Neem Exponential Financial Services (Private) Limited (“Neem”, “Company”, “we”, “us” or “our”) operates the website located at www.neem.io and other related websites, domains, sub-domains and mobile applications with links to this policy (collectively, the “Platform”). We have developed this privacy policy (the “Privacy Policy”) to explain what, how and why we collect, use and disclose information from and/or about you when you use the Platform or our services. We are committed to protecting and respecting your privacy.
The terms “you” and “your” refer to the user of the Platform and our services. The term “Services” and/or “Products” refers to any services/products offered by Neem whether on the Platform or otherwise. Please read this Privacy Policy before using the Platform or submitting any personal information to Neem.
All visitors to the Platform are advised to read and understand this Privacy Policy carefully, as by accessing the Platform, you agree to be bound by the terms and conditions of the Privacy Policy and consent to the collection, storage and use of information relating to you as provided herein.
BY USING THE PLATFORM, YOU AGREE THAT WE CAN COLLECT AND USE YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. BY USING THE PLATFORM, YOU AGREE TO THE CONTENTS OF THIS PRIVACY POLICY GIVE YOUR CONSENT TO US FOR COLLECTING YOUR PERSONAL INFORMATION.
This privacy policy explains:
- what information we collect and why we collect it;
- how we use that information; and
- the choices we offer, including how to access and update information.
We have tried to keep the Privacy Policy as simple as possible, but if you are not familiar with terms like cookies, IP addresses, pixel tags and browsers, then read about these key terms first. Your privacy matters to us so please do take the time to get to know our practices and if you have any questions feel free to contact us by sending an email to info@neem.io.
Changes to this privacy policy
We may update/change this Privacy Policy from time to time in response to changing legal, technical or business developments. Any changes we may make to this Privacy Policy in the future will be posted on the Platform and, where appropriate, notified to you when you next start/open/log in the Platform. Once posted on the Platform, the new/amended Privacy Policy will be effective immediately. The new/amended terms may be displayed on-screen and you may be required to read and accept them to continue your use of the Platform or the Services, including any additional terms of use apply to your use of any other linked website(s)/app(s).
This Privacy Policy sets out the basis on which any personal data we collect from you with your consent, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. Please also note that the personal data that may be collected by Neem will only be used for the purpose of determining whether you are eligible or not for Neem Services and the terms and conditions of such Services.
Legal rules we follow
As a regulated entity, Neem works under specific legal laws, rules and regulations including, but not limited to:
You, as a User, shall also be subject to the above mentioned laws.
Collection of information
In order to enhance the user experience and provide our Services, we collect, process and store personal information provided by you from time to time on the Platform., Company collects information about you: (a) information you affirmatively and voluntarily give to us; (b) information automatically collected when you visit the Platform or use any of our Services; and (c) information we receive from other valid sources such as third party information.
Information we may collect from you
This includes information submitted when you:
- Create, register or update your Neem account, which may include your name, age, CNIC number, email, phone number, username and password, address, payment or banking information, date of birth and profile picture.
- Create, register or update your account on such platforms that the Platform is imbedded in.
- Use and/or subscribe to our Services.
- Subscribe to our newsletters or promotions.
- When you report a problem with the Platform and/or our Services, while corresponding with us for customer support, including your name, address, e-mail address and phone number, the handheld or mobile device (the “Device”) phone number, SIM card, age, username, password, and other registration information, financial and credit information, personal description, and/or photograph.
- Contact us for information, questions or feedback about our Products and Services.
- Make an online payment, including your payment information, credit/debit card details, one-time passwords and other related information.
- Report problems for troubleshooting.
Information we collect about you and your Device
Regarding each time you visit the Platform, we may automatically collect and analyze the following information:
- When you communicate with us via our customer services department i.e. chat service, email, phone, through the Platform or otherwise, we may maintain a record a copy of your communication and your feedback/suggestions to us. We may ask for additional information to verify your identity;
- Where you have signed up for Services, we may collect information including but not limited to basic know-your-customer (KYC) information, name, CNIC number (including picture of front and back side of the card, a picture of your face along with CNIC, full name, CNIC number, issue date, expiry date, date of birth, city of birth, mother’s name), phone number, email address etc., current residential address, city, gender and marital status;
- Your employment, business or any additional information which is included in your loan KYC form.
- Your preferences for particular Products and Services, based on information provided by you or from your use of ours (or third party) network, products and services.
- E-Wallets account and communication date: details pertaining to your e-wallet account, including account number or username, account balance, transaction history and linked payment methods.
- Unique application numbers: When you install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us;
- Location information: Depending on the Services that you use, and your app settings or Device permissions, we may collect your real time information, or approximate location information as determined through data such as GPS, IP address;
- Usage and Preference Information: We collect information as to how you interact with our Services, preferences and settings chosen including the last time you used them, the duration of usage, the quantity of transactions made, the timing of such transaction and your activity or in-activity on the Platform;
- Geo-location Data: when you use our telecommunication Services, including call, SMS or broadband services, we may collect your geo-location data. If you opt for location-based services, such as directional applications on your Device or participate in location-based promotional activities, your geo-location data may be captured.
