Privacy
Policy

UPDATED: AUGUST 2025
NeoCurrency Privacy Policy
Who We Are

NeoCurrency (“NeoCurrency,” “we,” “us,” “our”) is a modern, all-digital rewards company that specializes in using data to identify the best rewards and prizes that drive participation and purchase. NeoCurrency supplies digital rewards for loyalty programs, market research, employee incentives and sweepstakes promotions. NeoCurrency is not the creator, sponsor or issuer of the loyalty or incentive program, specific reward, issuer of the gift cards acquired through the loyalty program, nor any sweepstakes promotion. NeoCurrency solely supplies the digital rewards for loyalty programs, incentive programs, and sweepstakes promotions. NeoCurrency provides services to businesses only and not to individuals (“Services”).

What This Privacy Policy Covers

At NeoCurrency, we work hard to build and maintain a relationship of trust with you. This Privacy Policy (“Privacy Policy”) describes, among other things, what ”Personal Information” we collect about you, how we collect, use, and disclose your Personal Information as well as other information we receive in connection with your access to this website (“our Site”), the measures we take to protect your Personal Information, , how we manage your Personal Information, and how long we retain your Personal Information. It also informs you of the privacy rights you may have and how to manage them with respect to our Site. The term “Personal Information” is defined below in the section entitled “Personal Information We Collect.”

Please read this Privacy Policy carefully before accessing and using our Site. By visiting our Site or otherwise accessing or using any of our Services, or by submitting any of your Personal Information to us by any means, you are telling us that you have read and understand our privacy practices with respect to your Personal Information and other information we collect about you as described in this Privacy Policy. If you object to our privacy practices as described this Privacy Policy, you should not use any of our Services.

Please note that this Privacy Policy may change from time to time, as described below in the Section entitled “Privacy Policy Changes.”

To make it easier for you to review those parts of our Privacy Policy that apply to you or are of interest to you, we have divided this Privacy Policy into the following Sections, any of which you can click on to gain immediate access to that section:

Privacy Policy Changes

This Privacy Policy is subject to change. We reserve the right to update or modify this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, and advances in technology. Changes to this Privacy Policy will be made visible on the Site by posting at the beginning of this Privacy Policy an updated “Last Revised” date. We encourage you to review this Privacy Policy frequently for any revisions or amendments.

Children Under the Age of 13

Our Site is intended for businesses only. It also is not intended or directed for access or use by children. We do not knowingly collect, use or disclose Personal Information from children under 13. If you are under 13, do not use or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at: privacy@neocurrency.com

Personal Information We Collect

As used in this Privacy Policy, “Personal Information” means information that, on its own or in combination with other information, can be used with reasonable effort to identify an individual, including information such as, but not limited to, your name, e-mail address, physical address, phone number, and credit card information.

You do not need to provide us with any of your Personal Information to simply browse our Site. However, if you want to interact with our Site, open an account with us, register for our newsletter or use any of our other Services, you will need to provide us with Personal Information about you. The Personal Information we collect about you can be broadly categorized as follows: (a) information we collect directly from you, (b) information we collect from third party sources, and (c) information we collect automatically by using data collection technologies.

Information We Collect Directly from You

When you interact with our Site, you may provide us Personal Information about yourself. This Personal Information could include your name, email address, and phone number. We collect this Personal Information to enable us to communicate with you.

Additionally, we collect the content of emails, text messages, and other communications, call logs, and calendar information. If you send us emails, you should be aware that any information you provide us via email may not be secure or encrypted and could be accessible by others. Please exercise caution when you provide us any personal or confidential information using email.

Information We Collect Through Automated Means

As you navigate through and interact with our Site, we (or our third-party partners) may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. In some jurisdictions, this information may be considered Personal Information under applicable data protection laws. We may use cookies and similar tracking technologies (collectively “Tracking Technologies” or “Cookies”) to collect some of this information. Our use of Tracking Technologies is discussed in more detail in the section below entitled “Cookies & Similar Technologies.”

Examples of the type of information we automatically collect using Tracking Technologies include:

  • Device and Online Identifiers: We collect information about your computer and Internet connection including your IP address, operating system, and browser type.
  • Internet and Other Network Activity Information: We collect information about your visits to our site including the date and time you visit pages on our Site, how many times you view a page or item as well as information concerning any emails or other communications that you open, forward or click-through to our Site. If you use multiple devices to access our Site, we may associate your usage from all your devices together.
  • Geolocation: We collect data about the location of your device, which may be imprecise (i.e., inferred from your device’s IP address). Depending on the device you use to access our Services (e.g. Apple™, iOS, Google™, Android, Windows, etc.), you may be able to control whether location data is collected from the settings on your wireless device.

The information we collect automatically is statistical data and does not include Personal Information. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns.

Information We Receive from Other Sources

We do not collect Personal Information from any additional outside source.

How We Use Your Personal Information

We use your Personal Information to:

  • Provide you with the information you request;
  • Improve the Site, including customization and personalization;
  • Provide you with effective customer service;
  • Comply with procedures, laws, and regulations where appropriate for our legitimate interests;
  • Establish, exercise, or defend our legal rights where appropriate for our legitimate interests; and
  • Fulfill other requests with your consent and for any other purposes disclosed at the time you provide Personal Information.
How We Share Your Personal Information

We may disclose aggregated, anonymized information related to you and our other users, as well as information that does not identify any individual, without restriction. “Anonymized information” is explained below under the heading “Aggregate/Anonymized Information.”

We do not sell Personal Information about you in the sense of receiving cash for the information. However, the definition of the term “sale” in some states is broad enough to include transactions that would constitute a “sale” under state law. For example, if you are a resident of Colorado or Connecticut, our use of cookies and tracking technologies constitutes a “sale” of Personal Information to third-party advertisers. In addition, California law may find that a “sale” has occurred if legal consideration other than money is exchanged. See discussion below in the Section entitled “Your Privacy Rights - Disclosures for Additional Jurisdictions.”

Third Party Links and Features

Please be aware that third-party websites accessible or recommended through our Site may have their own privacy and data collection policies and practices. These links and features are provided for your reference and convenience only and do not imply any endorsement by NeoCurrency of information or services provided through these third-party links and features, nor any association with their operators. We are not responsible for any actions, content of websites, terms and conditions, privacy policies, terms of use or other practices of such third parties. We urge you to read the privacy and security policies of any third parties.

In certain circumstances we share certain Personal Information for a business or other lawful purpose. We will share the Personal Information about you that we collect from you in the following ways:

  • Business Transfers: As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), Personal Information may be among the transferred assets. If a portion or all our assets are sold or transferred to a third party, User Personal Information would likely be one of the transferred assets. If such transfer is subject to notifications or restrictions under applicable laws, we will endeavor to comply with such requirements.
  • Comply with Laws and Protect Our Rights and the Rights of Others: We may disclose your Personal Information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order or a subpoena. We may also disclose your Personal Information to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Site; to enforce or apply other agreements; and to protect our own rights or property or the rights, property, or safety of other users of our Site.
  • Analytics and Research: We share Personal Information derived from Site usage with analytics and search engine providers that assist us to improve our Site, including Google Analytics. We also use Personal Information for research and development of our goods and Services. Please refer to our “Cookies & Similar Technologies” section below.
  • Bankruptcy: If any bankruptcy or reorganization proceeding were to be brought by or against us, such information may be considered an asset of ours and may be sold or transferred to third parties. Should such a sale or transfer occur, we would use reasonable efforts to require that the transferee use Personal Information obtained through our Services in a manner that is consistent with this Privacy Policy.
Security

We recognize the importance of implementing a variety of security safeguards designed to protect the confidentiality of your Personal Information. However, no data transmission over the Internet or other network is completely secure. As a result, while we strive to protect Personal Information transmitted to us on or through our Site, you do so at your own risk. We store Personal Information in data servers that are maintained at one or more commercial data centers owned or operated by companies that are regularly engaged in the business of storing Personal Information in secure settings pursuant to industry standards governing data security and privacy, and we utilize industry standard commercial efforts to undertake technical and organizational measures designed to protect your Personal Information, including encryption in transit, access controls, audit logging, secure development practices, and periodic security assessments. We also maintain administrative policies, employee training, and incident-response protocols to safeguard data.

