NeoCheck S.L. (“NeoCheck”) respects the privacy of our users. This Privacy Policy (“Policy”) describes our privacy practices concerning information collected in connection with NeoCheck’s payment, verification, and related online services, including NeoCheck SaaS and NeoCheck Onboarding (the “Services”). NeoCheck makes the Services available to third parties for integration into those third parties’ websites, applications, and online services. NeoCheck collects, uses, and discloses individual users’ information only as directed by these third parties and, accordingly, NeoCheck is a mere processor of user information with respect to the Services and not a controller. Further, some features of the Services may be disabled or altered by the data controller, or the controller may require NeoCheck to collect, use, disclose, or otherwise process data in ways that differ from those described below. Thus, to fully understand how your information will be handled when you use the Services, you must review not just this Policy, but also the privacy policy of the third party with whom you are dealing directly (the “Third-Party Data Controller”).

Notwithstanding the above, NeoCheck may process certain individual users’ information in anonymized form for its own purposes.

NeoCheck is headquartered in Spain at C/ Cerro Minguete 27, CP 28035, Madrid, Spain.

What personal and other information NeoCheck collects about you

NeoCheck collects “personal information” about users of the Services. “Personal information” is information such as a name, email address, or identification card image, which refers to an identified or identifiable person. NeoCheck processes personal information on behalf of the Third-Party Data Controller. For its own purposes, NeoCheck processes only anonymized information. “Anonymized information” is information which does not relate to an identified or identifiable person or is rendered anonymous in such a manner that the person is no longer identifiable.

Personal information. NeoCheck collects a wide range of personal information through the Services. This information varies depending on the NeoCheck application and the Third-Party Data Controller in question, but may include such information as name, physical address, email address, telephone number, social security number, driver’s license number, state or national ID card number, passport number, other ID card number, credit or debit card number, CVV, expiration date, and/or date of birth. In some cases, NeoCheck may collect a visually scanned or photographed image of your face and/or your identification card, driver’s license, passport, utility bill, bank account statement, insurance card, or credit/debit card. This image may include your photograph and other information from the imaged document, such as your eye colour, weight, height, and organ donor status.

Facial recognition. If you agree to use our NeoCheck SaaS with Biometric Facial Recognition, or other facial recognition service that we offer to our customers, NeoCheck will collect an image of your face that you provide through a mobile app and a photo or scan of your face as it appears on an identification document. NeoCheck will use facial recognition technology only for the purpose of verifying your identity as the person who appears on the identification document. NeoCheck may share the facial scans with the NeoCheck customer through which you used NeoCheck’s identity verification service. NeoCheck will retain your facial recognition information, including the photo of your face and photo or scan of your identification document, for the amount of time requested by the NeoCheck customer through which you used NeoCheck’s identity verification service. In no event will NeoCheck store your facial recognition information after NeoCheck ceases to have a customer relationship with the customer through which you used NeoCheck’s identity verification service.

Data provided by third parties. We may receive personal or anonymized information about you from the Third-Party Data Controller that integrates the Services into its website, application, or other online service. This information includes a customer ID, selected by the Third-Party Data Controller, that uniquely identifies you in the third party’s database. For additional information, review the privacy policy of the Third-Party Data Controller.

At the direction of the Third-Party Data Controller, NeoCheck also might obtain information about you from other third parties, such as consumer reporting agencies and fraud-prevention services.

Cookies and other tracking data. When you use the Services, we automatically receive and record certain information from your computer (or other device) and/or your web browser. This may include such information as the third-party website or application into which the Services are integrated, the date and time that you use the Services, your IP address and domain name, your software and hardware attributes (including operating system, device model, and hashed device fingerprint information), and your general geographic location (e.g., your city, state, or metropolitan region). We will process such data only as instructed by the Third-Party Data Controller.

We also use cookies in connection with the Services. For further information please refer to the section entitled “Cookies” below.

Cookies

What are cookies? Cookies are small files that are stored on your computer or other device by your web browser. A cookie allows NeoCheck to recognize whether you have used the Services before and may store user preferences and other information.

How are cookies used? For example, cookies can be used to collect information about your use of the Services during your current session and over time, your computer or other device’s operating system and browser type, your Internet service provider, your domain name and IP address, and your general geographic location. We process personal information generated by cookies only as instructed by the Third-Party Data Controller.

What kind of cookies are used on the Website? Our website primarily uses the following types of cookies:

Cookie Name Cookie Type Purpose
__ga Persistent cookie This cookie is used to distinguish users and expires after 2 years.
__gat Session cookie This cookie is used to throttle the request rate and expires after 10 minutes.

“Session cookies” are temporary bits of information which are deleted when you exit your web browser. Session cookies are typically used to improve navigation and to collect web statistics.

