Neo Privacy Policy

Neo Financial Technologies Inc., Neo Mortgage Services Inc. and their subsidiaries and affiliates (collectively “Neo”, “us” and “we”) value your privacy. We are committed to safeguarding your personal information. This Privacy Policy sets out our policies and procedures for the collection, use, retention, and disclosure of your personal information.

This Privacy Policy applies to the privacy practices of Neo on our website, located at https://www.neofinancial.com/ and any subdomains (the “Website”), our “Neo Financial” web and mobile application (the “App”, and together with the Website, the “Platform”), to Neo products and services including our Money, Credit, Invest, and Mortgage products (the “Products”) and to our other interactions with you.

Neo is accountable for the collection, use, and disclosure of your personal information.
Our Privacy Officer oversees the protection of your personal information and ensures our compliance with our Privacy Policy and applicable privacy laws. Please see the contact details for our Privacy Officer at the end of this Privacy Policy, in section 8.

What Information is in this Privacy Policy?

1. Personal Information We Collect

(a) Information You Provide to Us

• Identity information: your full name, email address, phone number, password, date of birth, mailing and home address and address history, employment and educational information, social insurance number (providing your SIN for identity verification purposes is optional), tax information, and identity documents.
• Financial information: your income information, information about your living situation, sources of income, credit information (including assets, liabilities, and payment information) account objectives, risk capacity, and investment timelines.
• Biometric information: images of yourself and your photo identification documents.
• Information about others: such as the full name, email address, and phone number of your spouse, family and household members, authorized users, or counterparties.
• Survey information: responses and data obtained through our surveys and client research.

(b) Information We Collect Automatically

• App and device data: type of device hardware and operating system, language settings, and the date and time the App accesses our servers, web browser, time zone, IP address, unique device identifier, your device’s GPS coordinates
• Usage data: search and Website history including cookie data, information regarding your use of the Platform, including your transactions, card and account usage, payment history and parties to transactions, and the Products that you use or are eligible for
• Analytics: we use web analytics services such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data)
• Rewards data: age of your rewards account and information regarding your rewards points balance. We collect the details of your purchase on third-party platforms you already use (such as Neo’s partnered merchant platforms)
• Additional Information: We will use commercially reasonable efforts, given the limitations imposed upon us by third party providers such as Apple and Google, to clearly disclose what, if any information is collected by the App, how it is used, and with whom it is shared. Please note, certain practices are outside of our control, for example, tracking by Google or Apple or your telecommunications carrier. We are not responsible for the actions of such third parties. You should always read and understand the policies of any third-party provider, such as Google with respect to Android apps and Apple with respect to iOS apps, and your telecommunications carrier, before making any purchase or downloading any app.

(c) Information We Collect from Third Parties

• Identity information: name, address, date of birth, phone number, device information from telecommunications providers
• Biometric information: identity service providers may collect biometric information (such as an image of your government-issued identification along with a real time image or video) to verify your identity; we collect the information from your identification (such as the ID number) and the final result of identity verification processes (i.e., verified or not verified)
• Screening information: results of anti-money laundering checks from sanctions and fraud screening providers
• Credit information: identity, financial, credit and transactional information from credit reporting agencies, such as TransUnion and/or Equifax
• Third party account information: financial institution name and numbers, account number, balance from accounts linked via Plaid or Flinks

2. How We Use Your Information

(a) Identity Verification

• To verify your identity and other information you have provided to us
• To complete a credit file identity verification
• To detect and prevent fraud

(b) Credit Verification

• To obtain additional credit, financial, personal and business information contained in your credit report for the purposes of verifying your creditworthiness. With your consent, we will run a credit check to help assess your eligibility for a credit card and the credit limits.
• To assess and manage our credit risks, establish credit and hold limits
• To qualify you for other products and services
• To assist in determining your ongoing creditworthiness, update our records, and help us determine your eligibility for other products and services (such as pre-approved credit products, credit limit increase, and other offers).
• To maintain accurate credit information within credit report agencies databases, we share credit information on an ongoing basis with credit reporting agencies

