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NeoSpend Privacy Policy

Effective Date: 1st November, 2025

1. Introduction

At NeoSpend Inc. (“NeoSpend”, “we”, “our”, or “us”), your privacy matters to us. We believe in being transparent about how we handle your personal information and in giving you control over your data. This Privacy Policy explains what information we collect, how it is used, when it may be shared, and the choices available to you.

If you have any questions or requests regarding your personal information, please contact us:
NeoSpend Inc.
Email: hello@neospend.com

2. Scope of this Policy

This Privacy Policy applies to your interactions with any NeoSpend product, service, or communication channel, including:

  • The NeoSpend mobile applications (iOS and Android);
  • The NeoSpend website at https://neospend.com;
  • Customer support (email, chat, phone);
  • Social media interactions;
  • Marketing campaigns, newsletters, or promotions conducted by NeoSpend.

This policy covers all activities where NeoSpend determines the purposes and means of processing personal information.

3. What We Mean by “Personal Information”

“Personal information” refers to any data that identifies or can reasonably be linked to an individual. This includes identifiers such as your name, contact details, banking connections, and device data. Information that has been aggregated, anonymized, or de-identified so it can no longer reasonably identify you is not considered personal information under this Policy.

4. When This Policy Does Not Apply

This Policy does not govern how third parties handle your data. For example:

  • When you connect your financial accounts through Plaid, or other integration partners, your data is handled in accordance with their privacy policies.
  • Your financial institutions (banks, credit card issuers, or lenders) maintain their own privacy practices.We recommend reviewing those policies before authorizing any data connections.

NeoSpend is not responsible for third-party data handling practices, technologies, or breaches outside our direct control.

5. What Information We Collect

We collect personal information in several ways — directly from you, automatically through your use of our Services, and from authorized third parties you choose to connect.

a. Information You Provide

  • Name, email address, and authentication credentials (e.g., Apple ID, Google Sign-In).
  • Financial account links and identifiers.
  • Communication content (emails, chats, support tickets).
  • Marketing preferences and consent indicators.

b. Financial Data (via Secure Partners)

With your explicit consent, we may access:

  • Account balances and transaction histories,
  • Loan, credit card, and investment account information,
  • Account metadata required to categorize and display your finances.All such connections occur through read-only, encrypted APIs provided by Plaid, or similar secure aggregators.

c. Automatically Collected Data

When you use our App or Website, we automatically collect:

  • Device information (IP address, operating system, device ID);
  • Usage metrics (app navigation, page visits, feature interactions);
  • Error logs, performance diagnostics, and crash analytics;
  • Time and date of access, referral sources, and session duration.

d. Marketing & Analytics

If you opt in, we may use third-party analytics and advertising tools (e.g., Google Analytics, Firebase, Adjust, Meta Ads) to measure engagement and deliver relevant promotions.

6. How We Use Your Information

We process personal information to:

  • Provide, maintain, and improve our Services;
  • Verify identity and secure your account;
  • Connect to and retrieve information from linked financial institutions;
  • Deliver personalized insights, alerts, and financial recommendations;
  • Communicate with you (support, updates, notifications);
  • Conduct internal analytics and market research;
  • Deliver marketing communications (only with your consent);
  • Comply with applicable legal and regulatory obligations.

We never use personal information for automated decision-making that produces legal or significant effects without your knowledge or consent.

7. Cookies and Tracking Technologies

We use cookies, pixels, and mobile identifiers to:

  • Maintain essential app functionality;
  • Analyze performance and usage trends;
  • Personalize user experience;
  • Deliver interest-based advertising (if consented).

You can manage or disable cookies through your browser or device settings. Certain features may not function properly without essential cookies.

8. Interest-Based Advertising (Optional)

Where permitted by law and with your consent, NeoSpend may use behavioral data to display relevant ads on our Website, App, or partner platforms. You may opt out of such personalized ads by adjusting your cookie preferences, device advertising settings, or visiting YourAdChoices.ca.

9. Information Sharing and Disclosure

We do not sell your personal information. We only share information with trusted service providers and partners under contractual confidentiality and data protection obligations, including:

  • Financial data connectors (Plaid);
  • Hosting and infrastructure providers (i.e., Google Cloud).
  • Analytics and monitoring tools;
  • Marketing and communications platforms;
  • Legal, compliance, or regulatory authorities (when required by law).

In cases of mergers, acquisitions, or business transfers, user data may be transferred as part of that transaction, subject to continued privacy protections.

10. Data Storage and International Transfers

Data is primarily stored on secure servers in Canada. Some partners may process or store data in other jurisdictions such as the United States. Whenever cross-border transfers occur, NeoSpend implements contractual, technical, and organizational safeguards to maintain privacy and data integrity consistent with Canadian standards.

11. Data Retention

We retain personal information only for as long as:

  • Required to operate and improve our Services;
  • Necessary to comply with legal, tax, and regulatory obligations;
  • Needed to resolve disputes or enforce agreements.

Aggregated analytics data may be stored for up to two years, after which it is de-identified or deleted.

12. Safeguards and Security

NeoSpend uses industry-recognized security measures, including:

  • End-to-end encryption (in transit and at rest).
  • Secure read-only access via Plaid.
  • Access restrictions and multi-factor authentication.
  • SOC 2-compliant hosting infrastructure.
  • Continuous system monitoring and independent audits.

Despite these safeguards, no system is completely immune from security risks. By using our Services, you acknowledge that transmission of data over the internet involves inherent risks beyond our control.

13. Communications and Notifications

  • Push Notifications: Optional; you may disable them through your device settings.
  • Marketing Emails: Sent only with your consent; each includes an unsubscribe option.
  • Service Announcements: Important operational or legal updates may be sent regardless of marketing preferences.

14. Your Privacy Rights (Canada)

Under PIPEDA and applicable provincial laws, you may:

  • Request access to personal information held about you;
  • Correct or update inaccurate data;
  • Withdraw consent to processing (where applicable);
  • Request deletion of your data (subject to legal or contractual retention requirements);
  • File a complaint with your local Privacy Commissioner.

Privacy Commissioner websites:

15. Limitation of Liability

NeoSpend is not liable for:

  • Damages resulting from unauthorized access caused by third-party systems or your own account misuse;
  • Data breaches occurring within third-party integrations (e.g., Plaid or banks);
  • Interruptions, loss of data, or service unavailability due to external factors beyond our control.To the fullest extent permitted by law, NeoSpend’s total liability arising from or related to this Policy shall not exceed the amount you paid (if any) for use of the Services in the preceding twelve months.

16. Changes to this Privacy Policy

We may revise this Policy periodically to reflect product updates or regulatory changes. When changes are material, we will notify users via email or in-app notice before the new version takes effect. The date at the top of this Policy always indicates its most recent update.

17. Language and Governing Law

This Privacy Policy is available in English. By using NeoSpend, you acknowledge that this Policy and all related documents are drafted in English at your request.

This Policy is governed by the laws of the Province of Manitoba and the laws of Canada applicable therein, without regard to conflict of law principles.

Summary of Key Commitments

  • We do not sell your data.
  • We use bank-level encryption and read-only financial access.
  • You can control or delete your data anytime.
  • We comply with PIPEDA and applicable Canadian privacy laws.