NeoCurrency employs automated systems, including our Reward Block technology, to identify unusual redemption patterns and prevent fraud. Reward Block may restrict or delay reward redemption attempts from specific IP addresses when activity exceeds limits established by our business clients. These measures do not produce legal or significant effects on individuals and are used solely to maintain the security and integrity of our reward systems.

We are not responsible for any loss or damage arising from your failure to maintain reasonable security safeguards with respect to your activity on our Site. If you have reason to believe that your interaction with us is no longer secure, please let us know immediately by contacting us as indicated in the “How to Manage Your Privacy Rights” section below.

Aggregate/Anonymized Information

We may aggregate and/or anonymize any information collected through the Site so that such information can no longer be linked to you or your device (“Aggregate/Anonymized Information”). We may use Aggregate/Anonymized Information for any purpose, including for our research purposes, and may also share such data with our Service Providers at our discretion.

Cookies & Similar Technologies

We and our service providers may use a small text file placed on your device to identify your device and browser (“Cookies”) and similar tracking technologies (“Tracking Technologies”) when you access our Site or if you engage with our email communications. For example, we and our service providers may use Cookies to improve the experience of our Site, such as keeping track of your activities on the Site, recognizing return visitors, and Site traffic. Please note, however, that if you do not accept Cookies, you may not be able to access all portions or features of our Site. The Tracking Technologies we may use include the following technologies:

  • Cookies or Browser Cookies. A Cookie is a small file placed on your computer or other device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Service. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services use Cookies.
  • Web Beacons. Certain pages of our Site and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixels, and single-pixel gifs) that permit us, among other things, to count users who have visited those pages or opened an email and for other related website statistics (such as recording the popularity of a certain section and verifying system and server integrity).

Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on your personal computer or other device when you go offline, while Session Cookies are deleted as soon as you close your web browser. We use both Session and Persistent Cookies for the purposes described below:

  • Strictly Necessary Cookies. Strictly Necessary Cookies are a Session Cookie. These Cookies enable basic functions on the Site, like page navigation and access to secure areas of the Site. The Site cannot function properly without these Cookies. As such, Strictly Necessary Cookies will always be collected regardless of your Cookie settings. Examples of how we use Strictly Necessary Cookies are as follows:
    • Preserving your Site session across page requests;
    • Distributing traffic to the Site across several servers to optimize response times and improve your website experience;
    • Identifying trusted web traffic to keep the Site secure;
    • Storing your Cookie consent choices for the Site.
  • Functional/Preference Cookies. Functional (also referred to as Preference) Cookies are a Persistent Cookie. They enable the Site to remember information that changes the way the Site behaves or looks during your experience, like your preferred language, the font text appears in, or the region that you are located in. Preference Cookies are used to establish a unique user ID that recognizes you on returning visits to improve and personalize your experience on our Site. We use Preference Cookies in various ways including as follows:
    • provide a more personalized experience to users with more relevant content and content recommendations;
    • remember information about a user's browser and settings preferences, such as preferred language, to make your experience more functional and customized;
    • increase your user experience of the Site, such as by remembering the sound volume level selected by the user;
    • test different versions of the Site to see which particular features or content users prefer to optimize the Site;
  • Performance/Statistics Cookies. Performance (also referred to as Statistics) Cookies are a Persistent Cookie. They help us understand how visitors interact with the Site by collecting and reporting information anonymously. Examples of how we use Statistics Cookies follow:
    • Anonymously logging details about your browser and computer through a website like Google Analytics;
    • Collecting anonymous data on your visits to the Site, such as the number of visits, average time spent on the website and what pages have been loaded, in order to generate reports for optimizing the Site’s content;
    • Determining what type of device (smartphones, tablets, computers, TVs etc.) is being used to access the Site;
    • Gathering anonymous, technical information regarding your browser, operating system, IP address and screen resolution as well as your navigation on the website.
Performance Cookies We Use
Google Analytics

We use Google Analytics, a web analytics service provided by Google, Inc. Google Analytics uses cookies to help us analyze how users interact with our Site, compile reports on their activity, and provide other services related to their activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a returning visitor, and any referring website. The information generated by Google Analytics is transmitted to and stored by Google and is subject to Google’s privacy policies. To learn more about Google’s partner services and to learn how to opt out of tracking of analytics by Google, click here.

