Last Updated: January 20, 2020

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.

Among the types of Personal Data that myneoma.com and the Gaia mobile application collect, by itself or through third parties, there are various types of data. More specifically the following data is collected through the Portal:

• Location, dwell time and path of end users when they enter the range of our gateways
• Personal Data given from users to us through API or connection to their database

When end users use our Services, we may ask that they provide us with some personally identifiable information - information about end users that can be used to contact or identify them, and information on the users’ use or potential use of the Services. Personal Data that we might collect may include, but is not limited to, end users’ name, mobile phone number, email address, nationality and country. Personal Data may also include other information users supply to us concerning user’s preferences and interests expressed in the course of using our Services.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the end user, or, in case of usage data, collected automatically when using the Portal myneoma.com.

Unless specified otherwise, all data requested by myneoma.com is mandatory and failure to provide this data may make it impossible for the Portal to provide its Services. In case where the Portal specifically states that some data is not mandatory, users are free not to communicate this data without consequences to the availability or the functioning of the Services. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Neoma Ltd at support@gaiahospitality.com.

Any use of cookies or of other tracking tools by the Portal or by the owners of third party services used by Portal myneoma.com serves the purpose of providing the Services required by the user, in addition to any other purposes described in the present document and in the Cookie Policy available.
Users are responsible for any third-party Personal Data obtained, published or shared through the Portal and confirm that they have the third party’s consent to provide the Data to the Portal.

Neoma Ltd takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to Neoma Ltd, in some cases, the data may be accessible to certain types of persons in charge, involved with the operation of the Portal (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as data processors by the owner. The updated list of these parties may be requested from Neoma at any time at support@gaiahospitality.com.

Neoma may process Personal Data relating to end users if one of the following applies:

• End users have given their consent for one or more specific purposes. Note: Under some legislations, Neoma may be allowed to process Personal Data until the end user objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to GDPR;
• provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which Neoma is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Company;
• processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.

In any case, the Company will help clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

The data is processed at the operating offices of Neoma Ltd located at ICT, 1/F, 5W, Enterprise Place, HKSTP, Hong Kong.

Depending on the user’s location, data transfers may involve transferring the user’s data to a country other than their own. To find out more about the place of processing of such transferred data, users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Company to safeguard their data. If any such transfer takes place, users can find out more by checking the relevant sections of this document or inquire with the Company using the information provided in the contact section.

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Company and the user shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Company’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Company within the relevant sections of this document or by contacting the Company at support@gaiahospitality.com.

The Company may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Company may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The data concerning the user is collected to allow the Company to provide its Services, as well as for the following purposes: data transfer outside the EU, location-based interactions and hosting and backend infrastructure.