Privacy Policy

Welcome to the NeoMaxer Privacy Policy

This Policy outlines our practices regarding your information how we gather, maintain, safeguard, and share it, as well as who we share it with. We recommend reading this document alongside our Terms of Use for a complete understanding.

As you enjoy the NeoMaxer experience across our mobile and desktop applications (collectively referred to as the "App"), browse our websites, or interact with our digital products and services (such as surveys and quizzes) - all of which we'll refer to as our "Sites" in this Policy - we collect certain information about you. Additionally, you may opt to use the App or Sites to share information with other users, including those in your personal network ("Users"). In some instances, we may also need to share your information.

This Policy aims to provide transparency about our data practices and empower you with the knowledge of how your information is handled within our ecosystem. This Privacy Policy is published in compliance of:

1. Section 43A of The Information Technology Act, 2000;
2. Rule 4 of The Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Information) Rules, 2011 (hereinafter referred to as the "SPI Rules");
3. Relevant provisions of The Consumer Protection Act, 2019 read with The Consumer Protection (E-Commerce) Rules, 2020;
4. The Digital Personal Data Protection Act, 2023.

This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!

This Privacy Policy applies from July 4, 2024.

TABLE OF CLAUSES

1. WHO WE ARE
2. COLLECTION OF INFORMATION
3. REASONABLE SECURITY PRACTICES AS PER THE INFORMATION TECHNOLOGY ACT, 2000 AND ITS RULES
4. PROFILE INFORMATION
5. PROFILE VERIFICATION INFORMATION (INCLUDING BIOMETRIC INFORMATION)
6. PURCHASES INFORMATION
7. GEOLOCATION INFORMATION
8. DEVICE AND PHOTOS INFORMATION
9. ADDRESS BOOK ACCESS
10. PROFILE SHARING
11. EXTERNAL THIRD PARTY LINKS
12. COOKIES
13. OPTING OUT
14. LOG FILE INFORMATION
15. INFORMATION FROM OTHER SOURCES
16. USE OF YOUR INFORMATION
17. WHY WE NEED THE INFORMATION WE ARE ASKING FROM YOU
18. SERVICE PROVIDERS
19. DATA RETENTION AND DELETION
20. YOUR RIGHTS
21. INFORMATION SHARING
22. CHILDREN'S PRIVACY
23. CHANGES TO THIS POLICY
24. GRIEVANCE REDRESSAL MECHANISM
25. GEOLOCATION DATA USAGE

1. WHO WE ARE

The App and Sites are operated by the NeoMaxer Fintech Private Limited (also referred to in this policy as "we", "us", "Company"). The NeoMaxer has designated a Data Protection Officer and they can be reached by emailing connect@neomaxer.com or by post at the following address: Neomaxer Fintech Pvt Ltd, Tower B, Brigade Tech Park, Pattandur Agrahara, Whitefield, Bengaluru, KA - 560066.

We respect the privacy of our User(s) and, committed to protect it in all respects. Any dispute with our company over any privacy matters are subject to this Privacy Policy read in conjunction with the 'Terms of Use' published on our Website(s)/Mobile Application(s) of NeoMaxer.

By accessing and/or using the Website(s)/Mobile Application(s), the Users signify their agreement to accept this Privacy Policy. IF YOU DO NOT AGREE WITH ANY OR ALL OF THE FOLLOWING TERMS OF THE PRIVACY POLICY, PLEASE DO NOT ACCESS AND/OR USE THE WEBSITE(S)/MOBILE APPLICATION(S) OF NeoMaxer.

2. COLLECTION OF INFORMATION

Registration Information

When you download the App and create an account ("Account"), we may collect certain information ("Registration Information") about you, such as:

• Name
• Username
• Email address
• Mobile number
• Gender identity
• Date, time, and location of birth
• Photographs
• Location

Once you register, you will be able to review and change this information at any time just by logging in to NeoMaxer (other than your date of birth and location, which, if you have given NeoMaxer access to your location in your device settings, is automatically updated based on the Geo-location of your device). It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

For Users who are California residents, the data we may collect falls within the following categories of "personal information", as defined by the California Consumer Privacy Act (CCPA):

• Identifiers, such as name and location
• Personal information, such as contact and financial information
• Protected classifications, such as age, gender identity, marital status, race, etc.
• Commercial information, such as transaction and purchase history
• Biometric information
• Internet/network activity like browsing history and app interactions
• Geolocation data
• Audio, electronic, and visual information (e.g., photos and videos)
• Professional or employment-related data
• Non-public education information
• Inferences drawn from personal data to build a user profile

When registering in India, "Personal Information" is defined under the SPDI Rules as any information that relates to a natural person and can identify them directly or indirectly.

"Sensitive personal data or information" (SPDI) includes:

• Passwords
• Financial details (e.g., bank accounts, card details)
• Physical, physiological, and mental health conditions
• Name, age, address, contact info, date of birth, sexual orientation
• Medical records/history
• Biometric data
• Information received under lawful contract
• Visitor details during registration
• Call data records

All of the above is collectively referred to as "Personal Information."

The information we collect comes from:

• Information supplied by users
• Information automatically tracked during navigation

By accessing and using our App/Sites and services, you voluntarily consent to the collection, storage, and use of your Personal Information, including updates you may provide at a later stage, for availing services from NeoMaxer.

To avail certain services, Users may need to provide registration data including:

• Name
• Phone Number
• Email Address
• Physical Address
• Gender
• Photos
• Biometrics
• Age
• GPS Location
• PIN Code

We presume lawful parental consent if any user under the age of 18 shares their Personal Information.

The information as supplied by the User(s) enables us to improve our Website(s)/Mobile Application(s) of NeoMaxer and provide back to the User(s) the most user-friendly experience. All required information is service dependent and We may use the above said User(s) information to maintain, protect, and improve our services (including advertising services) and, also for developing and providing other new services for our User(s).

It is clarified that any information shall not be considered as sensitive in case it is freely available and accessible in the public domain or is furnished under the Right to Information Act, 2005 and any rules made thereunder or, any other law for the time being in force. The primary reason for gathering information is to improve our products, deals, services, website content and navigation.

3. REASONABLE SECURITY PRACTICES AS PER THE INFORMATION TECHNOLOGY ACT, 2000 AND ITS RULES

We have implemented reasonable security practices as per Rule 8 of the SPI Rules as mentioned above and the Information Technology Act, 2000 amended through the Information Technology Amendment Act, 2008 and The Digital Personal Data Protection Act, 2023.

We have implemented stringent, internationally acceptable standards of technology, managerial security, technical security, operational security and physical security in order to protect your personally identifiable information from loss, misuse, disclosure, alteration or destruction. We have been assured by the third-party cloud service providers (such as Google Cloud Services, Amazon Web Services and GoDaddy) that the data collected by us is managed and stored firmly and securely as per the globally accepted best practices.

We have implemented “Reasonable Security Practices” as required by the Information Technology Act, 2000 and the SPI Rules. By complying with such provisions, we assure our User(s) proper care and control over our I.T. and Security operations as required under relevant sections i.e. sections 43, 43A, 45, 66, 72A & 85 of the Information Technology Act, 2000 read with the Information Technology Amendment Act, 2008 and including related rules made therein. However, NeoMaxer or its directors, shareholders, employees, and any other related persons (whether directly or indirectly) shall not be held responsible for any fraudulent/criminal activity in regard to misuse or unauthorized use of your sensitive personal information stored in our Website(s)/Mobile Application(s) of NeoMaxer.

By accessing/using our Website(s)/Mobile Application(s) of NeoMaxer, User(s) agree that We shall not be held responsible for any uncontrollable security attacks and any consequential losses (whether directly or indirectly) including financial losses, loss of opportunity, legal cost, attorney's fees, business losses, reputation loss, direct and indirect losses that may occur to the User(s), as per the statutory provisions of Section 43, 43A and 45 of the Information Technology Act, 2000 including any amendments in the said Act and any other laws of India for the time being in force.

You further agree that our management shall not be held responsible directly or indirectly for any cybercrime-related criminal liabilities under the Information Technology Act, 2000/2008 relating to your information, as you have agreed and acknowledged that our management complies with due diligence (care & controls) requirements of the Information Technology Act, 2000 including its rules and amendments.