“Persistent cookies” are more permanent bits of information that are stored and remain on your computer until they are deleted by you. This type of cookie stores information on your computer for a number of purposes; such as saving your passwords. Persistent cookies delete themselves after a certain period of time but are renewed each time you visit the website.

How do you avoid cookies? If you are concerned about having cookies on your computer or device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.

How NeoCheck uses the personal and anonymized information that we collect

In general, NeoCheck uses the personal and anonymized information that we collect in connection with the Services as discussed in this section of the Policy.

Personal information is used by NeoCheck only as directed by the Third-Party Data Controller that integrates the Services into its website, application, or other online service. Subject to the privacy policy of the Third-Party Data Controller, we use your personal information as follows on behalf of the Third-Party Data Controller:

NeoCheck may use your personal information to provide the Services. For example, we might use your credit card information or ID card information to populate an online form, or to verify your identity in connection with your use of another online service. We also may use your personal information to fulfill the terms of any agreement between us and the Third-Party Data Controller; to complete a transaction that you initiate; to deliver confirmations, account information, notifications, and similar operational communications; and to comply with legal and/or regulatory requirements.

Anonymized information that we collect in connection with the Services is used by NeoCheck for its own purposes to perform analytics and research concerning the Services.

How NeoCheck shares personal and anonymized information with third parties

In general, NeoCheck shares the personal and anonymized information that we collect in connection with the Services as discussed below.

However, NeoCheck shares personal information only as directed by the Third-Party Data Controller, and thus the following language is subject to the privacy policy of the Third-Party Data Controller.

Third-Party Data Controller. We share the personal and pseudonymized information that we collect on behalf of a particular Third-Party Data Controller with that Third-Party Data Controller.

NeoCheck service providers. NeoCheck also uses third-party service providers to help us deliver, manage, and improve the Services. These service providers may collect and/or use your personal information or anonymized information to assist us in achieving the purposes discussed above in the section entitled “How we use the personal and non-personal information that we collect.” For example, we use a third party to help us translate the information contained in scanned images of identification cards.

We also may share your personal information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; or to meet the terms of any agreement that you have with us or our partners.

Analytics providers. We partner with certain other third parties to collect anonymized information and engage in analysis, auditing, research, and reporting.

Legal purposes. We also may use or share your personal information with third parties when we have reason to believe that doing so is necessary:

  • to comply with applicable law or a court order, subpoena, or other legal process;
  • to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
  • to establish, protect, or exercise our legal rights or defend against legal claims; or
  • to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.

Aggregated information. From time to time, NeoCheck may also share anonymized and aggregated information about users of the Services, such as by publishing a report on trends in the usage of the Services.

Security

NeoCheck uses commercially reasonable physical, electronic, and procedural safeguards to protect your personal information against loss or unauthorized access, use, modification, or deletion. Among other things, NeoCheck encrypts sensitive information both in transit and at rest. NeoCheck is PCI Level 1 compliant and regularly conducts security audits, vulnerability scans, and penetration tests to ensure compliance with security best practices and standards. However, no security program is foolproof, and thus we cannot guarantee the absolute security of your personal or other information. Moreover, we cannot guarantee the safety of your information when in the possession of other parties, such as the Third-Party Data Controller.

Reviewing and updating your information

NeoCheck will grant you access to your personal information as directed by the Third-Party Data Controller that integrates the Services into its website, application, or online service. NeoCheck also will retain your personal information as directed by the Third-Party Data Controller and, accordingly, we may retain your personal information for as short as a few minutes or as long as five years.

Thus, if you want to learn more about the personal information that NeoCheck has about you, or you would like to submit a request to update or change that information, please contact the Third-Party Data Controller. You also may reach us by email at info@neocheck.com.

Information for users of the Services from outside the European Union

The personal information that NeoCheck collects through or in connection with the Services is transferred to and processed in the European Union for the purposes described above. NeoCheck also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the countries other than your country of residence. The data protection laws in these countries may be different from, and less stringent than, those in your country of residence.

However, we only transfer your personal data to countries where the EU Commission has decided that they have an adequate level of data protection or we take measures to ensure that all recipients provide an adequate level of data protection.

Changes to this Policy

Technology and the Internet are rapidly changing. NeoCheck therefore is likely to make changes to the Services in the future and as a consequence will need to revise this Policy to reflect those changes. When we revise the Policy, NeoCheck will post the new Policy on the NeoCheck website’s home page (www.neoceck.com), so you should review that page periodically. If we make a material change to the Policy, you will be provided with appropriate notice. If we maintain your email address, we also may email you a copy of the revised Policy at your most recently provided email address. It is therefore important that you update your email address if it changes.

Questions or comments

If you have any questions or comments regarding our Policy, please contact us at:

NeoCheck S.L.
Cerro Minguete 27,
PC 28035, Madrid, Spain
Email: info@neocheck.com