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Neoma Ltd. ("Neoma" or "we" or "us" or "our" or other similar pronouns) takes your privacy matters very seriously. Please read the following to learn more about our Privacy Policy ("Policy"). This Policy details how we receive, collect and use information in connection with our website located at Neoma.hk (the "Site"), the Neoma Software Development Kit software (the "Neoma SDK"), and other products and services provided on our platform (all of the foregoing, collectively, the "Services").
By visiting this Site or using the Services, you are accepting the policies and practices described in this Policy, as such Policy may be amended from time to time. Each time you visit the Site or use the Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy.
1. Collection of Information
Non-Personally Identifiable Information
When you sign up for your Account on the mobile application of our client (the Application) or use our Services (either on your mobile phone/device or other devices), our servers may (i) automatically record information that your mobile phone/device sends or transmits, including your device type, your device ID number (for example, your UDID), user settings, your location and information about your use of the Services such as offers viewed and/or used, stores visited, information you entered in the Application, (ii) record which search terms you used, or which referring/exit pages brought you to our page, and date/time information, (iii) record certain non-personally identifying information record information provided by you, such as your gender or age, (iv) record, determine or use information from another content delivery platform, and (v) record information derived from such above information and other sources such as entries and offers viewed on the website of our clients or on their social media presence, or information provided by Affiliated Partners (collectively, “Non-Personally Identifiable Information”).
Personal Information You May Provide To Us
When you use our Services, we may ask that you provide us with some personally identifiable information - information about you that can be used to contact or identify you, and information on your use or potential use of the Services and related services (“Personal Information”). Personal Information that we might collect may include, but is not limited to, your name, mobile phone number, email address, nationality, hometown, country, and if you choose to provide your photograph. Personal Information may also include other information you supply to us concerning your preferences and interests expressed in the course of using our Services.
Information About You We May Obtain Through Other Sources
We may also use additional methods to collect your Personal Information when you are physically visiting the location of our clients or Affiliated Partners, when based on presence location data gleaned from a mobile device with your Neoma user ID active. If you do not wish to have your Personal Information collected by these methods, you may not be able to earn and redeem rewards or other as part of the Services.
The Application and Services include geolocation and location presence awareness technology and functionality intended to make the Application useful at the particular location it is being used. For example, the Application may offer rewards points based on presence in a particular location, provide a reminder of items previously liked on the Application, or show the highest-rated deals at a store. To offer those benefits, we must of course be able to determine that the Application is being used in a particular store or other location. To do that, we may use the signal of our “Neoma Beacon” presence technology devices which are located in various locations. Those devices broadcast signals that can be received by a phone on which the Application is installed. When the phone receives the Neoma Beacon signal, if consent has been provided to receive notifications from the Application in settings (please see our Terms of Services), we may send a message (text, image, audio file, etc.) through the Application. Thus, Neoma Beacon can send a welcome message after entering a particular location and show location-specific rewards, discounts, coupons and recommendations. To make the Application and Services better operate, consistent with the other terms of this Privacy Policy, Neoma may also collect other information based on Neoma Beacon signals, for example, the strength of the signal between the Neoma Beacon and the phone, the duration the phone is near the Neoma Beacon, or the battery level of the Neoma Beacon itself, including when the Application is in the background or not running. To avoid geolocation data from being used or received by Neoma while the Application is in the background or not currently running on the phone, it is possible to opt-out in the Settings of the Application at any time. Please rest assured that any use of Neoma Beacon and other geolocation and presence technology innovations in the Application or Services are intended to ensure the best, most interactive and valuable experience.
We may also receive Personal Information from Affiliated Partners provided by you in the course of your use of their services, or from third parties, subject to the limitations of the Privacy Policies of those Affiliated Partners or third parties.
Information About Transactions at Affiliated Partners
To provide you with further potential rewards and/or offers from certain Affiliated Partners, we may receive information about transactions that you make at an Affiliated Partner including the Affiliated Partner name, the location, the date and time, the transaction amount, the purchased items and other personal information about you (“Transaction Data”), from payment processing vendors, from banks or from credit or debit card networks or issuers (“Transaction Providers”). Unless the privacy policy of the Affiliated Partner that you accepted already allows for this information sharing, we will ask for your permission (by your explicit opt-in) in order to receive this information. We will ask for your permission (“opt-in”) in case we need to share Personal Information with Transaction Providers to identify you to be able to receive the Transaction Data that determines whether offers or rewards apply to you.