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures, including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data.

All information gathered on our Website(s)/Mobile Application(s) of NeoMaxer is securely stored and managed by us on third-party cloud service provider's servers which may or may not be based in India. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply will not be intercepted while being transmitted to us over the internet. In any case, we take all reasonable efforts that any personal information provided by you to us is transmitted through modern cryptography (secure HTTPS connection). User(s) agree that any information you include in a posting to the public discussion areas on our Website(s)/Mobile Application(s) of NeoMaxer is available to anyone who has access to our Website(s)/Mobile App of NeoMaxer.

However, the internet is an ever-evolving medium. We may change our Privacy Policy from time to time to incorporate in lieu of necessary future changes and/or to comply with amendments in the existing laws, including but not limited to cover other technical upgradation (if any) that may come from time to time. Of course, our use of any information we gather will always be consistent with the policy under which the information was collected, regardless of what the new policy may be, provided that the same is not also contrary to the existing laws at the relevant time in future.

4. PROFILE INFORMATION

We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, Aadhar number, driver's license details and other sensitive information which is open to abuse and misuse on your profile. When you post information about yourself or use the messaging function to communicate with other Users, the amount of personal information you share is at your own risk.

5. PROFILE VERIFICATION INFORMATION (INCLUDING BIOMETRIC INFORMATION)

To provide you with the best and safest user experience, we may implement account verification measures. This may include requesting your phone number and, in some cases, photo verification. Our goals are twofold:

1. To confirm you're a real person, not a bot.
2. To prevent the creation of fake accounts that could be used for harmful activities or cybercrime, which threaten our community's integrity.

These verification steps are crucial in our fraud prevention efforts.

6. PURCHASES INFORMATION

If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes. NeoMaxer uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked.

7. GEOLOCATION INFORMATION

If you have given NeoMaxer access to your location in your device settings, when you use your cell, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device's coordinates to offer certain features to you. This information helps us identify your physical location and we use it to personalize the App and make it easier for you to interact with other Users, by enabling the general locality information to be displayed to Users seeing your profile and showing you the profiles of other Users who are near you.

8. DEVICE AND PHOTOS INFORMATION

We may request permission to access your device’s camera, microphone, and photo library for profile photo uploads and certain interactive features. This access will always be subject to your explicit consent, and you may revoke these permissions at any time via your device settings.

9. ADDRESS BOOK ACCESS

If you grant permission, we may access your device's address book. This access is strictly limited to adding contacts at your request.

10. PROFILE SHARING

By using our services, you acknowledge and consent to the automatic sharing of your profile information with individuals and entities within your geographical location. This feature is designed to enhance local connectivity and provide relevant local services. The shared profile information may include, but is not limited to, your name, contact details, and relevant personal and professional information. We ensure that your data is handled securely and in compliance with applicable privacy laws. If you have any concerns or wish to opt-out of this feature, please contact our support team.

11. EXTERNAL THIRD PARTY LINKS

We may keep track of how you interact with links available on NeoMaxer including third party services by redirecting clicks or through other means.

12. COOKIES

To improve the responsiveness for our User(s), we may use "cookies", or similar other electronic tools to collect information in order to assign each user a unique, random number as a user identification ("User ID") to understand each and every user's individual interests using their identified computer/mobile devices. Unless you voluntarily identify yourself (through registration, for example), we will have no way of knowing who you are, even if we assign a cookie to your computer/mobile devices. A cookie also cannot read data off your hard drive.

The Android and iOS applications do not use "cookies" explicitly. However, our Website(s)/Mobile Application(s) of NeoMaxer may use third party code and libraries that use "cookies" to collect information and improve their services. User(s) have the option to either accept or refuse these cookies and, to know when a cookie is being sent to your device. However, in case the User(s) choose to refuse our cookies, he/she may not be able to use some/complete portions of our services.

Advertisers using the platform of our Website(s)/Mobile Application(s) of NeoMaxer to advertise may also assign and use their own cookies to your browser, a process that we do not control.

Once the User(s) permit, We may obtain additional information such as list of apps installed on your device, device information, location, network carrier ("Information") available on your device, to personalize your experience and improve the app suggestions. This data may also be used at our end to take necessary business decisions.

