PRIVACY POLICY

 

Last Updated: December 23, 2022 

 

This Privacy policy ("Policy") governs the access to and use of all parts of the website and mobile application branded as NEO Dash / NEO X and referring to the domain https:// www.myneodash.com en (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 Dash / NEO X Operators. Please take a moment to read this Privacy Policy along with the Cookies Policy carefully, and note that by using NEO Dash / NEO X, 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 

  1. PURPOSE OF THIS POLICY 
  2. DEFINITIONS 
  3. ACCEPTANCE 
  4. THE PERSONAL DATA NEO Dash / NEO X COLLECTS FROM USERS 
  5. WHY USERS' PERSONAL DATA IS USED?  
  6. DATA TRANSFER 
  7. PROTECTION AND STORAGE OF PERSONAL DATA 
  8. DATA RETENTION 
  9. PROTECTION AND STORAGE OF PERSONAL DATA 
  10. YOUR RIGHTS PROTECTED UNDER THE GENERAL DATA PROTECTION REGULATION 
  11. PRIVACY TERMS IN USING DIGITAL ASSETS AND BLOCKCHAIN 
  12. MODIFICATIONS 
  13. CONTACT INFORMATION 

1. PURPOSE OF THIS POLICY 

We at NEO Dash / NEO X 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 Dash / NEO X collects, processes and manages Users' personal data through the Website and/or App, that are developed to offer NEO Dash / NEO X services. 

 

2. DEFINITIONS 

"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 Dash / NEO X 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 programme, or a combination of both, or any equipment or a programme, 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). 

 

3. ACCEPTANCE 

By accessing and using NEO Dash / NEO X, 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. 

 

4. THE PERSONAL DATA NEO Dash / NEO X COLLECTS FROM USERS Your Personal data is collected and stored with NEO Dash / NEO X in order to provide, develop and to enhance our products and services including technical infrastructure, security, compliance, fraud prevention and customer support. We are committed to exercise due diligence when dealing with every User and in the course of conducting business, we ensure that it is able to comply with all the applicable Laws and regulations that require to prevent the facilitation of money laundering and terrorist financing. NEO Dash / NEO X collects Users' information according to the different tier levels by which each tier will correspond to the amount of Know Your Client [KYC] verifications undergone by each User in the onboarding process. 

 

The personal data we collect from NEO Dash / NEO X Users are; 

If Retail Users; 

Full name 

Date of Birth 

Email 

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 Dash / NEO X 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 

 

5. WHY USERS ' PERSONAL DATA IS USED? 

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 Dash / NEO X 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 

 

 

6. DATA TRANSFER 

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 Dash / NEO X is obliged to share the User's personal information with the applicable regulatory bodies. 

With third party KYC/AML service providers of NEO Dash / NEO X to identity verification services in User onboarding process and in ongoing transaction monitoring process. 

 

NEO Dash / NEO X 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 Dash / NEO X 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 Dash / NEO X 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.

 

7. PROTECTION AND STORAGE OF PERSONAL DATA 

NEO Dash / NEO X 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 Dash / NEO X shall notify a security alert to confirm and ensure the protection of the User's account. NEO Dash / NEO X 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 Dash / NEO X insists the Users to notify the Customer support immediately. Furthermore, NEO Dash / NEO X 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. 

 

8. DATA RETENTION 

NEO Dash / NEO X 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 Dash / NEO X 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. 

 

9. GENERAL DATA PROTECTIONS REGULATIONS OF EU 

The NEO Dash / NEO X 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 Dash / NEO X will be liable for any violation of its privacy and security standards, with penalties. According to the GDPR, NEO Dash / NEO X 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. 

 

10. YOUR RIGHTS PROTECTED UNDER THE GENERAL DATA PROTECTION REGULATION Under certain circumstances, you have rights under data protection laws in relation to your personal data which are set out in more detail below 

 

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 continuing 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 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 consent for us to use or where we used the information to perform a contract with you. 

 

11. PRIVACY TERMS IN USING DIGITAL ASSETS AND BLOCKCHAIN 

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.