2. Use of Information
The terms “using” and “processing” information, as used in this policy, include using cookies or other storage means on a computer or mobile device, subjecting the information to statistical or other analysis and collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our subsidiaries.
Personal Information
We use Personal Information only for the following purposes: (i) to administer the Services, (ii) to provide, improve and optimize the Services, (iii) to personalize your experience, (iv) to provide you with software updates and/or product announcements, (v) to better understand your needs and interests, and (vi) to provide you with further information and offers from the Application that we believe you may find useful or interesting, such as targeted Proximity Marketing campaigns. We may match data from your transactions with Affiliated Partners and/or the content information with our usage data in a personally identifiable form in order to perform accounting reconciliation and/or let our clients provide you with targeted offers and/or rewards or discounts; but to protect your privacy, our Affiliated Partners and Neoma will perform this matching in a protected environment that does not allow our Affiliated Partners to gain Personal Information you have not opted in to disclose to them.
Non-Personally Identifiable Information
Non-Personally Identifiable Information about users of the Application may be used for a few purposes, for example, to improve features and functionality of the Services and to make more relevant. We may analyze trends through aggregated demographic and psychographic offers to users. We may also share this Non-Personally Identifiable Information with our Affiliated Partners to allow them to deliver tailored information, advertisements, promotions, sweepstakes, discounts, and other incentives to you when you use the Services. Any information shared with Affiliated Partners in this context will not contain nor be linked to your Personal Information unless you have given us your explicit consent through an “opt-in” mechanism on the Application. For example, an Affiliated Partner may want to offer a discount on its products to a certain audience (for example, men ages 18-34) or audience segment (for example, women ages 25-40 who have viewed certain content). If the Non-Personally Identifiable Information that we have collected about you meets this description, you would be able to view and use the discount offered by the Affiliated Partner.
Use of Cookies
We may use “cookies” (a cookie is a small data file that is kept in your device’s memory for record-keeping purposes), and/or other storage on your device to help us collect, maintain, and use this information, for two purposes. First, to make the interactions easier and more personalized for you, we may utilize persistent cookies to save information relating to your Account and/or activity for future interactions with the Services. Second, to better understand how you interact with the Services and to monitor aggregate usage by Neoma users and web traffic routing on the Services, we utilize session ID cookies to enable certain features of the Services. Unlike persistent cookies, session cookies are deleted from your device when you log off from the Services. At any time, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. Please understand that if you do not accept cookies, you may not be able to use all portions or all functionality of the Services.
Usage Patterns
We may also use data collection tags or directives such as JavaScript scripts, API calls, or similar means (individually or collectively, “Usage Tracking”) in combination with cookies and the demographic or psychographic data we have collected, and with third-party analysis partners, to analyze usage patterns of users anonymously and to serve advertisements to you that are tailored based on our analysis of what we believe you would respond favorably to in light of the information that we have collected or accessed about you as described above. Usage Tracking allows us to count users who have visited our Site or used the Application of our clients, to analyze their behavior in order to improve the Site and the Application and to personalize and determine the effectiveness of Proximity Marketing campaigns.
Analytics
Neoma uses Google Analytics to help us anonymously track and report user/visitor behavior information and users' standard log information to the Site and the Neoma SDK. This information (including but not limited to: IP address, data storage, maintenance services, database management, web analytics and information processing) helps us analyze and evaluate how the Neoma SDK and Site are used as part of our ongoing efforts to improve the Site and Neoma SDK’s features and services. No personally identifying data is included in this type of reporting. Google Analytics may have access to your information only for the purposes of performing these tasks and on behalf of Neoma and under obligation similar in those in this Privacy Policy. For more information about the terms that govern Google Analytics, please visit the Google Analytics terms of service.
We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personal Information of visitors or users. Google will not associate your IP address with any other data held by Google. Neither we nor Google will link, or seek to link, an IP address with the identity of a device user. We will not associate any data gathered from this site with any Personally Identifiable Information from any source, unless you explicitly submit that information on our website.
3. Sharing and Disclosure of Information
We do not rent, sell, or share any Personal Information about users of the Application with any third-party, except as specifically described herein. We may disclose your Personal Information if we believe such action is necessary to:
- (a) comply with the law, or legal process served on us;
- (b) protect and defend our rights or property (including the enforcement of our agreements); or
- (c) act in urgent circumstances to protect the personal safety of users of our Services or members of the public.
In order to provide you with Neoma products you have requested, Neoma may, if necessary, share your Personal Information (excluding your address book and related information) and traffic data with trusted partner service providers and/or agents, for example: providers of payment and analytical services, customer support or hosting services. Neoma will always require these third parties to take appropriate organizational and technical measures to protect your personal data and traffic data and to observe the relevant legislation. Neoma will never share your address book information with any third party, except as may be required by law (see below).
We may share your Personal Information with trusted third-party partners. Should we add any partner, we will immediately update this description.
Notwithstanding any of the foregoing, the Neoma servers that are used to store your Personal Information are owned and hosted by Google App Engine, by Google Company. You can read more about measures taken by Google App Engine which is governed by Google’s General Privacy Policy to protect the security of their servers and your Personal Information here: http://www.google.com/intl/en/policies/privacy/
We may from time to time ask you to provide information about your experiences, which will be used to measure and improve quality. You are at no time under any obligation to provide any of such data. Any and all information which is voluntarily submitted in feedback forms on the Site or any survey that you accept to take part in is used for the purposes of reviewing this feedback and improving the Neoma software, products and website.
We may contact you to send you messages about faults and service issues. Furthermore, we reserve the right to use email to notify you of any eventual claims related to your use of our software, websites and/or products, including without limitation claims of violation of third party rights.
4. Children's Privacy
Neoma websites and software clients are not intended for or designed to attract anyone under the age of 13 and we do not intentionally or knowingly collect Personal Information on our sites from anyone under the age of 13 (or older in some jurisdictions). We encourage parents to be involved in the online activities of their children to ensure that no information is collected from a child without parental permission. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, please contact us. If we become aware that a member is under the age of 13 and has provided us with Personal Information without verifiable parental consent, we will delete such information from our files.
5. Security
We take reasonable precaution to protect Personal Information from misuse, loss and unauthorized access. Although we cannot guarantee that Personal Information will not be subject to unauthorized access, we have physical, electronic, and procedural safeguards in place to protect Personal Information. Personal Information is stored on our servers and protected by secured networks to which access is limited to a few authorized employees and personnel. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. In addition, we will delete information after it is no longer useful for providing the Services.
We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
6. Business Transitions
In the event that we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, Personal Information will likely be among the assets transferred. As part of such a transaction the new entity will be required to commit to the same level of protection of your Personal Information as described in this Privacy Policy. If we cannot obtain such a commitment, we will not perform the business transition.
We will post a notice on this Site of any such change in ownership or control of the Personal Information we may have prior to such transfer.
7. Changes to Policy
From time to time, we may revise this Policy. We reserve the right to update or modify this Policy, or any other of our policies or practices, at any time with or without notice. However, we will not use your Personal Information in a way that is materially different than the uses described in this Policy without giving you an opportunity to opt-out of such differing uses. We will post the revised Policy on the Site, so that users can always be aware of what information we collect, how the information is used and under what circumstances such information may be disclosed. You agree to review the Policy periodically so that you are aware of any modifications. Your continued use of the Site and the Application indicates your assent to any changes and signifies your agreement to the terms of our Policy. If you do not agree with these terms, you should not use the Site, the Application, or any other Service.
8. Change or Removal of Information
You may review, update, correct or delete your Personal Information in your registration profile by making the appropriate modifications in your Profile settings. If you would like us to delete your Account and/or remove your records from our system, please contact us and we will delete your account within 45 days if we do not have any legal obligation to retain the record.
If you have additional concerns and/or requests, you can contact Neoma at support@neoma.hk.
9. Contact Information
Please direct all questions in connection with this Policy via e-mail to privacy@neoma.hk or by writing to Neoma Ltd., Attention: Privacy Policy Administrator, 21/f, on hing building, 1 on hing terrace, Central, Hong Kong.