PRIVACY POLICY
Last Updated: February 28, 2024
This Privacy policy ("Policy") governs the access to and use of all parts of the website and mobile application branded as NEO ONE and referring to the domain https:// www.myneoone.com (hereinafter referred as the "Website" "App") and all documents, data, materials or other information made available on the Website and/or App.
This Policy applies to all platforms, websites and/or App and NEO ONE Operators. Please take a moment to read this Privacy Policy along with the Cookies Policy carefully, and note that by using NEO ONE, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Policy.
This Policy applies to all visitors, users and others who access or use the Website and/ or App.
This Policy may be made available in several languages; all versions are legally binding, but in the event of inconsistency between the English version and a translated version, the English version prevails.
CONTENT
10.YOUR RIGHTS PROTECTED UNDER THE GENERAL DATA PROTECTION REGULATION
11.PRIVACY TERMS IN USING DIGITAL ASSETS AND BLOCKCHAIN
12.MODIFICATIONS
13.CONTACT INFORMATION
We at NEO ONE know and understand how important it is for you to understand how we collect, store, process, share and use your personal data. We respect and protect the privacy of our Users' personal data in our platform.
The purpose of this Policy is to describe how NEO ONE collects, processes and manages Users' personal data through the Website and/or App, that are developed to offer NEO ONE services.
"Personal data" means any information in respect of commercial transactions, which is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose; is recorded with the intention that it should wholly or partly be processed by means of such equipment; or is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system, that relates directly or indirectly to a data subject, who is identified or identifiable from that information, or from that and other information in the possession of a data User, including any sensitive personal data and expression of opinion about the data subject;
"User(s)" means any legal person who has attained the age of 18 with legal capacity who successfully creates an account in NEO ONE and successfully completes and passes their Know Your Client("KYC").
" Document(s)" includes any medium in which data is recorded, whether printed, or on tape, or film or by electronic means, or otherwise; map, diagram, photograph, film, microfilm, video-tape, sound recording, or machine-readable record; any record which is capable of being produced from a machine-readable record by means of equipment or a program, or a combination of both, or any equipment or a program, or a combination of both, and is used for that purpose by the public body or private body which holds the record;
"PEP" means a Politically Exposed Person refers to a natural person (and includes where relevant, a family member or close associate) who is or has been entrusted with a prominent public function, including but not limited to, a head of state or government, senior government or an important political party official (all full comprehensive definition for PEP is provided further under BVI's Anti Money Laundering [AML] and Sanctions Rules and Guidance).
By accessing and using NEO ONE, you are consenting and accepting the terms of this Policy. If you do not agree or consent with the details we require with any aspect of this Policy, you shall at any time withdraw your consent and discontinue access or use of our services.
The personal data we collect from NEO ONE Users are;
If Retail Users;
Full name
Date of Birth
Address
Gender
Residence Address
Nationality
Country Code
Telephone number
Employment
Status
Nature of the employment
Employer details
Government issued Identity or Driving License
Passport details
Proof of Residences
Salary Certificate
Source of Fund
Sanction list & PEP questionnaire
Audio or video recordings
If Corporate Users;
Company name
Country of Incorporation
Country of Operation
Authorized Person's Details
Ultimate Beneficial Owner Details
A copy of Certificate of Incorporation
Source of Funds Verification documents
UBO structure
A letter of authorization issued to individual performing on behalf of entity
Sanction list & PEP Questionnaire
Passport copies of all directors & Shareholders
Valid Trade License
Memorandum of Association
Article of Association
Registered Address
Audited financial Statement
UBO Proof of address
Audio or video recordings
Automated information stored by NEO ONE are;
Browser Information
IP Address
Login information
Browser type and version
Time zone setting
Platform
Operating System
Transaction history
Pages accessed and links clicked
Public blockchain data
Log information
Device- specific information
Location
System activity
Uniform Resource Locators [URL]
Data collected via Cookies
To communicate with User
To comply with legal and regulatory compliance
To detect and prevent frauds and credit risks
To provide, troubleshoot and improve NEO ONE Services
To enforce our terms in our User agreement
To provide customer services
To ensure quality control
To ensure network and information security
To enhance and personalize User experience
To facilitate corporate acquisitions, mergers or transactions
To engage in marketing activities
For Transaction services
Purposes for which we seek User's consent
We process the customer’s data upon the instructions of selected third parties, including business suppliers, distributors, card issuers and subcontractors. We act as a data processor, but upon processing any additional customer’s data, we act as a data controller. We share your personal data with selected third parties when it is necessary for the delivery of our services, or when there is a legal basis to do so. The aforementioned third parties only collect, use and disclose your information in the ways indicated by us in order to provide adequate services.
We further ensure that we comply with the applicable data protection legal norms and we shall only share information in the following circumstances: With applicable regulatory bodies of Estonia.
In the event of suspicious activities or transactions such as any fraud, tax, money laundering or terrorist financing activities, NEO ONE is obliged to share the User's personal information with the applicable regulatory bodies.
With third party KYC/AML service providers of NEO ONE to identity verification services in User onboarding process and in ongoing transaction monitoring process.
NEO ONE intends to uphold and implement the strictest standards of compliance, security and transparency in its operation, starting with detailed verification of onboard Users and operates transaction monitoring system to trace the nature of the virtual asset wallet to which each of our Users is sending to or receiving from, therefore NEO ONE acquires the User's information via third party KYC/AML service providers to provide streamlined verification process for individuals and companies with global coverage, configurable verification rules, detailed and case management tools along with PEP database screening, financial crime screening, legality of assets verification and due diligence services.
With service providers under contracts to operate the business.
Example of the types of services providers other than mentioned in the Article 8 (ii)
We transfer only the minimum amount of data necessary for a particular outsourced service provider(s) and we only cooperate with the outsourced service providers who can provide and ensure adequate level of personal data protection.
With our affiliates/ business partners as a general part of conducting business to offer services, with financial Institution which we partner to process payments you have authorized, NEO ONE ensures that the service providers and affiliates/ business partners who process personal information to acknowledge the confidentiality of this information and to protect the User's right to privacy by complying with all applicable privacy and data protection laws.
NEO ONE maintains physical, technical, administrative and procedural safeguards in connection with the collections, storage and disclosure of User's personal data. We use firewall barriers, encryption techniques and authentication procedures to maintain the security of User's online sessions. In the event of a User signing in his/her account on different devices, NEO ONE shall notify a security alert to confirm and ensure the protection of the User's account. NEO ONE Users are requested to protect their account password from unauthorized access to avoid unnecessary authentication issues. In order to circumvent loss, misuse, unauthorized acquisition or alteration of your data, Users are requested to choose the strongest password and to protect the account privacy data from any third-parties. In the event of unauthorized access, the NEO ONE insists the Users to notify the Customer support immediately. Furthermore, NEO ONE does not ensure the security or privacy of data transmitted via email, phone or SMS, till such data reaches the domain of our network, since we have no access to protect such data until it reaches our network domain.
NEO ONE third party services providers shall keep the original or a true copy of all KYC Documents, data and information it receives from Users in a readily retrievable format for five [5] years. When an investigation into a suspicious User or a suspicious transaction has been initiated and in the event of proceeding the investigation in respect of the User, NEO ONE third party services providers shall not destroy any relevant records even though the prescribed period for retention shall have elapsed by the reporting authority, for the reason that we are subjected to certain anti-money laundering laws. Furthermore, information or data collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from the expiry of the Cookie policy.
The NEO ONE is obliged and bound by the General Data Protection Regulation [GDPR], which is drafted and passed by the European Union to regulate and protect the data of EU citizens. This regulation came into effect on May 25, 2018, and NEO ONE will be liable for any violation of its privacy and security standards, with penalties. According to the GDPR, NEO ONE provides privacy notice, in a concise, transparent, intelligible and easily accessible form, written in clear and plain language, delivered in a timely manner; and provided free of charge.
Request access
This enables you to receive copies of your personal data. We hold about you and to check that we are lawfully processing it. This is also commonly known as a "data subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure
This enables you to request us to delete or remove personal data where there is no good reason for us to continue to process it. Please note that there may be circumstances where we may be legally entitled to retain your personal data.
Request to Restrict Processing
This enables you to object to the processing of your personal data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your personal data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
Request to Object Processing
You have the right to object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object to where we are processing your personal data for direct marketing purposes.
Request to transfer
If you request us, we will provide you or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided with your consent for us to use or where we used the information to perform a contract with you.
The digital assets are recorded on a public blockchain. It is a ledger which means a chain of blocks where each block contains the recording of any data transmission.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
If you have questions or comments about this notice, you may email us at [email protected] or contact us by post at:
MM Bitinvest OÜ
Narva mnt 5, Harju maakond, Tallinn
10117, Estonia