Last Updated: October 15, 2023
Neoma Ltd (“Neoma” or “Company”) through the portal myneoma.com and its Gaia mobile application collects some Personal Data from its Users.
This privacy policy is in line with the Data Protection Regulation 679/2016/EU (“GDPR”) and governs your use of the Neoma Ltd Portal (the “Portal”) and sets out the basis on which any personal data we collect from you, or that you provide to us, will be processes and used by us.
Protection of your personal data is very important to us. Please devote some time to read our Privacy Policy and understand the way Neoma, either as a Data Collector or as a Data Processor, collects, stores, uses and in general processes personal information that is collected through our website, our sales activities in general, when entering into and executing agreements with/for us and/or during the use of our products, solutions and services.
Neoma Ltd
Unit 510, 5W Enterprise Place,
Hong Kong Science Park,
Sha Tin, Hong Kong
Phone: +852 3970 5670
Email: contactus@neoma.ai / dpo@neoma.ai
Neoma is a technology company specialised in creating world-class experiences in premium and luxury spaces. We measure how people use spaces and empower staff to manage their customers effectively and recognise them automatically.
Due to its international activities, Neoma has to comply with several international laws and regulations, GDPR of European Union among others.
The term “personal data” refers to information about physical persons, such as name, postal address, email address, biometric information, phone number etc that are/can be used to identify a single person.
Any act or series of acts, performed with or without the use of automated means, on personal data or sets of personal data, such as collection, registration, organisation, structuring, storage, adaptation or alteration, retrieval, information retrieval, use, disclosure by transmission, dissemination or any other form of disposal, association or combination, restriction, deletion or destruction.
GDPR acknowledges two company roles in personal data processing: Data Collector, which initiates processing and assumes responsibility, and Data Processor, which processes personal data only under a specifically defined order of a Data Collector.
Neoma, as a technology company in the area of customer management and recognition, assumes both roles, in accordance with the source and the reason of personal data processing. In any case, Neoma processes only the absolutely necessary information per case, as follows:
We maintain your personal/face data for as long needed for the fulfilment of the purpose associated with its collection, unless if an extension is needed due to legal or any other company obligations. e.g. For guest stay in a hotel, data is deleted after checkout or for any event, data is deleted after event is over.
Any kind of access/process to your personal data is allowed only to persons authorized by us, either our employees or our subcontractors and only regarding the above-mentioned purposes. It is not shared to any un-mentioned third party.
We have taken the necessary and appropriate organisational and technical measures for the security and protection of your data from any form of accidental or unlawful processing both at the physical level and at the level of logical security (indicative procedures of physical security, graded data access, protection of computer systems, software). We are using AES-256 encryption framework (bank grade) and we have an information security policy in place, as per company's ISO 27001 certification
These measures are reviewed and amended when deemed necessary.
You have the following rights:
You can exercise your rights by sending an email to dpo@neoma.ai or via the company contact information, as presented in our website.
We answer to your requests without delays and, in any case, within 30 days from the submission of your request. If your request is too complicated, we will inform you within 30 days that we may need an extension of up to 60 more days the most.
We update this policy whenever necessary. If there are significant changes to the policy or the way we use your personal data, we will post an update to this policy on our website before the changes take effect and we will notify you as soon as possible. We encourage you to periodically read this policy to know how your data is protected.