Google reCAPTCHA

We use Google reCAPTCHA, a free service provided by Google, Inc., to protect our Site from spam and abuse. Google reCAPTCHA uses advanced risk analysis techniques to decipher humans and bots. Google reCAPTCHA works differently depending on what version is deployed. For example, you may be asked to check a box indicating that you are not a robot or Google reCAPTCHA may detect abusive traffic without user interaction. Google reCAPTCHA works by transmitting certain types of information to Google, such as the referrer URL, IP address, visitor behavior, operating system information, browser and length of the visit, cookies, and mouse movements. Your use of Google reCAPTCHA is subject to Google’s Privacy Policy and Terms of Service. More information as to Google reCAPTCHA and how it works is available here.

Google Ad Manager

We use Google Ad Manager to define, create and manage our advertising campaigns, and Google Ad Manager generates associated reports for us. In doing so, we define ad inventories or so-called ad units. Ad units are the areas on our Site in which ads are to be presented. In Ad Manager, a tag (a code snippet) is generated for each ad unit. This snippet is inserted on our Site. When a user visits our Site, a request is sent to Google Ad Manager via the ad tag.

Google Tag Manager

We use the Google Tag Manager tool to integrate various website tags from Google into our website (e.g. website analysis products).

In programming language, tags are parts of code that are used to track the activities of visitors to a website. The word "tag" refers to a label or a marker and is used to mark a database with certain additional information. Depending on the type of activity tracked and the function of the particular tag, a distinction is made between so-called counter tags, conversion tags, remarketing tags and container tags.

To find out more about Google's privacy policy in general, you can access Google’s privacy policy here.

Third Party Links and Features

Third-party websites accessible or recommended through our Site may have their own privacy and data collection policies and practices. These links and features are provided for your reference and convenience only and do not imply any endorsement by NeoCurrency of information or services provided through these third-party links and features, nor any association with their operators. We are not responsible for any actions, content of websites, terms and conditions, privacy policies, terms of use or other practices of such third parties. We urge you to read the privacy and security policies of these third parties.

Any relationship between you and such third parties will be governed exclusively by the terms offered by the third party and agreed to by you. If you provide third parties with any Personal Information or other information, their use of such information will be subject to their privacy policies, if any, and will not be subject to this Privacy Policy.

For avoidance of doubt, if we provide links to social media platforms, such as Facebook or YouTube, and you choose to visit those websites through our links, please note that the information you post, transmit or otherwise make available on those websites may be viewed by the general public. We do not control user-posted content on social media homepages and are not responsible for any third-party use of your information that you have posted, transmitted or otherwise made available there.

How Long We Retain Your Personal Information

We expect to retain your Personal Information for as long as we have a business need for it or as needed to comply with this Privacy Policy. This includes maintaining and improving the performance of our Services, keeping our Services secure, and maintaining appropriate business and financial records. Most of our retention periods are determined on the basis of this general rule. If we process Personal Information on the basis of consent (including consent to extended storage), we store the data for as long as necessary to process it according to your consent or until you withdraw your consent. We also retain and use Personal Information to protect as well as enforce our rights and comply with our legal obligations. Legal requirements (such as record retention requirements or litigation holds) may require us to retain some or all the Personal Information we hold for a longer period of time, even after our business purpose or need expires.

How to Manage Your Privacy Rights

Subject to our legal requirements and legitimate business needs, we strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your Personal Information. You may instruct us not to use any of your Personal Information to contact you regarding any of our products, services, promotions or special events by contacting us using the information in the “Exercising Your Privacy Rights” section below. In the event any commercial email messages are sent, you can opt out by following the instructions located at the bottom of such emails. Removing your name from the email list may take a reasonable amount of time. Please note that, regardless of your request, we may still use and share certain Personal Information as permitted by this Privacy Policy or as required by applicable law.

Tracking Technologies: You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Site may then be inaccessible or not function properly. To manage your Cookie settings, please refer to our Cookie banner on our Site.

Account Deletion: Requests to delete your account may be emailed to privacy@neocurrency.com with “Delete Account” in the subject line.