- Device Information: We may collect information from and about the devices you use to access our Platform and/or Services, including, IP address, the type of mobile device you use, mobile network information, mobile network information, your device operating system, operating systems and versions, software and hardware attributes, pages viewed, number of sessions, unique visitors, file names and versions, preferred languages, the type of browser you use and browsing patterns, your Device’s location and time zone setting (Device Information), traffic data, location data, weblogs and other communication data (Log Information) and/or details of how you have interacted with our Services and Platforms. In addition we gather statistical information about the Platform and visitors to the Platform including, browser software, operating system, software and hardware attributes, pages viewed, number of sessions and unique visitors. Collecting this information enables us to better understand the visitors who come to our Platform, where they come from, and what content is of interest to them. We use this information for our internal analytics purposes and to improve the quality and standard of our Platform. Some of this information may be collected using cookies and similar tracking technology;
- Stored information and files: Depending on your app settings or Device permissions, we may also access metadata and other information associated with other files stored on your Device. This may include, for example, photographs, personal contacts and address book information. If you permit the Platform to access the address book on your Device, we may collect names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Privacy Policy or at the time of consent or collection;
- Transaction Information: We collect transaction details related to your use of our Services, and information about your activity on the Services, including the full Uniform Resource Locators (URL), the type of Services/Products you requested or provided, comments, domain names, search results selected, number of clicks, information and pages viewed and searched for, the order of those pages, length of your visit to our Services, the date and time you used the Services, amount charged for every transaction made, details regarding application of promotional code, methods used to browse away from the page and any phone number used to call our customer service number, the amount of money in your account, timing of the transactions made, general details about recipient of the transactions being made from your account and other related transaction details.
Information we receive from other sources
- We may receive information about you from third parties, such as mobile wallet operators, financial institutions, credit bureaus, duly licensed lenders, other users, partners (including ad partners, analytics providers, search information providers), or our affiliated companies or if you use any of the other websites/apps we operate or the other Services we provide.
- We may receive personal information about you from third parties that are engaged by us to assist with providing verification services and conducting suitable money laundering and KYC and AML (anti-money laundering) checks on users of the Platform. This may include your name, email address, company details and contact information.
- If you choose to participate in reviewing or rating the Services on the Platform, we may receive personal information about you from third parties that work with us to conduct reviews into our Services and/or rate us.
- Subject to your consent, we may collect your information and activity from payment providers, advertising networks, analytics providers, search information providers and social media platforms.
- We may collect social media information you use to log in and interact with our Platform, as long as you agree to share such information with us.
Removal of consent for collecting further information
You may withdraw your consent for further collection of the above information at any time by logging out and uninstalling the Platform from your Device.
Tracking and cookies
Neem may use mobile tracking technologies and/or website cookies to distinguish you from other users of the Platform. This helps us to provide you with a good experience when you use the App or browse any of the sites and also allows us to improve the App and our sites.
A “cookie” is a small piece of information stored on a web browser/device so it can be later read back. Cookies are useful for enabling the browser/device to remember information specific to a given user. We place both permanent and temporary cookies. The cookies do not contain any of your personally identifiable information.
Uses made of the information
Neem may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Privacy Policy.
Information collected by us shall be used for the purpose of:
To allow you to use Services on the Platform, like:
- Managing your account;
- Performing payments;
- Carrying out credit checks;
- Providing you with lending and insurance products;
- Communicating with you.
To allow you to undertake or initiate any transactions on the Platform;
- For our internal record keeping, quality assurance, training and feedback;
- To improve our Services;
- To improve your usage of the Platform, improve User experience and etc.
- To process payments with respect to transactions initiated on the Platform;
- To communicate important notices or changes to the Services provided by Company on the Platform, use of the Platform and the terms/policies which govern the relationship between you and the Company;
- or internal purposes of the Company such as auditing, data analysis and research conducted either indirectly/directly by Company. Personal, aggregated statistics and de-identified information related to sales, Services, customers, network traffic and location patterns are analyzed;
- creating User profiles to offer you personalized content, Products and Services, ensuring that you receive recommendations aligned with your interests;
- or promotion and marketing purposes by Company;
- for any other purposes with your consent; and/or
- for determining whether or not to provide a financial service or product to you and the amount of such exposure and the terms and conditions applicable to such services or product.
From time to time, we may use your information to customise, develop and improve the Platform and/or Services according to your interests.
Disclosure of your information
Neem does not disclose information about identifiable individuals to other parties, but we may provide them with anonymous, encrypted and/or anonymised aggregate information/data about our users. We will use your data for the purposes of compiling statistics relating to our user base or financial product or services and may disclose such information to any third party for such purposes, provided that such information will always be anonymous. Should we wish to use your information for marketing purposes, we will inform you prior to such use. You shall be entitled to prevent such usage by informing us, within ten (10) days of being informed of the proposed use, that you do not wish to disclose such information. You can also exercise the right at any time by contacting us at info@neem.io
Data collected from you from the Platform shall only be used for the uses mentioned above other than that, Neem may disclose some or all of the data to:
- Regulated entities: connect to mobile wallet providers, credit bureaus, NADRA, banks, lenders, insurers, or other partner financial and non-financial institutions.
