Privacy Policy

1

What information does neeo collect and use?
    NEEO may gather and use information about you, including (but not limited to) information in the following categories:

  • (a)Identification data (e.g. name, username, mobile number, etc.);
  • (b)Profile information (e.g. country of residence, language preference and any information that you choose to make available to others as part of your NEEO user profile);
  • (c)Electronic identification data (e.g. IP addresses);
  • (d)List of your contacts and related data;
  • (e)Correspondence between you and NEEO;
  • (f)Traffic data; and
  • (g)Content of instant messaging communications, voice messages, transmitted pictures and video messages;
  • (h)Location information, derived from your mobile carrier or from the mobile device that you use;
  • (i)Mobile device information, such as manufacturer’s name, device model number, operating system, carrier network;
  • (j)Location information, device identifiers and standard identifiers of the Wi-Fi networks your device detects, when you search for or connect to a WiFi hotspot;
  • (k)Access tokens for other accounts you associate with your NEEO account (such as Facebook), which are like an electronic key provided by the service that acts in place of a password for authentication.

2

How does neeo use this information and for what purpose?
    Our primary purpose in collecting information is to provide you with a safe, smooth, efficient, and customized experience. NEEO collects and uses, or has third party service providers acting on NEEO’s behalf collecting and using, personal data relating to you, as permitted or necessary to:

  • provide communications, video sharing and other products in particular to convey the communications, pictures and videos you and others make by means of the NEEO software and/or the NEEO products;
  • change and customize NEEO features and functionality;
  • provide other services for you (as described when we collect the information);
  • provide you with customer support and troubleshoot problems;
  • compare information for accuracy;
  • inform you about service updates and faults;
  • request feedback or participation in on-line surveys;
  • resolve disputes;
  • verify your identity;
  • customize, measure, and improve NEEO software and websites, as well as other NEEO products and services;
  • improve our search functionality and help you find and contact other NEEO users more easily and accurately;
  • organize and carry out NEEO’s marketing or promotional operations/offers and similar events;
  • offer certain NEEO software, features and websites, free of charge through the support of advertising; and
  • protect your and NEEO’s interests, including in particular to enforce our Terms of Use and prevent and fight against fraud, (together, the Purposes).

3

Our disclosure of your personal information
  • Except as provided below, NEEO will not sell, rent, trade or otherwise transfer any personal and/or traffic data or communications content outside of PowerfulPal LTD and its controlled subsidiaries and affiliates without your explicit permission, unless it is obliged to do so under applicable laws or by order of the competent authorities. Please note that information that you voluntarily make public in your user profile, or which you disclose on forums, discussions boards or by posting comments will be publicly available and viewable by others.

    We may access, disclose and preserve personal data, including your private content (such as the content of your instant messages, stored video messages, voicemails or file transfers), when we have a good faith belief that doing so is necessary to: comply with applicable law or respond to valid legal process from competent authorities, including from law enforcement or other government agencies; protect our customers, for example to prevent spam or attempts to defraud our users, or to help prevent the loss of life or serious injury of anyone; operate and maintain the security of our websites, products and services, including to prevent or stop an attack on our computer systems or networks; or protect our rights or property including enforcing the terms governing the use of our websites, products or services – however, if we receive information indicating that someone is using our products to traffic in stolen intellectual or physical property of NEEO or PowerfulPal LTD, we will not inspect a customer’s private communications or documents ourselves, but we may refer the matter to law enforcement.

    In order to provide you with NEEO products you have requested, NEEO may sometimes, if necessary, share your personal and traffic data with NEEO’s group companies, carriers, partner service providers and/or agents. For example, WiFi access services providers, distributors of NEEO software and/or NEEO products, and/or the third party banking organizations or other providers of payment, email delivery, analytical services, customer support, or hosting services. NEEO 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.