Some devices and browsers support a “Do Not Track” (or DNT) feature, a privacy preference that you can set in certain web browsers, which is intended to be a signal to websites and services that you do not wish to be tracked across different websites or online services you visit. Please note that we cannot control how third-party websites or online services you visit through our website respond to Do Not Track signals. Check the privacy policies of those third parties for information on their privacy practices.

Your Privacy Rights – Disclosures for Additional Jurisdictions
State Privacy Rights

Depending on the state in which you reside, in particular, if you reside in Connecticut, Delaware, Iowa, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah or Virginia, you have the following privacy rights regarding your Personal Information as of the date of this Privacy Policy:

  • The right to confirm whether or not we are processing your Personal Information and to access such Personal Information, subject to certain exceptions.
  • The right to correct inaccurate Personal Information that we maintain about you, subject to certain exceptions. (Iowa and Utah do not provide this right to its residents).
  • The right to correct inaccurate Personal Information that we maintain about you, subject to certain exceptions. (Iowa and Utah do not provide this right to its residents).
  • The right to obtain a copy of your Personal Information in a portable format that allows you to transmit the information to another entity, subject to certain exceptions.
  • The right to opt out of our processing your Personal Information for purposes of (1) targeted advertising; (2) the “sale” of your Personal Information (as that term is defined by applicable law); and (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

If you are a resident of Delaware, Minnesota or Oregon, you have the additional privacy right to obtain a list of categories of third parties to which we have disclosed your Personal Information.

Additionally for Minnesota residents, you have the right to review Personal Information used for any profiling that resulted in a decision about you, to obtain an explanation of that decision, and if the decision was based on inaccurate information, to have the information corrected and the decision re-evaluated.

If you are a resident of California or Colorado, you are entitled to additional privacy related disclosures, which can be found, with respect to California, in the Section below entitled “Notice to California Residents,” and with respect to Colorado, in the Section below entitled “Notice to Colorado Residents.”

Specifically for Nevada residents, Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@neocurrency.com. However, please know we do not currently sell data triggering that statutes opt-out requirements.

We do not sell your Personal Information in the sense of receiving cash for the information. However, the definition of the term “sale” in some states is broad enough to include transactions that would constitute a “sale” under state law. For instance, if you are a resident of Colorado or Connecticut, our use of Cookies and Tracking Technologies constitutes a sale of Personal Information to third-party advertisers. We do not use Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals. Please refer to our “Cookies & Similar Technologies” section above.

Regardless of jurisdiction, please see Section on “Exercising Your Privacy Rights” to contact us for the purpose of exercising one or more of applicable privacy rights.

Notice To California Residents

This section applies solely to all visitors, users, and others who reside in the State of California (“CA Consumers”) and is presented in compliance with the California state laws, including the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CCPA). Any terms defined in the CCPA have the same meaning when used in this notice. References to “you” and “yours” in this Notice are directed to CA Consumers only.

We do not share Personal Information with third parties for their own direct marketing purposes without your consent.

Notice of Collection of Personal Information

We currently collect and, in the 12 months prior to the Last Updated Date of this Privacy Policy, have collected the following categories of Personal Information:

  • Identifiers (e.g., name, mailing address, email address); and
  • Geolocation data (i.e., IP information).

We collect Personal Information directly from California residents when fulfilling rewards for business clients who have supplied an email address. Please note that there are certain exemptions to the CCPA including a Business to Business (“B2B”) Communications Exemption. To the extent the B2B Communications Exemption applies to the collection of information by us and our communication with you, it will be applied.

We currently collect and have collected the above categories of Personal Information for the following business or commercial purposes:

  • Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance;
  • Helping to ensure security and integrity and prevent fraud;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services;
  • Short-term, transient use, such as non-personalized advertising shown as part of your current interaction with us; providing advertising and marketing services;
  • Undertaking activities to verify or maintain the quality or safety of our services or devices and to improve, upgrade, or enhance them;
  • Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us; and
  • Undertaking internal research for technological development and demonstration.
Sale, Share, and Disclosure of Personal Information

The CCPA defines “sale” as the transfer of Personal Information for monetary or other valuable consideration. Although we do not “sell” Personal Information as that term is commonly understood (for money), we engage in online activities that may constitute a sale or the sharing of Personal Information under California law if it is determined that we have received “other valuable consideration” for the Personal Information.