- Neem’s affiliate companies: any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries.
- Law enforcement agencies: any local or international law enforcement, court of competent jurisdiction, competent regulatory or governmental agencies so as to assist in the prevention, detection, investigation or prosecution of criminal activities or fraud.
- Financial technology providers: We collaborate with financial technology providers who develop and offer various financial products; your information may be shared with them in this context.
Third parties in following cases:
- With prospective business partners or in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; If Neem or substantially all of its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets;
- if you request for integration with third party services, such as social networks, we may share your information as needed to enable these integrations; and
- you consent to such disclosure to the relevant third parties.
- Debit collection agencies and credit check agencies: we may engage third party service providers, such as debit collection agencies and credit check agencies, as necessary.
- Advertising, measurement and analytics partners: following your consent, we may collaborate with third parties for advertising, measurement and analytics purpose.
- comply with our duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
- enforce our terms and conditions and other agreements or to investigate potential breaches.
- publish statistics relating to the use of the Platform, in which case all information will be aggregated and made anonymous.
- protect us from incurring any legal liability. In such an event we shall be under no obligation to specifically inform you or seek your approval or consent.
- protect the personal safety of you, the Company, its members and employees, or any person, in any emergency.
- Agencies, counsels and/or any of our other agents to enforce Neem’s rights against you.
- Third party service providers solely for the purpose of assisting or rendering services to us in the administration of our Services.
- The information collected from you may also be used by us to file a complaint against you and to initiate or commence proceedings against you for recovery of outstanding amounts.
- Third parties for the purpose of insuring Neem from users of the Platform in relation to default or other credit loss and safeguarding you from fraud or unauthorized charges.
Where Neem stores your personal data and its protection
All data and information is saved and stored on servers, which are secured with passwords and pins to ensure no unauthorized person(s) has access to it. Once your information is in our possession, we adhere to strict security guidelines, protecting it against unauthorized access. We shall take reasonable steps to help protect your rights of privacy and your information (personal or otherwise) in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, or destruction of such information, in compliance with the applicable laws. However, we cannot guarantee security of your stored data and information.
The data that we collect from you may be transferred to, and stored at, a destination inside Pakistan. By submitting your personal data, you agree to this transfer, storing or processing.
We take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share your username and password with anyone.
In addition to the above, we protect your information through:
- Data encryption: When you use our services and log into your account, we protect your data by turning it into secret code using strong security methods like TLS and SSL. We use this encryption on all our web pages where we collect personal info. To buy things on these pages, you need to use a secure browser like Internet Explorer, Safari, Firefox, or Chrome. This keeps your personal data private when it travels over the Internet.
- Auto logout: If you're not active in your account for a while, we'll automatically log you out to keep your information safe.
- Third-party protection: When we get help from other companies to handle your personal info, we make sure they follow strict rules to protect it. They have limited access to the data and must obey the law. We also make sure our products and services are built with privacy and data protection in mind from the start.
Retention of information
We will exclusively handle your personal information for lawful purposes and solely for the duration required to fulfil those objectives. Once your personal information is no longer needed, we will securely and responsibly dispose of it, adhering to relevant data retention laws. As an illustration, the State Bank of Pakistan mandates the retention of customer records for a period of 10 years.
Consent and authorisation to use of information
By using our Platform, you agree and consent, without any reservation:
- To allow us to access any and all information and data about you or contained in your mobile device, in the manner detailed in this Policy;
- To allow us to access any and all information and data about you or contained in your mobile device, in the manner detailed in this Policy;
- To allow us to use all such information and data in such manner as we may deem fit for our purposes, including sharing the data with one or more third parties inside Pakistan, without any commercial benefit of the same to you;
- To allow us to store and utilise the data for such period of time as we deem fit for our purposes;
- To allow us to use the data so collected for any purpose in pursuance to your use of the Platform.
Your consent is of your own free will, without any duress or coercion of any nature. By using our Platform, you confirm unequivocally that you have read the Policy and are aware of and have no objection to the collection, storage and use of your data by Neem.
Your rights
We place great importance on ensuring your awareness of your privacy rights. To that end, we have outlined a non-exhaustive list of privacy rights that you can exercise while entrusting us with your information:
- Right to revoke consent: If you have granted consent for us to utilise, process, or share your personal data, you have the option to withdraw that consent at any time, unless the information is essential for us to carry out our services.
- Right to access your information: You have the ability to access and request a copy of the personal data we hold about you whenever you wish. You can do this by getting in touch with us or by accessing the information directly through your e-wallet account.
- Right to deletion: You can request that we delete specific portions of the personal data we have on you, provided certain conditions are met:
- The information is no longer necessary for our purposes, and there is no legal requirement for us to retain it.
- Other legal justifications that permit you to make such a request.
While we will make every effort to accommodate your request, please keep in mind that this may render you ineligible for certain services. Your privacy matters to us so please do take the time to get to know our practices and if you have any questions feel free to contact us by sending an email to info@neem.io.
