Last Updated: November 21, 2022
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.
1. PURPOSE OF THIS POLICY
4. THE PERSONAL DATA My NEO Group 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
13. CONTACT INFORMATION
PURPOSE OF THIS POLICY
We at My NEO Group 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 My NEO Group collects, processes and manages Users’ personal data through the Website and/or App, that are developed to offer My NEO Group 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 My NEO Group 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).
By accessing and using My NEO Group, 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 My NEO Group COLLECTS FROM USERS
Your Personal data is collected and stored with My NEO Group 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.
My NEO Group 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 My NEO Group Users are;
If Retail Users;
Date of Birth
Nature of the employment
Government issued Identity or Driving License
Proof of Residences
Source of Fund
Sanction list & PEP questionnaire
Audio or video recordings
If Corporate Users;
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
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
Audited financial Statement
UBO Proof of address
Audio or video recordings
Automated information stored by My NEO Group are;
Browser type and version
Time zone setting
Pages accessed and links clicked
Public blockchain data
Device- specific information
Uniform Resource Locators [URL]
Data collected via Cookies
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 My NEO Group 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 may share your personal data with selected third parties, including business suppliers, distributors and subcontractors, 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 British Virgin Island
In the event of suspicious activities or transactions such as any fraud, tax, money laundering or terrorist financing activities, My NEO Group is obliged to share the User’s personal information with the applicable regulatory bodies.
With third party KYC/AML service providers of My NEO Group to identity verification services in User onboarding process and in ongoing transaction monitoring process.
My NEO Group 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 My NEO Group 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
My NEO Group 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
PROTECTION AND STORAGE OF PERSONAL DATA
My NEO Group 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, My NEO Group shall notify a security alert to confirm and ensure the protection of the User’s account.
My NEO Group 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 My NEO Group insists the Users to notify the Customer support immediately.
Furthermore, My NEO Group 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.
My NEO Group shall keep the original or a true copy of all KYC Documents, data and information it receives from its User in a readily retrievable format for five  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, My NEO Group 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.
GENERAL DATA PROTECTIONS REGULATIONS OF EU
The My NEO Group 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 My NEO Group will be liable for any violation of its privacy and security standards, with penalties.
According to the GDPR, My NEO Group 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.
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
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.
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.
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. Blockchains are decentralized or third-party networks which are not controlled or operated by any third-party service provider or affiliates or business partners of My NEO Group, and we have no access or authority to erase, modify or alter any personal data from such networks.
We reserve the right, at our sole discretion, to modify, amend, supplement or replace this Policy at any time and such update details shall be indicated at the top of this page. We will review and revise this Policy when there are any material circumstances arise that may affect our ability to apply this Policy pursuant to the provisions of statutory and law requirements. What constitutes a material change will be determined at our sole discretion.
We will inform our Users of all material amendments to this Policy by publishing the updated version of this Policy on our Website and/or App. When an updated version of the Policy is released, your continued access to the Website and/or App means that you agree to the updated content and agree to abide by the updated Policy.
In the event of any comments, questions, inquiries, or complaints regarding this Policy, the User has the right to submit questions and/or concerns at firstname.lastname@example.org