We have not sold or shared, for cross-context behavioral advertising purposes, Personal Information in the 12 months preceding the Last Updated Date of this Privacy Policy.

We shared Personal Information to third parties for the following business or commercial purposes:

  • Targeted advertising

The following table identifies the categories of Personal Information that we disclosed for a business purpose in the 12 months preceding the Last Updated Date of this Privacy Policy and, for each category, the categories of third-party recipients to whom we disclosed Personal Information:

Category of Personal Information Categories of Third-Party Recipients
Identifiers such as name, online identifier, email address, and account name. Service providers, including for customer support.
Commercial Information (e.g., products or services purchased or considered, purchase histories or tendencies) Service providers, including for customer support.
Financial information such as gift card information Service providers, including for customer support and order fulfillment.

We disclosed Personal Information for the following business or commercial purposes:

  • Performing services on behalf of the business, including providing customer service, processing and fulfilling orders and transactions, or verifying customer information.
  • Providing advertising and marketing services.
  • Helping to ensure security and integrity and prevent fraud.
  • Undertaking activities to verify or maintain the quality or safety of our services or devices

We do not use or disclose sensitive Personal Information for purposes other than those specified in Cal. Code Regs. tit. 11, § 7027(m).

Sale or Share of Personal Information of Consumers under 16 Years of Age

We do not knowingly sell or share (for cross-context behavioral advertising) the Personal Information of consumers under 16 years of age.

Your California Privacy Rights

If you reside in California, then you have the following privacy rights per California privacy laws regarding your Personal Information as of the Last Updated Date of this Privacy Policy. Please remember that your privacy rights may be subject to limitations, qualifications or exceptions specified in the privacy law.

  • The right to know the categories of Personal Information we’ve collected and the categories of sources from which we got the information.
  • The right to know the business purpose for collecting Personal Information.
  • The right to know the categories of third parties with whom we share that Personal Information.
  • The right to access the specific pieces of Personal Information we’ve collected and then gain access to the Personal Information.
  • The right to delete Personal Information that we collected from and/or about you, subject to certain exceptions.
  • The right to correct inaccurate Personal Information that we maintain about you, subject to certain exceptions.
  • The right to opt out of having your Personal Information sold or shared for cross-context behavioral advertising.
  • The right to limit disclosure of sensitive Personal Information but know that we do not use your sensitive Personal Information (if at all) in a manner subject to that right.

California residents also have the right to not be discriminated against if they choose to exercise their privacy rights. We will not discriminate against you for exercising any of your California privacy rights, such as charging you a different price or providing you with a lesser quality of goods or Services if you exercise any of those rights.

We reserve the right to verify your identity before responding to any request made under the CCPA. This verification process may include, at a minimum, depending on the sensitivity of the information you are requesting; the type of request you are making; and the information we have collected, verifying your name, email address, phone number, or other information. You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a properly executed power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

Please note that certain information may be exempt from such requests under California law. For example, we require certain information in order to comply with legal obligations, so we may need to either reject your request to delete the information or, if we are legally permitted to delete it, we would need to terminate our communications with you after deleting it. If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us at privacy@neocurrency.com.

California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of Personal Information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your Personal Information with third parties for their own direct marketing purposes within the meaning of that law.

Notice To Colorado Residents

This portion of our Privacy Policy applies only to residents of the state of Colorado and applies only to the extent of any inconsistency with the information above. All terms not otherwise defined in this portion shall have the meanings defined under the Colorado Privacy Act (“CPA”).

Collection, Use and Sharing of Personal Information

We may collect, use and process certain categories of Personal Information as described in the chart below.

Category of Personal Information Processing Purpose Used for Targeted Advertising? Sold or Shared
Identifiers such as name, online identifier, email address, and account name. Product and service fulfillment; communications and marketing; improve products, services, and operations; prevention of fraud and other harm; legal compliance No Advertising Networks; Service providers, including for customer support and marketing.
Commercial Information (e.g., products or services purchased or considered, purchase histories or tendencies) Product and service fulfillment; communications and marketing; improve products, services, and operations; prevention of fraud and other harm; legal compliance No Advertising Networks; Service providers, including for customer support and marketing.
Financial Information such as gift card information Product and service fulfillment; improve products, services, and operations; prevention of fraud and other harm; legal compliance No Service providers, including for customer support and order fulfillment.
Internet or other electronic network activity such as information regarding your interaction with the Site Communications and marketing; improve products, services, and operations; prevention of fraud and other harm; legal compliance No Advertising Networks; Service providers, including for customer support and marketing.
Geolocation data such as IP address Product or service fulfillment; communications and marketing No Advertising Networks; Service providers, including for analytics and customer support.