We assure that all or any information of the User(s) shall not be shared with any third party and shall be purely utilized for enhancing each user experience and personalizing the services within NeoMaxer networks.

13. OPTING OUT

In case any of the User(s) wish to opt out of storing cookies, the said user has an option to remove/block cookies in the corresponding internet browser's settings. However, this may have a direct impact upon the corresponding User(s)'s experience of our services.

14. LOG FILE INFORMATION

It is necessary to inform and clarify our User(s) that:

1. We automatically collect limited information about your computer's or mobile's connection to the internet, mobile number/email address (if applicable), including your IP address, when you visit our Website(s)/Mobile Application(s) of NeoMaxer.
2. Your IP address is a number that lets computers attached to the Internet know where to send you data – such as the pages you view.
3. We automatically receive and log information from your browser, including your IP address, your computer's name, your operating system, browser type and version.

15. INFORMATION FROM OTHER SOURCES

1. We may receive information about you from other sources, add it to our account information and treat it in accordance with this Privacy Policy.
2. If you provide information to the platform provider or other partner, whom we provide/receive services from, your account information and order information may be passed on to us.
3. We may obtain updated contact information from third parties in order to correct our records and fulfill the services or to communicate with you.

16. USE OF YOUR INFORMATION

Our goal is to ensure your experience on NeoMaxer is an enjoyable one and you don't end up getting stung! In order to deliver an enjoyable experience to you, we may use your Registration and other information to:

1. Offer you our services and features;
2. Contact you with information about the App (e.g., updates and new features);
3. Personalize the App/Sites and the content we deliver to you;
4. Conduct research and analytics about how you use and interact with the App/Sites;
5. To test new technologies and processes designed to enhance and improve the App/Sites;
6. Resolve disputes, troubleshoot problems and to enforce our Terms & Conditions;
7. Investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
8. To send you information about the promotions and offers we have available (e.g., specify the types of goods/services/offers to be provided via direct marketing) by direct marketing or other modes of communication.
9. We will not use your information in email direct marketing unless you give us your consent during the Account creating process or via Settings in the App (you can withdraw from marketing at any time via Settings in the App or by using the opt-out mechanisms and links provided in each message); and
10. Protect our Users and third parties from harm.

17. WHY WE NEED THE INFORMATION WE ARE ASKING FROM YOU

Under the Digital Personal Data Protection Act 2023, European Union and United Kingdom data protection laws, we are required to tell you our reason for using your data and we have set this out in the table below.

18. SERVICE PROVIDERS

We may engage certain trusted third parties to perform functions and provide services to us ("Service Providers"). The suppliers with which NeoMaxer shares User personal data vary depending on a variety of factors, such as which of our App, Sites and services a User engages with. For example, to provide our services to Users, we typically use the following suppliers:

• Billing services to allow customers to purchase paid features of our App (for example, Google Play).
• Authentication services to allow customers to authenticate their account (for example, Twilio).
• Social media providers to allow customers to create/connect their NeoMaxer account with their account(s) on such platforms (for example Facebook, Instagram).

We carry out due diligence on all Service Providers we engage to ensure they have adequate data protection and information security measures in place and only provide them with the personal data necessary for the service they are providing.

Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible, and our suppliers are also subject to extensive obligations under our contractual arrangements, including strict data retention limits.

19. DATA RETENTION AND DELETION

We keep your personal information only as long as we need it for the legal basis relied upon as mentioned in the above table WHY WE NEED THE INFORMATION WE ARE ASKING FROM YOU section and as permitted by applicable law. Please see PROFILE VERIFICATION INFORMATION (INCLUDING BIOMETRIC INFORMATION) section above, to learn about our retention policy with respect to biometric information.

When your Account is deleted, we make sure it is no longer viewable in the App. For up to 180 days, it is still possible to restore your Account if it was accidentally deleted. After 180 days, we begin the process of deleting your personal information from our systems, unless:

1. We must keep it to comply with applicable law (for instance, if you make purchases within the App, some personal data may be kept for tax and accounting purposes);
2. We must keep it to evidence our compliance with applicable law (for example, if an account is blocked, we keep some account information and a record of the behaviour that led to the block; this information is retained for evidential purposes in case of queries or legal claims concerning the block);
3. There is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
4. The information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users' safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account).

