Privacy Policy

1 - Introduction: Our commitment to your privacy

Welcome to NeoMana! NeoMana Labs, Inc. ("NeoMana," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our NeoPay payment network, Point of Sale (POS) system, or any related services (collectively, the "Services").

Our community-focused payment network allows users ("Users," "you") to load funds onto the NeoPay app and make payments to member merchants while participating in our rewards programs, including our weekly cash sweepstakes.

This Privacy Policy applies only to our Services and not to the practices of third parties that we do not own or control, including member merchants or other third-party services you might access. We encourage you to review the privacy policies of any third party you interact with.

We understand the importance of your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws. By accessing or using our Services, you consent to the collection, use, disclosure, and protection of your information as described in this Privacy Policy.

2 - Information we collect

We collect information about you to provide and improve our Services, ensure security, and comply with regulations. This information includes:

2.1 - Personal information

We may collect the following types of personal information, some of which are subject to your opting in and/or permission:

• Identity Information: Full name, date of birth, username, student ID, university affiliation
• Contact Information: Email address, phone number, mailing address
• Financial Information: Bank account information, payment card details, transaction history
• Location Information: GPS data, IP address, and other location-based information
• Device Information: Device type, operating system, browser type, mobile network information
• Usage Information: Interactions with our Services, preferences, and settings
• Communications: Customer service communications, feedback, and survey responses

2.2 - Information needed for compliance and verification

We may collect information needed for "Know Your Customer" (KYC) compliance and identity verification, which may include:

• Social Security Number (SSN) or portions thereof
• Government-issued ID details and images
• Other information required to prevent fraud and meet legal obligations

2.3 - Information collected automatically

When you use our Services, we may automatically collect certain information, including:

• Technical Information: IP address, device type, browser information, operating system
• Usage Data: Time spent on Services, features used, transactions processed
• Location Data: General location information based on IP address or precise location if location services are enabled
• Transaction Data: Purchase history, payment methods, merchant information, delivery details

For fraud protection purposes only, we may collect device-specific information such as:

• Battery usage information
• Device identifiers
• Device storage information
• Network-related identifiers
• SIM card information
• Information to determine if you are attempting to spoof your location

2.4 - Information from third parties

We may receive information about you from third parties, including:

• Banking Partners: Account verification information
• Identity Verification Services: Information to verify your identity
• University Partnerships: Verification of student status
• Member Merchants: Transaction information, purchase history
• Payment Processors: Transaction details
• Referees and Other Authorized Third Parties: Information you authorize them to provide to us

3 - How we use your information

We use your information for various purposes, including:

3.1 - Service provision and improvement

• Access to our NeoPay network
• Improving and optimizing our Services
• Providing customer support and responding to inquiries
• Maintaining your NeoPay account
• Verifying and establishing your account with our banking partners

3.2 - Rewards and promotions

• Operating our weekly sweepstakes program
• Distributing cash prizes to winners
• Providing post-purchase rewards
• Offering merchant discounts and promotions
• Managing the Welcome Package for new users
• Communicating about offers, emails, newsletters, and other information that may be of interest to you

3.3 - Security and fraud prevention

• Verifying your identity
• Detecting and preventing fraudulent transactions
• Ensuring secure payment processing
• Protecting against unauthorized access to user accounts
• Monitoring for suspicious activity
• Protecting against or deterring fraudulent, illegal, or harmful actions
• Conducting risk assessments

3.4 - Business operations

• Analyzing usage patterns and trends
• Developing new features and services
• Evaluating the effectiveness of our business strategies
• Managing merchant relationships
• Measuring economic impact within university communities
• Identifying trends and statistical information that may be useful to our business
• Complying with our legal or contractual obligations

3.5 - Communication

• Sending transaction confirmations
• Providing sweepstakes results and notifications
• Delivering important service updates
• Sharing promotional offers from member merchants (with consent)
• Requesting feedback on service quality
• Responding to user inquiries
• Fulfilling user requests
• Resolving disputes
• Enforcing our Terms of Service

4 - Information sharing and disclosure

We share limited personal information with vendors, third-party service providers, and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. We limit this based on the minimum information required for such vendors, third-party service providers, and agents to perform the required services.

We may share your information in the following circumstances:

4.1 - With service providers

We share information with third-party service providers who help us operate, provide, improve, and market our Services, including:

• Payment processors and financial institutions
• Cloud storage providers
• Analytics providers
• Customer service providers
• Marketing partners
• Identity verification services
• Hosting service providers
• Email providers
• Banking and financial partners and payment networks
• Cloud communication service providers
• Other contractors as needed for business purposes

4.2 - With member merchants

We share limited transaction information with member merchants to:

• Support loyalty programs and promotions
• Provide anonymized analytics and insights

4.3 - For legal reasons

We may disclose your information when required by law or in the following situations:

• When we believe it is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• To comply with legal obligations or legal process
• To protect our rights, privacy, safety, or property
• To protect against legal liability
• To prevent or investigate possible wrongdoing
• To address fraud, security, or technical issues

4.4 - Business transfers

If we are involved in a merger, acquisition, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. In the event that we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, your personal information would be one of the assets that is transferred to or acquired by the third party that is acquiring our assets.

4.5 - With your consent

We may share your information in other ways if we have your express consent or at your direction.

5 - Data retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you
• Whether we need the information to continue to administer your account and provide the Services
• Our legal obligations
• Applicable statutes of limitations
• Ongoing or potential legal disputes
• The need to resolve disputes or enforce our contractual agreements
• Guidelines issued by relevant data protection authorities
• The need to prevent harm and promote safety, security, and integrity

When we no longer need to use your personal information, we will either delete it or anonymize it so that it can no longer be associated with you.

6 - Your rights and choices

Depending on your location, you may have certain rights regarding your personal information, including:

• Access: The right to request access to your personal information
• Correction: The right to request that we correct inaccurate or incomplete information
• Deletion: The right to request deletion of your personal information
• Restriction: The right to request restriction of processing of your personal information
• Data Portability: The right to receive your personal information in a structured, commonly used format
• Objection: The right to object to our processing of your personal information
• Withdrawal of Consent: The right to withdraw consent at any time where we rely on consent to process your information

To exercise these rights, please contact us using the information in the "Contact Us" section below.

6.1 - Communication preferences

You can manage your communication preferences by:

• Adjusting settings in your account
• Following the unsubscribe instructions in marketing emails
• Contacting us directly

7 - Data security

We seek to protect your personal information using appropriate technical and organizational measures based on the type of information and applicable processing activity. These measures include:

• Encryption of sensitive data
• Secure communication protocols
• Access controls
• Regular security assessments
• Employee training on data protection

We implement 'least privilege principles' when it comes to giving employees access to personal information – employees should only be able to access data if it is necessary for them to carry out the duties of their role.

We limit personal data tracking and only store what we need to deliver the Services. We also minimize the use of third-party services to only those required to deliver the Services effectively.

While we strive to protect your personal information, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information. Despite our reasonable efforts, no security measures are impenetrable, and we cannot guarantee "perfect security" of any personal information.

Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. We recommend that you do not use unsecure channels to send us sensitive or confidential information.

8 - Third-party links and services

Our Services may contain links to third-party websites, apps, or services that are not operated by us. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party services. We encourage you to review the privacy policies of any third-party services you visit or use.

8.1 - Cookies and similar technologies

The Services may use "Cookies" and similar technologies to enable our servers to recognize your web browser and tell us how and when you visit and use our Services. Cookies are small files – usually consisting of letters and numbers – placed on your computer, tablet, phone, or similar device when you use that device to visit our Site.

We use the following types of Cookies:

• Essential Cookies: Required for providing you with features or services that you have requested. Disabling these Cookies may make certain features and services unavailable.
• Analytics Cookies: We use analytics cookies, including through third-party tracking technology partners such as Google Analytics, to help us improve our website by collecting and reporting information on how you use it.

You can decide whether or not to accept Cookies through your internet browser's settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies. You can also delete all Cookies that are already on your computer. If you do this, however, you may have to manually adjust some preferences every time you visit a site, and some Services and functionalities may not work.

9 - Children's privacy

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18, we will take steps to delete that information as quickly as possible. If you believe we might have any information from or about a child under 18, please contact us.

10 - International data transfers

Your information may be transferred to and processed in countries other than the country in which you reside. These countries may have data protection laws that are different from those in your country. However, we will take appropriate measures to ensure that your personal information remains protected in accordance with this Privacy Policy and applicable law.

11 - Sweepstakes and rewards program

Participation in our sweepstakes and rewards program is subject to additional terms and conditions. When you participate in these programs, we collect and use your information as described in this Privacy Policy and in accordance with the program's specific terms.

12 - Changes to this privacy policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The updated policy will be posted on our website with a revised effective date. We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any changes to this Privacy Policy constitutes your acceptance of the changes.

13 - Contact us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

NeoMana Labs, Inc.

Privacy Team
136 E. Rosemary Street, Ste 100 Chapel Hill, NC 27514
Email: info@neomana.com

14 - Additional information for specific jurisdictions

14.1 - California residents

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). Please see our California Privacy Rights Notice for more information.

14.2 - Nevada residents

Nevada residents have the right to opt out of the sale of certain personal information to third parties. We do not sell your personal information as defined under Nevada law.

14.3 - European Economic Area, United Kingdom, and Switzerland

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, you may have additional rights under the General Data Protection Regulation (GDPR) or similar laws. Please contact us for more information about these rights and how to exercise them.

15 - Supplemental notices

15.1 - Mobile application privacy

When you download, access, or use our mobile application, we may collect additional information as permitted by your device operating system's permissions. You can adjust these permissions through your device settings.

15.2 - Cookies and similar technologies

We use cookies and similar technologies to collect information about your browsing activities and to distinguish you from other users of our Services. For more information about how we use these technologies and how you can control them, please see our Cookie Policy.