We do not sell Personal Information we collect or receive from other sources.

CPA Rights

If you are a Colorado resident, you have the following rights regarding your Personal Information:

  • Right to Know and Access: The right to confirm whether or not we are processing your Personal Information and to access such Personal Information.
  • Right to Correct: The right to correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and our purposes of the processing of such Personal Information.
  • Right to Delete: The right to delete Personal Information provided by or obtained about you.
  • Right to Obtain a Copy: The right to obtain a copy of your Personal Information that you previously provided to us in a portable and to the extent technically feasible, readily useable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means.
  • Right to Opt-Out: The right to opt out of the processing of your Personal Information for purposes of: (1) targeted advertising, (2) the sale of Personal Information, or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
International Data Transfer
Notice Regarding EU, EEA, and UK Personal Information

If you are located outside of the United States of America, we inform you that NeoCurrency is incorporated in the United States, and therefore, all Personal Information collected by NeoCurrency is transferred to and processed in the United States for the purposes described in this Privacy Policy. The United States may have privacy and data protection laws that differ from, and are potentially less protective than, the laws of your country. Your Personal Information can be subject to access requests from governments, courts, or law enforcement in the United States according to the laws of the United States. By using the Services, you acknowledge that NeoCurrency may not be subject to the particular privacy law in your country of residence. While NeoCurrency may recognize the application of these privacy laws in certain limited circumstances, by using the Services you acknowledge that your Personal Information will be processed in the United States, and you acknowledge that you may not be able to avail yourself of all privacy rights under the privacy laws in your country of residence. We provide secure technology and operational services and may process your Personal Information — such as your name, email address, and IP address — solely for the purposes we define (e.g., identity verification or reward transaction processing).

GDPR Data Privacy Rights

If you are a resident of a country outside the United States, such as, but not limited to Canada, a country within the EU, EEA, or the UK, the law in your country of residence may grant you certain rights with respect to your Personal Information, in particular the right to access, correct, and delete the Personal Information we hold about you. We will retain your Personal Information for the length of time you engage with our Services, as described in the retention section of this Privacy Policy under the heading “How Long We Retain Your Personal Information” or until you request deletion of such Personal Information. We are considered the Data Controller (or equivalent distinction) with regard to your Personal Information. You can find our contact information here.

In certain circumstances, you have the following data protection rights:

  • The right to be informed. You have the right to know about the Personal Information we received about you and what we do with it.
  • The right of access. You have the right to request access to the Personal Information we have on you.
  • The right of rectification. You have the right to have your Personal Information rectified if that information is inaccurate or incomplete.
  • The right to object. You have the right to object to our processing of your Personal Information.
  • The right to erasure. You have the right to ask that we delete or erase your Personal Information where there is not good reason for us to continue to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), or where we processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Please note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • The right of restriction. You have the right to request that we restrict the processing of your Personal Information.
  • The right to data portability. You have the right to be provided with a copy of the Personal Information we have on you in a structured, machine-readable and commonly used format.
  • The right to withdraw consent. You have the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.
  • Rights in relation to automated decision making and profiling. If we make significant decisions based solely on the automated processing of your Personal Information, you have the right to object to this automated processing.

In order make a request regarding your Personal Information, please contact us as described in this Privacy Policy. Please remember that your privacy rights may be subject to limitations, qualifications or exceptions specified in the privacy law applicable to you.

If you have a comment, question, or complaint about how we are handling your Personal Information, we hope that you contact us to allow us to resolve the matter. You may contact us, our Data Protection Officer, and/or our GDPR Representative by emailing privacy@neocurrency.com. In addition, if you are located in the EU, EEA, or the UK, you may submit a complaint regarding the processing of your Personal Information to the appropriate regulatory authority. A list of the contact details for the European privacy supervisory authorities are available here. Details for the UK privacy supervisory authority is available here.