(c) Account and Product servicing

• To contact you by mail, email, SMS message (message and data rates apply), in-App messaging and telephone to respond to your question or comment.
• To deliver and improve the financial products and services you have with us, and provide you with relevant information about your application and/or account
• To administer and authenticate your access to your Neo profile, to enable you to access products and services, and to update you about changes to the Platform, and to market products and services to you in accordance with this Privacy Policy.
• To facilitate transactions from linked bank accounts
• To confirm which products and services are most suitable for you
• To train our personnel, and for quality assurance purposes.
• To open, maintain, service, process, analyze, market, audit, collect or fulfill products or packages related to Neo Rewards™, Neo Premium Rewards Package or the Neo Store.

(d) Legal and Regulatory

(e) Offers, marketing and advertising

• To contact you by mail, email, SMS message (message and data rates may apply), push notification, and telephone to update you on changes to the Products, send you important updates about financial account opening disclosures, and important or useful messages about your financial accounts.
• To provide you with personalized marketing communications. You can request that we not contact you for the purposes of advertising, marketing, promotions, rewards programs, research by updating your privacy preferences within the Platform.
• To provide you with location-based services, including information about nearby Neo Rewards partners.
• For more information, see section 4 - Your Choices.

(f) Analytics

• To service insights that inform decision-making, including but not limited to, introducing new features or products, changing or removing existing features or products, improved credit adjudication, risk and resource optimization, and to manage our business.
• To help us understand our clients and to enhance our product and service offerings.
• To evaluate existing products and services, develop new products and services, optimize our Website, perform analytics, and improve the client experience we offer.
• To evaluate and improve the user experience and the Website.
• To help us understand the activity on the App, to monitor and improve the App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-App experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
• For more information, see section 4 - Your Choices.

(g) Automated decision making

Personal Information We Process on Behalf of Third-Party Organizations

3. Sharing of Personal Information

(a) Service Providers

• Client support: to provide support services to clients that reach out to us with questions about Neo or our products or services, including our financial, co-brand, or third party partners, we may share identity, financial and credit information.
• Mortgage processing services: to administer your mortgage, including processing or servicing of mortgages, mortgage insurers, consumer reporting agencies, title custodian, and title insurance providers, we may share identity, financial, credit and biometric information.
• Fraud detection services: to monitor your transaction information and identify fraudulent activity, we may share identity, financial, and biometric information.
• Credit reporting agencies: to obtain information regarding your creditworthiness, where you have provided us with your consent to run a credit check, we may share identity information.
• Sanctions screening providers: to ensure that you are not a sanctioned person subject to prohibitions under applicable money laundering, terrorist financing or other regulatory restrictions, we may share identity information.
• Marketing and research companies: to understand and deliver products, services and offers that you, and others who are similar to you, may find useful or block offers you won’t find useful, we may share your app and device data, usage data and analytics, or anonymized and aggregated information to digital affiliates and companies like Google and Facebook.
• Collections and law firms: to help us collect a debt owed to us by you, we may share your identity, financial, and credit information, and information about others, with our external legal representatives and debt collection providers.
• Payment processing businesses: to process your transactions and payments, we may share identity, and financial information, and information about others.
• Print and plastic suppliers: to issue and service card products, we may share your identity and financial information with suppliers to print and send cards and statements.
• Referral program partners: to administer our rewards referral program we may share your full name and account status information (i.e. whether your application was completed).
• Neo Rewards/Store: to provide rewards, products, attribution and fulfillment, we may share your identity, financial, online, transaction, counterparty and third party information with certain third parties as part of Neo Rewards™, Premium Rewards Package and Neo Store. To provide insights and analytics on rewards programs, we may share anonymized and aggregated information with third party merchants within our cashback program.
• Cloud service providers: to store your information and provide the Platform and Products.

