Privacy Policy
Your privacy is important to us. The personal information Neo Billing Technologies Inc. and its affiliates (collectively “Neo”, “us” and “we”) collects about you is managed in accordance with this Privacy Policy (“Policy”).
Privacy Commitment and Personal Information
We collect, use and disclose personal information to operate our business and as permitted or required by law. Personal information is information about an identifiable individual, as defined in the Federal Personal Information Protection and Electronic Documents Act and in any applicable provincial legislation, such as the Alberta Personal Information Protection Act, the British Columbia Personal Information Protection Act, and the Quebec Act Respecting the Protection of Personal Information in the Private Sector.
Changes to Privacy Policy
This Policy describes our current privacy practices. We update this Policy on an ongoing basis to ensure consumers, applicants, customers, third-party program merchants, and service providers, are aware of updates to our privacy practices, to streamline those practices and to comply with applicable laws. Consumers are individuals who are not currently our customers; applicants are individuals who apply to become our customers; and customers are individuals who have been approved, use or have used our products and services in the past. Please visit this site regularly for updates. We will also notify individuals with whom we have a relationship of any material changes that may impact them.
Accountability
Our Privacy Officer is responsible for ensuring that we comply with this Policy and applicable privacy laws. We are responsible for personal information in our possession or custody, as well as personal information transferred to a third party for processing. More details on our third parties are provided below under “Limiting Use, Disclosure and Retention”.
Information We Collect, and Limiting Collection
Except where information is required to fulfill an identified purpose or as required by law, you get to decide what information you want to share with us.
Contact information and marketing preferences.
We may collect information you provide, such as your name, phone number, address, city, email address, and marketing preferences if you visit or use our website or mobile application, register or apply for one of our products or services, interact with us through social media or online ads, participate in surveys, or engage with us in any way.
Identity information.
If you apply or sign up for one of our products or services, depending on the product or service, we may collect identity information about you, including your name, date of birth, contact details, identification information, employment and occupation details, tax residency details, living situation, intended purpose of account, account objectives, risk capacity, funds time horizon, and financial information. If you give us your Social Insurance Number (SIN), we may use it for tax reporting. When you provide contact or identity information for another person or an authorized user, we expect that you have the authority to consent to its collection, use, and disclosure as outlined in this Policy. With your consent, we may also collect biometric information including an image of your government-issued identification (either driver’s license, passport, or other government-issued photo identification card) as well as a real-time image (i.e. a “selfie”) that you provide for the purposes of helping to verify your identity, preventing fraud, and complying with applicable legal and regulatory obligations, including those relating to money laundering, terrorist financing and financial dealings with certain sanctioned individuals. On an optional basis and with a compatible device, you may also choose to use a fingerprint or facial recognition system to access your account (e.g., Face ID or TouchID on the iOS platform). If you choose to use such a feature, the biometric information associated with this feature will be stored and processed locally on your device, and we do not collect or have access to this information.
Financial information.
We may collect financial information that allows us to determine creditworthiness or eligibility for or appropriateness of products or services, such as income, employment history, net worth, credit reports and information from security provided for loans. We may collect and share information with credit reporting agencies and other outside sources to verify financial information about you, such as your employment and credit history. Information used to assess your creditworthiness may include: credit reporting agency data, income data, employment data, living situation, and housing costs.
Online information.
We may collect information from your mobile and online activity; for example, information about your web browser, time zone, Internet Protocol (IP) address, mobile device ID, application and website use, and history. Cookies (small computer files that a website’s server places on your computer) collect information about your online behaviour. You can set your browser to reject cookies, but this may impair our ability to customize and test your experience, like remembering your preferred language or present location-specific information to you. If you visit the JA Knowledge Hub, we will share anonymized geographic data with the literacy content partner.
Transaction information.
If you sign up for one of our products or services, depending on the product or service, we may collect information about your transactions, including purchases, account balances, fees, payment history, parties to transactions, card usage, account usage, and rewards redemption. If you consent and provide account details for card or bank accounts with other providers, we may also collect and store transaction information from these accounts.
Counterparty information.
If you add authorized users or contacts to your account, we will collect and store their name, email address, and phone number. If you add business contacts to your account, we will collect and store the business name, nickname, and your account number with them.
Usage information.
If you sign up for one of our products or services, depending on the product or service, we may collect information regarding the use of our website and mobile application, including screens visited and in-app behavior in order to monitor and improve the app.
Security credentials. If you create an account or sign up for one of our products or services, depending on the product or service, we may collect and store security credentials including your username, password, security questions, and card personal identification number.
Communication information.
When you have a telephone or online chat conversation with one of our representatives, your call and chat may be recorded for quality and training purposes, as well as to resolve concerns. If you choose to contact us by email or mail, we may retain your email or mailing address, the content of your communication and our responses.Security credentials. If you create an account or sign up for one of our products or services, depending on the product or service, we may collect and store security credentials including your username, password, security questions, and card personal identification number.
Third party information.
We may collect information about you from third parties that we have contracted with, such as credit reporting agencies or affiliates. We may collect publicly available information about you from online sources, or from surveys that you participate in. You may also enter into various services, agreements and reward and loyalty programs operated by third parties. The privacy policies of such third parties will apply to such transactions with third parties, and not this Policy.
- Identifying Purposes
We will clearly identify the purposes for which personal information is collected, used or disclosed prior to, or at the time of, collection, and as stated in our customer agreements and disclosures.
Rewards and Store.
We may use your security credentials, contact, identity, online, usage and transaction information to identify you on our third-party platforms you already use (such as Neo’s partnered merchant platforms) to attribute rewards redemptions to your respective third-party account. We may also use this information to open, maintain, service, process, analyse, market, audit, collect or fulfil products or packages related to Neo Billing.
Safeguards
We use procedures and practices appropriate to the sensitivity of personal information to protect against loss, theft and unauthorized access. Access to your information is restricted to those individuals and parties who require access.