    Some NEEO products may be (i) co-branded; (ii) made available via a partner company’s website; and/or (iii) supported through a partner company. If you register for or use such products, you consent to both NEEO’s and the partner company’s use of personal data collected in connection with the product and you understand that the partner company’s use of your personal data may be subject to the partner company’s privacy policy. NEEO may offer its products in connection with other websites or services or may team with other online services to give you the combined results of both products/services or additional services and benefits. To determine whether you would benefit from the combined offer, if you have provided your consent, NEEO may match your email address, and email addresses of your contacts against email addresses you have provided to the third party website/service provider.

    NEEO, NEEO's local partner, or the operator or company facilitating your communication may provide personal data, communications content and/or traffic data to an appropriate judicial, law enforcement or government authority lawfully requesting such information or in accordance with NEEO Civil Subpoena Policy incorporated into the NEEO's Terms and Conditions. NEEO may provide reasonable assistance and information to fulfill such request and you hereby consent to such disclosure.

    Information that is collected by or sent to NEEO and/or PowerfulPal LTD may be stored and processed in the United States or any other country in which PowerfulPal LTD or its affiliates, subsidiaries, or service providers maintain facilities. In this regard, or for purposes of sharing or disclosing data in accordance with this article, NEEO reserves the right to transfer information outside of your country. By using NEEO software, NEEO's websites or NEEO products you consent to any such transfer of information outside of your country. PowerfulPal LTD abides by the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Economic Area, and Switzerland. To learn more about the Safe Harbor program, please visit www.export.gov/safeharbor.

    As PowerfulPal LTD continues to develop its business, PowerfulPal LTD might sell or buy subsidiaries or business units. In any such transactions in which NEEO or substantially all of its assets are acquired by a third party, personal information of NEEO users will generally be one of the transferred business assets. We reserve the right to include your personal information in any such transfer to a third party.

4

What are cookies and gifs how does neeo use them?
    Key Points

  • Currently, only NEEO websites (and not NEEO software) are utilizing the cookies technology. By using NEEO’s websites you are giving your consent to the use of cookies. You can choose to reject cookies at any time, either by changing your browser settings (if your browser permits) or by ceasing to use NEEO’s websites or by using the applicable opt-out functions. You should be aware that certain features are only available through the use of cookies and if you choose not to accept cookies, such features may not be available to you.
    • 4.1    What are Cookies and GIFs?
    • 4.1.1    Cookies
      Cookies are small files containing a string of characters (text) that are sent to your browser from a website’s server. The cookie may contain a unique identifier but it does not contain personally identifiable information such as your name or email address. NEEO may use cookies when you visit its websites, or visit other websites where NEEO serves advertisements. The browser of the NEEO software client or your Internet browser stores the cookie on your computer's hard drive and this may be accessed by the website during your next visit. Other websites may also send cookies to your browser but your browser will not allow those websites to see NEEO’s cookie data.
    • 4.1.2    Other similar technologies
      NEEO web pages and client interfaces may include clear gifs, web-beacons, tracking pixels and other similar electronic images to help deliver cookies on our sites and let us count users who have visited those pages. In addition, we use these images in our HTML-based emails to let us know which emails have been opened and acted upon and to enable us to recognize you and understand your activity on our websites as a result of these actions. This allows us to gauge the effectiveness of certain communications and track the effectiveness of our marketing campaigns and to tailor your online experience and provide recommendations based on your activity.
    • 4.2    What type of Cookies does NEEO use?
      NEEO websites use session cookies, persistent cookies and local shared objects (flash cookies).

      Session cookies are temporary cookies, or unique identifiers associated with your browser for the duration of your visit to NEEO’s websites or area of the NEEO software client. Once you close your browser, the session cookie ID will disappear and information about your visit is not retained.

      Persistent Cookies remain on your browser even after you close it and may be used by your browser on subsequent visits to the website.

      Local Shared Objects or ‘Flash Cookies’ are cookies written with Adobe flash technology. These cookies are saved on your computer in the same way as other cookies but they cannot be managed at browser level in the same way.
    • 4.3    How NEEO uses Cookies
      NEEO uses its own cookies for a variety of purposes, including to:
    • 1recognize you when you sign in and understand how you arrived at our website, so we can make sure that we provide you with relevant customer content and information. For example:
      • if you arrived at our website by clicking on a link to hear about US subscription packages, we can make sure you see content relevant to those offers;
      • we can recognize your time zone so that your call lists are accurately displayed;
      • if your cookie was set a long time ago, we know you are not a new user and we will not show you content intended for new users, such as ‘how to use NEEO’ pages;
    • 2remember your chosen preferences, such as:
      • the language you choose to see our website in;
    • 3fight against fraud;
    • 4inform you about the version of the NEEO software you are using so that we can provide you with new software updates and direct you to the relevant help sections;
    • 5enable you to access your account and account services through the NEEO software;
    • 6provide internal and customer analytics and gain statistics and metrics about our websites, such as total number of visitors and page views;
    • 7monitor the effectiveness and performance of our advertising and marketing campaigns and carry out research in order to help us to improve our products and websites;
    • 8initiate security measures such as ‘time-out’ when you have not logged into your account for a period of time;
    • 9populate your NEEO app with one or more of your NEEO contact's information;
    • 10deliver video and picture content to you;
    • 11provide NEEO ads most relevant to you when you visit other sites that display NEEO ads.
    • 4.4    Third Party Cookies
      In addition to NEEO’s cookies, NEEO’s analytics, ad-serving and affiliate partners may set cookies and access cookies on your computer, when you are visiting a NEEO website and may collect information about your online activities across websites or online services.
    • 4.5    Your Choices about Cookies
      We don’t recommend that you restrict or block cookies as this may impact on the functionality of our websites and products. However, if you choose to do so, please see the comprehensive information about cookies at www.aboutcookies.org.

5

Your advertising choices
  • NEEO websites and some NEEO software may enable third-party advertisements provided by PowerfulPal LTD's Ad Serving Partners. We may use non-personally identifiable information that you have provided to NEEO, such as the age, gender, language and country of residence in your NEEO profile as well as information about your relationship with and use of NEEO’s websites, software, and products, such as the destination of your calls, in order to provide advertisements likely to be of greater interest to you and to help us measure and improve the performance of our advertising campaigns and offers.

6

Your user profile
  • Your user profile is the information provided by you at registration or later which is displayed in your NEEO profile in the NEEO software client, in the NEEO search directory and on your personal details page in your account. It may include your NEEO username, full name, address, telephone and mobile numbers, gender, date of birth, country, language, “about me” page URL, and any other information that you decide to make available. You can access your user profile from the NEEO software in order to view, correct or complete information, remove non-mandatory information; and to see the privacy settings associated with your profile information.

7

Linked websites and third party applications
  • NEEO websites may contain links that will let you leave NEEO's website and access another website. Linked websites are not under the control of NEEO and these websites have different privacy policies. The NEEO Privacy Policy applies solely to personal information that is acquired on the websites or through your use of the NEEO software, NEEO products and/or your relationship with NEEO, so NEEO urges you to be careful when you enter any personal information online. NEEO accepts no responsibility or liability for these other websites.

    If you use any extras, plug-ins or third party applications together with the NEEO software or use any third party applications or products that incorporate or embed the NEEO software (“Applications”), the provider of such Applications may obtain access to certain personal information about you. NEEO does not and cannot control how the provider of Applications may use any personal information connected in connection with such Applications. Please ensure that you review any privacy policies or other terms applicable to the use of such Application before installation.

8

How does neeo protect your personal information?
  • NEEO will take appropriate organizational and technical measures to protect the personal data and traffic data provided to it or collected by it with due observance of the applicable obligations and exceptions under the relevant legislation. Your personal and traffic data can only be accessed by authorized employees of PowerfulPal LTD or its affiliates, subsidiaries or service providers who need to have access to this data in order to be able to fulfill their given duties.

    NEEO currently uses standard techniques for encryption and decryption of data. NEEO does not currently scan the data to identify any suspected spam and/or malicious URLs. It is a sole responsibility of its users to exercise appropriate care when using NEEO.

9

Contacting you
  • NEEO may from time to time ask you to provide information on 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 website or any survey that you take part in is used for the purposes of reviewing this feedback and improving the NEEO software, and NEEO and other PowerfulPal LTD products and websites.

    NEEO may contact you to send you messages about faults and service issues. Further, NEEO reserves the right to use email, the NEEO software or SMS to notify you of any eventual claims related to your use of NEEO software, the NEEO websites and/or NEEO products, including without limitation claims of violation of third party rights.

    NEEO may send you alerts by email or SMS to notify you when someone has tried to contact you. NEEO may also use email, SMS or the NEEO software to keep you up to date with news about the NEEO software and NEEO products that you have purchased and/or to inform you about other NEEO products or other NEEO related information. You can opt-out of the receipt of alerts and/or promotional emails.

10

How can you access or amend your personal data?
  • You have the right to access and, where relevant, to amend your personal information. Some of your information may be viewed or edited by signing into your account. We will respond to requests to view, correct, complete or remove your personal information within a reasonable period of time and upon verification of your identity.

    NEEO will use all reasonable endeavours to accommodate requests to delete personal information unless it is required to be retained by law or for lawful business purposes. However, please note that due to the technical nature of the peer to peer network, it can sometimes take up to two weeks before your NEEO ID disappears completely from the peer to peer network. Your details may still appear in the search directory during this time.

11

How long is your personal data kept by neeo?
  • NEEO will retain your information for as long as is necessary to: (1) fulfill any of the Purposes (as defined above in this Privacy Policy) or (2) comply with applicable legislation, regulatory requests and relevant orders from competent courts.

    Retention of Instant Messages, Voice Messages, and Video Messages

    Your instant messages (IM), voicemail, and video messages, including any media that you share through our messaging features, such as videos, pictures, or your location on a map, (collectively “messages”) may be stored by NEEO (a) to convey and synchronize your messages and (b) to enable you and your recipients to view the messages.

12

Children
  • NEEO's websites and software clients are not intended for or designed to attract users under the age of 13. 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.

13

Mobile notifications
  • When you use NEEO on your phone, NEEO may use notification services available for that phone to let you know of incoming calls, chats and other messages when you are not actively running or using the NEEO application. These services may be provided by a third party. For example, messages sent to an Apple device will use Apple’s Push Notification Services.

    Notification services may receive information about the caller, sender of the message and the content of the message as part of providing the service and may use the information in accordance with the terms and conditions and privacy policy for the service provider. NEEO is not responsible for the data collected by third party notification services.

14

Mapping and location features
  • If you agree to allow access to your location, NEEO can use that information to provide services you request or to personalize your experience. Location information may include available cell tower data, Wi-Fi hotspot data, and Global Position System (GPS) data.

    When you use a location based service or feature, available cell tower data, Wi-Fi data and Global Position System (GPS) data may be sent to PowerfulPal LTD. PowerfulPal LTD may use location information to provide the services you request, personalize your experience and improve PowerfulPal LTD products and services.

    Certain services may allow you to control when location information is sent to PowerfulPal LTD or made available to others. Refer to the documentation that came with your device for information about how to turn off location features.

15

Can this privacy policy be modified?
  • NEEO will occasionally update this Privacy Policy to reflect changes in our software and/or products and customer feedback. When we post changes to this Privacy Policy, we will update the "last revised" date at the bottom of the Privacy Policy. If there are material changes to this Privacy Policy or in how we will use your personal information, we will notify you either by prominently posting a notice of such changes or by directly sending you a notification. You agree that your continued use of the NEEO software or NEEO products after notice shall constitute your acceptance of the updated/modified Privacy Policy. We encourage you to periodically review this Privacy Policy to be informed of how NEEO is collecting, using, and protecting your information.

16

How can you contact neeo?
  • To contact NEEO in relation to the “NEEO” branded software or products, please submit a written request to:

    PowerfulPal LTD
    1629 Sheepshead Bay Rd, 3rd Fl.
    Brooklyn, NY 11550
Get Neeo on App store & Google Play Store
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