NeoCurrency acts as a data processor under the General Data Protection Regulation (GDPR) for both the EU, EEA, and the UK. Our legal basis for collecting and using the Personal Information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect it.

Our guidelines are as follows:

  • Processing Personal Information only on documented instructions
  • Implementing appropriate technical and organizational security measures
  • Ensuring our personnel are subject to confidentiality obligations
  • Assisting in responding to data subject rights requests
  • Do not engage in unauthorized or independent use of your data
  • Cooperating fully in the event of data breaches or audits

Where certain sensitive Personal Information is processed based on your explicit consent, you may have the right to withdraw such consent at any time. To do so, please contact us as described in this Privacy Policy. If there is a different legal basis that would permit us to continue processing your Personal Information after withdrawing consent, we will notify you of that legal basis at the time of your request.

Any transfers of Personal Information outside the European Economic Area (EEA) are subject to lawful safeguards, such as Standard Contractual Clauses approved by the European Commission.

Notice to Canadian Privacy

If you are a Canadian resident, you may have certain rights under applicable Canadian laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and successor legislation. Please see the website of the Office of the Privacy Commissioner of Canada for further information.

We make reasonable efforts to notify you of the purposes for which Personal Information will be used or disclosed and if the initial purpose changes. Subject to legal or contractual restrictions and reasonable notice, you may withdraw consent at any time. Subject to certain limits and exceptions set out in the applicable laws, Canadian residents have the following rights:

  • Right of Access. You have the right to request a copy of the Personal Information that we have or hold about you.
  • Right to Data Portability. If you are located in Quebec, you may have the right to be provided with a copy of the Personal Information we have on you (if any) in a structured, machine-readable and commonly used format for the transfer of your Personal Information to you or to a third party.
  • Right to Know. You have the right to be informed of what Personal Information we have collected about you, the sources from which your Personal Information was collected, the purposes for which your Personal Information has been used, and the third parties (or categories of third parties) to whom we have disclosed your Personal Information.
  • Right to Correct or Rectify. You have the right to request corrections to inaccurate or incomplete Personal Information.
  • Right to Withdraw Consent. You have the right to withdraw your consent to our collection, use or disclosure of your Personal Information.
  • Right of Deletion. In certain circumstances, you have the right to request that your Personal Information be deleted.
  • Rights to Complain and Challenge Compliance. You have the right to complain about or to challenge our compliance with Canadian Privacy Laws. We will investigate any challenge and take appropriate action.

Canadian residents also may learn more about targeted advertisements from participating third parties in Canada at the Canadian DAA choice page at https://youradchoices.ca/.

You and we confirm that it is our wish that this Privacy Policy and all other related policies and notices be drawn up in English. Vous reconnaissez avoir exigé la rédaction en anglais du présent document ainsi que tous les documents qui s'y rattachent.

Exercising Your Privacy Rights

You may exercise your one or more of your privacy rights as follows:

  • To submit a consumer request regarding your privacy rights, please email privacy@neocurrency.com and use the subject line “Consumer Privacy Act Request”.
  • You may also exercise your privacy rights by going to the footer of NeoCurrency’s website and selecting the interactive link “Exercise Your Privacy Right Here.”

In order to verify requests and the information in them, you must provide, at a minimum, your name and an email address and respond to a confirmation email that will be sent to that address. We may ask that you provide a photo of an official government issued ID.

Only you, or a designated authorized agent (someone legally authorized to act on your behalf and with written permission), may make a verifiable consumer request related to your Personal Information. If you are an authorized agent making a request on the consumer’s behalf, follow the Exercising Your Privacy Rights instructions to submit a consumer request.

HOW TO APPEAL OUR DECISIONS REGARDING YOUR CONSUMER REQUEST

If you are a resident of California, Colorado, Connecticut, Delaware, Iowa, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, or Virginia, you may appeal our denial of your request pursuant to your State Privacy Rights. In order to appeal our denial of your consumer request, please contact us at privacy@neocurrency.com. We will respond to an appeal within 60 days of receipt for residents of Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, Tennessee, Texas, and Viriginia, and within 45 days of receipt for residents of Colorado, Minnesota, New Jersey, and Oregon.

If you have concerns about your appeal, you have the right to contact the following authority in your state: