link to this Privacy Policy is displayed (collectively or individually referred to as the “Application”). By using the Application, you consent to the collection, transfer, process, storage, disclosure, and use of your information as described in this Privacy Policy. If you do not agree with this Privacy Policy, then please do not use the Application.

This Privacy Policy may change from time to time. Your continued use of the Application after we revise this Privacy Policy means you accept those changes, so please check the Privacy Policy periodically for updates.

1. Scope of Privacy Policy

This Privacy Policy is part of the Terms of Service for the Application and includes any separate privacy notices and/or notices posted on particular pages of the Application that may provide more detail regarding the information we collect on those pages, why we need that information, and choices you may have about the ways we use that information. No matter where your information is collected, used, transferred or stored, if it was collected through the Application, it will be subject to the terms of this Privacy Policy.

2. Information We Collect

We may collect and use the following personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer:

• Information provided to us directly by you.
• Information collected automatically when you use the Application.

Information You Provide To Us Directly

When you register with, or use this Application, we may ask that you provide:

• Your SNS identifier, email address, Profile Image and nickname when you register for an account and provide information to link to a social media account.
• Event information: When you participate in our events or promotions, we may ask for your name, phone number, address, email address, Social Media account and any other information required to deliver prizes and to respond to inquiries.
• User Content (e.g., photos, comments, and other materials) that you post to the Application.
• Information you provide to other users through the Application.
• Information you provide for customer service (e.g., email, country information, records and copies of your correspondence, etc.)
• Communications between you and SNOW. (For example, we may send you Application-related emails. Note that you may not opt out of Application-related e-mails.)

Purchase Information

When you make purchases (e.g., Regular subscription, credits, etc.) in NELD, we will collect related order information, including IP address, order number, transaction time, product category and product price. This information is collected when you provide us with your payment information to place an order through the Application.

Analytics Information

We use third-party analytics tools to help us measure traffic and usage trends for the Application. These tools collect information sent by your device to our Application, including the content and ads that you view or click, and other information that assists us in improving the Application. We collect and use this analytics information in the aggregate with analytics information from other users so that it cannot reasonably be used to identify any particular individual user.

Behavioral Advertising Information

We do not allow third-party advertising companies to collect information through the Application in order to provide behavioral (interest-based) advertisements. If you wish to learn more about behavioral advertising practices generally or to opt out of this type of advertising, you can visit the websites of the Digital Advertising Alliance at www.aboutads.info and Networking Advertising Initiative at www.networkadvertising.org/choices/.

Log Information

When you use the Application, we may automatically collect and store certain information in server logs. This may include:

• Information on how you interact with the Application.
• Your IP address.
• Device event information such as browser type, browser language, the date and time of your request and referral URL.

Metadata

Metadata refers to technical data associated with user content. Put simply, metadata is data that describes data. When you use the Application, we collect and use technical metadata associated with your User Content and Generated Output, such as file format, file size, and resolution; the AI model and parameters used to produce a Generated Output; and the canvas and node context in which the content was created or used. We may also make use of the metadata to serve up more contextually relevant products or services to you.

Device and Usage Information

We may collect device and usage information such as:

• Other information about your device: device type, operating system, IP address, browser type (e.g., Firefox, Chrome, Safari), timestamps, and time zone.
• Data about user activities (e.g., the pages you view, the time and duration of your activities in the NELD) that helps us determine how a user interacts with advertising or content, such as determining whether a user who viewed a particular advertisement ultimately purchased the advertised product or service.

Third-Party Social Media Site

If you choose, you can log in to the Application through certain third-party social media sites. Any information that such social media site provides to us will be governed by this Privacy Policy. This information includes nickname, email address, Profile Image and identifier.

Information Collection and Tracking Technologies

• Cookies (or mobile cookies). Cookies are small files installed on your browser. You may refuse to accept cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of the Application.
• Web Beacons. Pages of the Application may include small electronic files known as web beacons (also referred to as clear GIFs, pixel tags, and single-pixel GIFs) that allow the Company to identify users who have visited those pages and to gather other related statistics (for example, recording the popularity of certain webpage content and verifying system and server integrity).

3. How We Use Your Information

In addition to some of the specific uses of information we describe in this Privacy Policy, we may use information that we receive and the choices you make in your settings:

• To provide the functionality of the Application
• To help us develop, deliver, test and improve the Application
• To settle payments for purchases and paid services
• To monitor metrics such as total number of visitors, traffic, and demographic patterns
• To provide personalized content and information to you and others, which could include sending you promotional messages, marketing, advertising and other information that may be of interest to you
• To diagnose or fix technology problems
• To allow us to keep you posted on NELD’s latest product announcements, application updates, and upcoming events
• To provide customer support and respond to your inquiries and requests
• To allow professionals to contact you through the Application (as further described below)
• To administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our third-party business partners
• To find and prevent fraud
• To resolve disputes, to protect the rights, property, or safety of NELD, our Application visitors, customers, or the public, and to enforce any legal terms that govern your use of the Application or our other services and products
• To comply with our legal and regulatory obligations
• For the performance of any contract with you or to take steps at your request before entering into a contract
• In any other way we may describe when you provide the information
• Where you have given consent, or
• For any other legitimate interest or those of a third party, including the third parties identified in Section 4 (Information Sharing and Disclosure to Third Parties), below.

4. Information Sharing and Disclosure to Third Parties

Third-Party Service Providers

We use a variety of third-party service providers to help us provide the Application including business analytics, marketing, and other services. These providers have limited access to your information, including in some instances User Content, to perform these tasks on our behalf and are contractually obligated to use it consistent with this Privacy Policy.

Aggregated and Non-Personally Identifiable Information

We may share or disclose non-personally identifiable, aggregated usage information and geolocation information (such as anonymous usage data, platform types, number of clicks, location data, etc.) with unaffiliated partners and third parties. We do not share your personal information with third-party advertising networks for their own marketing purposes, and we do not allow third-party advertising platforms to collect behavioral information about you through the Application. You can control or disable the use of location services for the Application via your browser’s site location permission. See Section 6 “Your Choices About Your Information” of this Privacy Policy for further instructions.

Professionals and Other Users

Any information that you provide to other users via the Application are shared and disclosed to them. By sending your information to other users, you acknowledge and agree that they may contact you via the Application.

Business Transfers and Affiliates

We may share your information with companies or organizations connected or affiliated with SNOW. We may also transfer your information to an affiliate, a subsidiary or a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of SNOW’s business, assets or stock, including, without limitation, in connection with any bankruptcy or similar proceeding.

Legal Disclosures

Notwithstanding anything to the contrary in this Privacy Policy, we may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our users’ rights or property. However, nothing in this Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party’s, including a government’s, request to disclose your information.

5. Personal Information Sold or Disclosed for a Business Purpose

We do not sell personal information and have not sold personal information. We also do not allow third-party advertising platforms to collect behavioral information about you through the Application.

We may disclose to one or more third parties, for the business purposes described in this Privacy Policy, the following categories of personal information that identify, relate to, describe, are reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer:

• Identifiers: identifiers such as a unique personal identifier (such as cookies, beacons, pixel tags; other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Sensory Information: audio, electronic, visual, and similar information
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

6. Your Choices About Your Information

Account Information

You may update or correct information you have provided to us by going into the User Account settings screen within the Application. If you wish to deactivate your account, please use the account deletion option in your account settings, but note that we may retain your information as required by law or for business purposes.

Promotional Communications

You may opt out of receiving promotional communications from us by following the instructions in those messages. If you opt out, please note that we may still send you Application-related communications, such as those about your account or our ongoing business relations.

Opting Out of Interest-Based Advertising Services

Please note that opting-out will not block general advertisements that are sent at random and not tied to your perceived interest. You may learn more about personalized and behavioral advertising and how to opt out of this type of advertising from the Digital Advertising Alliance at www.aboutads.info and Networking Advertising Initiative at www.networkadvertising.org/choices/.

Profile Information

You may update or edit the information you have provided to us under “Settings > Profile”.

If you no longer want to use the service, you can opt out of it and delete the account.

Follow these steps to view, edit, or remove information from your profile.

• View Personal Information
  • Settings > Profile > Email, Name, Profile photo
• Accurate Personal Information
  • Settings > Profile > Name, Profile photo
• Disconnect SNS Account
  • Google: Google Account Management > Data and Privacy > Data from Apps and Services in Use > Third-Party Apps to Access My Account > Login via Google Account > Select Apps to Unlink > Delete Access
• Delete Personal Information
  • Settings > Profile > Name, Profile photo, Delete account

If you need to delete the content you created after deleting your account, please contact us at dl_neld@snowcorp.com with the content you want to delete and the reason for the request, and we will assist you with the deletion process after verifying your identity.

Delete requests can be sent directly by the author himself or through a legal representative. If the agent sends the request, the company may request the submission of a power of attorney to verify the agent’s legality.

Deletion requests may be denied if the requester is not the author himself or his/her legal representative, or if the content must be preserved under the law (at full discretion).

7. How Long We Keep Your Information

The Company may process and retain your personal information for the period necessary to get consent from you or to accomplish the purpose of the task specified in the Terms and Conditions and Privacy Policy. If the period specified below expires, all information, including personal information, will be deleted.

• Profile information provided when signing up and using the service: until deletion of NELD account.
• Records on the provision of goods or services: until the supply of goods or services is completed, or the use of the service is terminated.
• Inquiries about the use of services: until the troubleshooting is completed.

However, in any of the following events, the information may be stored until the relevant issues are resolved.

• At the time of account deletion: in case of damage caused by stolen information, etc., up to the minimum period specified by the Company for recovery and victim protection (30 days after deletion of account).
• In the event that an investigation is in progress due to violation of relevant laws and regulations in each service country: until the investigation is completed.
• In the event that residual claims and debt relationships result from service use: until the relevant claims and debt relationships are settled.
• If otherwise specified in the laws of the country providing the service: until the deadline required by the applicable laws.

8. Children’s Privacy

This Application is not directed to children under 14 years of age (or any higher minimum age required in your jurisdiction). We do not knowingly collect or solicit any information from anyone under the age of 14 (or such higher minimum age) or knowingly allow such persons to register for the Application. If you believe that we might have any information from or about a child under 14 (or such higher minimum age), please contact us at dl_neld@snowcorp.com.

9. Transferring Your Data

Your information collected through the Application may be stored and processed in the United States or any other country in which SNOW, its affiliates or service providers maintain facilities. As such, we and our service providers may transfer your personal data to, or access it in, jurisdictions (including the United States) that may not provide equivalent levels of data protection as your home jurisdiction.

In particular, when you make a purchase, your payment is processed by a third-party payment processor designated by SNOW (the processor, and the countries in which it processes payment data, will be identified in this policy once confirmed), and when you use AI generation features, data necessary to process your generation request is transmitted to external AI model providers, such as fal.ai, located in the United States.

By registering for and using the Application, you consent to the transfer of information to the United States or to any other country in which SNOW, its affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

10. Security

SNOW cannot fully ensure the security of any information you transmit to the NELD Application or guarantee that information on the Application may not be accessed, disclosed, altered, or destroyed. You are responsible for maintaining the secrecy of your unique password and account information at all times. Your privacy settings may also be affected by changes that the social media services you connect to SNOW make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

11. External Links

The Application may contain links to third-party sites or online services. We are not responsible for the practices of such third parties, whose information practices are subject to their own policies and procedures, not to this Privacy Policy.