20. YOUR RIGHTS

Privacy laws applicable in your country may give you the following rights:

1. Right to be informed: what personal data an organization is processing and why (we provide this information to you in this Privacy Policy).
2. Right of access: you can request a copy of your data.
3. Right of rectification: if the data held is inaccurate, you have the right to have it corrected.
4. Right to erasure: you have the right to have your data deleted in certain circumstances.
5. Right to restrict processing: in limited circumstances, you have the right to request that processing is stopped but the data retained.
6. Right to data portability: you can request a copy of certain data in a machine-readable form that can be transferred to another provider.
7. Right to object: in certain circumstances (including where data is processed on the basis of legitimate interests or for the purposes of marketing) you may object to that processing.

The particular rights which are applicable to you (which might include other rights not listed above) may vary depending on your country. You should make yourself aware of the rights you have under applicable privacy laws in your country.

If you want to exercise any of your rights listed above, please write to our Data Protection Officer. For your protection and the protection of all of our Users, we may need to request specific information from you to help us confirm your identity before we can answer the above requests.

If you have a concern about how we have processed your request or your personal data, you should contact us in the first instance via the contact details listed above.

21. INFORMATION SHARING

NeoMaxer may share the sensitive Personal Information to any third-party including Government Bodies / Government agencies / Government authorities/ Service Provider / Alliance Partner without obtaining the prior consent of the User(s) in the following limited circumstances:

a. When it is requested or required by law or by any court or governmental agency or authority to disclose, for the purpose of verification of identity, or for the prevention, detection, investigation including cyber incidents, or for prosecution and punishment of offences. These disclosures are made in good faith and belief that such disclosure is reasonably necessary for enforcing the Privacy Policy and Terms of Use and also, for the purpose of complying with the applicable laws and regulations during relevant time.

b. NeoMaxer proposes to share such information within its group companies/affiliated companies and officers and employees of such group companies/affiliated companies for the purpose of processing Personal Information on its behalf. We also ensure that these recipients of such information agree to process such information based on our instructions and in compliance with this Privacy Policy and Terms of Use also published at our Website(s)/Mobile Application(s) of NeoMaxer The said group companies/affiliated companies also ensure that the Personal Information shared with them is not transferred to any third party, except as provided under this clause.

c. NeoMaxer may use third-party advertising companies to serve ads when the User(s) visit our Website(s)/Mobile Application(s) of NeoMaxer. These companies may use Personal Information (non-sensitive personal information only) about the User(s)'s visit to our Website(s)/Mobile Application(s) of NeoMaxer and other third party websites in order to provide advertisements about goods and services of interest to any particular User(s).

d. NeoMaxer shall transfer information about the User(s) in case it is acquired by or merged with another company.

22. CHILDREN'S PRIVACY

Our service is restricted to individuals who are 18 years of age or older. We do not permit individuals under the age of 18 on our platform. If you suspect that a member is under the age of 18, please use the reporting mechanism available on the service.

23. CHANGES TO THIS POLICY

As NeoMaxer evolves, we may revise this Privacy Policy from time to time. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within NeoMaxer.

24. GRIEVANCE REDRESSAL MECHANISM

User(s) and/or any other person, whosoever has any grievances of any kind, are requested to send an email at connect@neomaxer.com for necessary action: We will be happy to provide any other necessary clarification in regard to this Privacy Policy or may help you to understand the implications of the same. Further, we may also help you in providing other information, at your request, with respect to our operations, as may be deemed reasonable by us. For the said purpose, you may reach out to the above-mentioned email address/postal address. The said request may take some time to be processed.

25. GEOLOCATION DATA USAGE

NeoMaxer may access and collect location data from your device to enhance your experience and provide location-based services. This data is used to:

1. Personalize your experience by showing relevant products and services.
2. Enable location-based features, such as nearby store recommendations and service availability.
3. Improve security and fraud prevention, ensuring compliance with our policies.

NeoMaxer does not share your precise location with third parties without your consent. Users can manage or disable location access at any time through their device settings. However, restricting location access may impact certain features of the app.