(b) Products and Services Offered by Neo

• Financial and banking partners: When you apply for or open a Product, we may share your identity, financial, credit and screening information, and information about others, with financial and banking partners involved in offering or servicing the account. We provide this information to applicable account providers to open your account and for regulatory reporting and compliance purposes.
• Credit card partners: We may share your identity information with our credit card program partners to administer rewards programs, perform analytics, deliver personalized offers and experiences to you, and facilitate display of information in third party applications.
• Mortgage providers: When you apply for or open a Neo Mortgage, we may disclose your identity, financial, and credit information provided in connection with your mortgage application (as well as other information we receive from third parties, such as your credit history), to a prospective mortgage lender for the purpose of processing your mortgage, including administering and servicing your mortgage, preparing documentation, verifying your identity, protecting you and Neo from fraud and error, and complying with legal and regulatory requirements. We may also disclose such personal information to any assignee or proposed assignment of the mortgage commitment, to an entity that funds, purchases, invests, or takes an assignment of all or part of your mortgage loan, including to facilitate such sale, to mortgage insurers, to consumer reporting agencies, to the title custodian, or to title insurance providers.
• Neo Rewards/Store: We may share your identity, financial, online, transaction, counterparty and third party information with certain third parties as part of Neo Rewards™, Premium Rewards Package and Neo Store products for the purposes of providing rewards, products, attribution and fulfillment. To provide insights and analytics on rewards programs, we may share anonymized and aggregated information with third party merchants within our cashback program.
• Mobile wallet providers: If you choose to load your card into a mobile wallet, we may share your identity and financial information with the wallet provider, Mastercard, and other service providers. Please see the Mobile Wallet Terms and Conditions
• Insurance product providers: We may share your identity information to administer certain insurance products or other benefit perks associated with your Product.

(c) Legal and Compliance

4. Your Choices

(a) Access and Accuracy

(b) Analytics and Advertising

• Google Analytics: For more information on Google Analytics or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners’ sites or apps” and “Google Analytics and Privacy”.
• Personalized Marketing: Personalized marketing is optional and you can manage your privacy preferences within the Platform. If you reside in Quebec, you are opted out of personalized marketing.
• Location Tracking: You can opt-out of location tracking at any time by turning off your location services for the App in the settings of your mobile device.
• Cookies: We use “cookies”, which are small computer files that a website’s server places on your computer so that we can recognize your computer or device when you return. You can set your browser to notify you when you receive a cookie or 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.
• Marketing: We may use third parties such as ad exchanges and data companies to serve our advertisements on our Platform or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our Website, and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Platform. To learn more about this behavioural advertising practice or to opt-out of this type of advertising, you can visit the Digital Advertising Alliance website here, or at the Digital Advertising Alliance of Canada website here.

5. Safeguarding and Retention of Personal Information

We use industry standard security practices and procedures to safeguard your personal information.

We limit retention of your personal information.

6. Information About Our Privacy Governance Policies and Practices

• We have implemented policies and procedures to protect personal information in our custody and control from unauthorized access, use or disclosure.
• We follow a SOC 2 compliance program to ensure that our systems and infrastructures are securely controlled and effectively operated. Controls are reviewed regularly to ensure operating effectiveness and security.
• We regularly redact data when transmitting outside of secure segments or applications within our private network. We use encryption where necessary to further secure our data both at rest and while in transmission. In the event of a data breach, encrypted data cannot be viewed or otherwise used, and keys cannot be exported (i.e., stolen, breached, etc.) from our key management service by design.
• We have implemented processes to respond to data subject requests and complaints in a timely and effective manner.
• We have implemented a framework for the retention and destruction of personal information to ensure compliance with legal obligations, and to securely destroy personal information once no longer required.
• We have implemented a privacy framework that defines the roles and responsibilities for our employees with respect to the treatment of personal information. While all Neo employees share the responsibility of keeping your personal information safe, we have identified key internal leaders who are responsible for data within our business.
• We have designated a Privacy Officer who is responsible for overseeing Neo’s compliance with privacy legislation, for advising Neo about our personal information and data protection obligations, as well as monitoring compliance. Our technical teams are responsible for the technical controls in place to manage your data and keep it safe, including implementing information security systems and secure data storage.
• We provide our employees with regular privacy training and awareness.

7. Updates to our Privacy Policy

8. Contact Us