12. California Consumer Privacy Rights

If you are a California resident, you have rights under the California Consumer Privacy Act of 2018 (CCPA), as applicable, to exercise free of charge. For more information, see the California Consumer Privacy Statement at the end of this Privacy Policy.

13. Do Not Track

Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not currently respond to DNT signals.

14. Changes to Our Privacy Policy

SNOW may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you additional forms or notice of modifications or updates as appropriate under the circumstances. Your continued use of the Application after any modification to this Privacy Policy will constitute your acceptance of such modification.

15. How to Contact Us

If you have questions or concerns about NELD’s Privacy Policy or to submit a request for information, please contact us at dl_neld@snowcorp.com.

California Consumer Privacy Statement

Effective on the date the Service is officially launched.

This California Consumer Privacy Statement supplements the NELD Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). This Statement does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

• Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, Internet Protocol address, email address, account name, and other similar identifiers
• Protected Classifications: characteristics of protected classifications under California or federal law, such as age and gender. Users are not asked to provide this information to use the Application.
• Commercial Information: commercial information, including records of products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies.
• Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
• Geolocation Data: physical location or movements
• Sensory Information: audio, electronic, visual, and similar information
• Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
• Sensitive Personal Information: personal information that reveals a consumer’s:
  • account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account;
  • precise geolocation

We may use the categories of personal information listed above for the purposes described in the NELD Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

2. Our Prior Collection, Use, and Disclosure of Personal Information

As of the effective date of this Policy, we may collect, use, and share your personal information as described in Section 1. The 12-month disclosure required by the CCPA will be incorporated into this section once 12 months have elapsed from the effective date of this Policy.

Sources of Personal Information

We may obtain personal information about you from a variety of sources, as described below.

Sharing of Personal Information

We may share your personal information with certain categories of third parties, as described below.

Sale of Personal Information

We do not sell personal information and have not sold personal information. We do not use third-party advertising networks to display interest-based advertisements on our website, and we do not allow third-party advertising platforms to collect behavioral information about you through our Services. We do not sell the personal information of minors we actually know to be under 16 years of age.

Disclosure of Personal Information for a Business Purpose

We may disclose the following categories of personal information to third parties for business purposes:

• Identifiers
• Online Activity
• Sensory Information
• Inferences

3. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Right to Know: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months. Once we receive your request and confirm your identity, we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Right to Correct: You have the right to request that we correct inaccurate personal information that we maintain about you. Upon receipt of your verifiable consumer request, we will use commercially reasonable efforts to verify the accuracy of the personal information at issue, and may request documentation supporting the basis for the correction. If we determine that the information is inaccurate, we will correct it and, where feasible, instruct our service providers and contractors that maintain the same information to do the same.

Right to Delete: You have the right to request that we delete certain personal information we have collected from you. Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et 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.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Right to Opt Out of Sale: You have the right to opt out of the sale of your personal information. As described above, we do not sell personal information and have not sold personal information, and we do not sell the personal information of consumers we actually know are less than 16 years old. If you nevertheless wish to submit an opt-out request regarding the sale of your personal information, please email us at dl_neld@snowcorp.com.

Please note that opting out of interest-based advertising will not block general advertisements that are sent at random and not tied to the perceived interest of the User of a particular device.

You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

You may learn more about personalized and behavioral advertising and how to opt out of this type of advertising from the Digital Advertising Alliance at www.aboutads.info and Networking Advertising Initiative at www.networkadvertising.org/choices/.

How to Submit a Request to Know or Delete: To exercise your rights to know or delete described above, email us at dl_neld@snowcorp.com. Your request to know or delete must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Only you, or someone legally authorized to act on your behalf (an “authorized agent”), may make a request to know, delete, or correct related to your personal information. To designate an authorized agent, please provide us with your contact information, the contact information of your authorized agent, and a description of how and when your authorized agent will be reaching out to us (to the extent known).

We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please email us at dl_neld@snowcorp.com.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact dl_neld@snowcorp.com to request this Statement in an alternative format.