Neo360 Ltd (“we”, “us”, “our”, ” Neo360 “), a company registered in England & Wales with company number 06686993.
We are committed to protecting and respecting your privacy. We are a data controller under UK law. This means we are responsible for determining the purposes for which and the manner in which the personal information provided through the Neo360 mobile application is processed.
Personal Information means information that identifies you personally such as your name, contact details, or data that can be linked with such information in order to identify you.
What does this policy relate to?
This policy applies to your use of the Neo360 mobile application software (“App”), from the site from which you downloaded the App (“Apple Appstore”), once you have downloaded the App onto your mobile or handheld device. This policy also applies to any of the services accessible through the App (“Services”).
This policy sets out the basis on which any personal information we collect from you, or that you provide to us or that is provided to us by other third parties will be processed by us. Please read this policy carefully to understand our practices regarding your personal information and how we will treat it.
What personal information does Neo360 collect?
Information you give us.
This is information you give us about you when filling in forms/screens on the App or registering for Services through Neo360, any interactions you undertake or services you request or source through Neo360 and via any health or monitoring device you connect to Neo360 or by corresponding with us by phone, e-mail or otherwise. It will be clear at the time what personal information we are requesting from you. If you do not provide the personal information necessary or withdraw your consent for the processing of your personal information, where this information is necessary for us to provide Neo360 services to you, we will not be able to provide these services to you. You don’t have to provide data and can simply choose to stop using the App at any time.
Information we collect about you and your device.
Each time you use Neo360 we automatically collect the following information:
technical information, including the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, and time zone setting;
information either accessed through your device or stored on your device which you have explicitly consented to sharing, and the providence of that data including the device used to collect that data, time, date; and details of your use of Neo360.
How does Neo360 use your personal information?
We DO NOT use your data for marketing purposes.
Any personal information you submit through Neo360 is generally required for providing the services to you. However, we may rely on other lawful basis for using your personal information. Specifically, we use information held about you in the following ways:
To provide services to you or where we have a contract with you
- To register you for the Neo360 App and Services and manage your account and for our own internal administrative purposes.
- To provide you with the Neo360 App and Services and to ensure that Neo360 presents the correct version and data for your device.
- To update you on any developments or information about the Neo360 App and Services. These are strictly service emails and do not include marketing.
- To allow us to investigate and address queries, questions and complaints that affect your use of the Neo360 App and Services.
Where we have a legal obligation
To make disclosures as required by or in compliance with reasonable requests by regulatory bodies including the Information Commissioners Office, or as otherwise required by law or regulation.
Where it is in our legitimate interest
- To review and enhance the quality of our services and products through details of your use of the Neo360 App and Services. This is in our legitimate interest to ensure we continue to improve the services we provide to customers.
- To allow us respond to general enquiries and feedback from you. This is in our legitimate interest in providing a responsive service to customers.
- For internal operations, including troubleshooting, detection of fraud, log data analysis, testing, security, audit and statistical purposes. This is in our legitimate interest to protect our business interests and assess our business effectiveness.
When will Neo360 share your personal information?
We WILL NOT share any of your data with any third party organisation EVER.
How does Neo360 store your personal information?
We will store your personal information at our secure data centre which is located within Canada. We do not transfer your personal information outside of Canada. All data is encrypted when being transferred to and from your device to Neo360 or to our data centre. It is your responsibility to keep any passwords or pin codes used to access Neo360 confidential.
We take all steps reasonably necessary to ensure that your data is treated securely through strict procedures and security features to prevent unauthorised access to your personal information. However, we cannot guarantee the secure transmission of information via the internet due to security threats outside our control and as such, any transmission of information is at your own risk.
How long does Neo360 store your personal information?
We will retain your personal information for as long as needed to fulfil the purposes outlined in the ‘How does Neo360 use your personal information?’ section above or for a period specifically required by applicable regulations or laws. For example, we generally keep your personal information for as long as you remain a registered user of the App.
When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligation(s) under applicable law to retain data for a certain period of time;
- statute of limitations under applicable law(s);
- our legitimate interests where we have carried out balancing tests (see section on ‘How do we use your information above);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
Otherwise, when requested we securely erase or anonymise your personal information where you cease to be a user of the App and we no longer require your information for the purposes collected.
What about third party sites?
Neo360 DOES NOT link to third party sites EVER.
What rights do you have?
By law, you have a number of rights, subject to certain conditions, when it comes to your information. Further information and advice about your rights can be obtained from the data protection regulator in your country. You can exercise any of these rights by contacting us through our details below.
|Rights||What does this mean?|
|The right to object to processing||You have the right to object to certain types of processing, including processing where we rely on our legitimate interest as a ground for processing.|
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
|The right to rectification||You are entitled to have your information corrected if it is inaccurate or incomplete.|
|The right to erasure||This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your information where there is no compelling reason for us to keep using it. This is not a general right to erasure, there are exceptions.|
|The right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|The right to data portability||You have rights to obtain and reuse your information for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.|
|The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your information with your national data protection regulator.|
|The right to withdraw consent||If you have given your consent to anything we do with your information, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your information with your consent up to that point is unlawful). Note that such withdrawal in certain circumstance may mean we can no longer continue to provide the Services to you.|
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Alternatively, we may be entitled to refuse to act on the request.
Please consider your request responsibly before submitting it. We will respond as soon as we can. Generally, this will be within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.
If you have any questions, comments and requests regarding this Policy, please get in touch with us at: