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Aviva has partnered with Neos Ventures Limited (“Neos”) to make Neos products and services available to Aviva’s customers. This Privacy Notice describes the types of personal information Neos obtains about consumers and other individuals identified below, how Neos may use the personal information, with whom Neos may share it (including Aviva), and the choices available to you regarding Neos’ use of your personal information.

This Privacy Notice also describes the measures Neos takes to safeguard the personal information and how individuals can contact Neos about its privacy practices. In accordance with the General Data Protection Regulation and related UK data protection legislation, Neos is committed to respecting and protecting the confidentiality and security of your information.

References to “Aviva” are to Aviva UK Digital Limited. Where the term “Aviva Group Company” is used, it refers to one or more of the trading companies of Aviva that operate in the United Kingdom. Neos is majority owned by an Aviva Group Company. For information concerning Aviva and for a full list of the Aviva Group Companies, see https://www.aviva.co.uk.

1. Information Neos collects

1.1 Information Neos obtain about you

Neos obtains certain personal information in connection with the products and services it provides.
The types of personal information Neos obtain include:
  • Contact information, such as name, phone number, and email and postal address;
  • Account information, such as online password and other log-in details used to access Neos products and services;
  • Payment information, such as name, billing address and payment card details, including card number, expiration date and security code, which is collected and stored by our third- party payment processor on our behalf. Neos stores only the last four digits of your payment card and the expiration date;
  • The geolocation of your mobile device if you consent to the collection of this data;
  • Product setup information, such as the name and description of your Neos product (for example, “Neos SmartCam”) and the location where you install your Neos product
  • Technical information about your Neos product, such as your Wi-Fi network information and signal strength, and your Neos product’s model, serial number and software version;
  • Social media handles, content and other data posted on our official social media pages;
  • Information Neos obtains from third-party social media services (e.g., Facebook) or payment services (e.g., Paypal) if you choose to link to, create or log into your Neos account through these services (including when you share Neos videos or content via your social media account);
  • Other personal information contained in content you submit to us, such as through our “Contact Us” feature or customer support tools on our websites or mobile apps.

In addition, Neos products and services are designed to allow you to see, hear and speak to anyone in within proximity of a given product (example is the “Neos SmartCam”) from your mobile or smart device. To provide you with these services, Neos obtains content (and related information) that is captured and recorded when using Neos products and services, such as video or audio recordings, live video or audio streams, images, comments, and data Neos products collect from their surrounding environment to perform their functions (such as motion, events, temperature and ambient light).

Privacy and video surveillance laws in your jurisdiction may apply to your use of Neos products and services. You are solely responsible for ensuring that you comply with applicable law when you use Neos products or services. For example, you may need to display a notice that alerts visitors to your home that you are using Neos products or services. Capturing, recording or sharing video or audio content that involves other people may affect their privacy rights.

1.2 Information Neos obtains by automated means

When you interact with Neos products and services, Neos obtains certain information by automated means, such as cookies, web server logs, web beacons, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

Neos may use these automated technologies to collect information about your equipment, browsing actions, and usage patterns. The information Neos obtains in this manner may include your device IP address, identifiers associated with your devices, types of devices connected to Neos’ services, web browser characteristics, device characteristics, language preferences, referring/exit pages, clickstream data, and dates and times of website or app visits. These technologies help Neos (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with Neos’ products and services; (3) tailor the services around your preferences; (4) measure the usability of Neos’ products and services and the effectiveness of Neos’ communications; and (5) otherwise manage and enhance Neos’ products and services, and help ensure they are working properly.

Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of Neos’ online services. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device.

1.3 How Neos uses the information it collects

Neos may use the personal information it obtains about you to:
  • Provide our products and services to you;
  • Establish and manage your Neos account and profile;
  • Process and fulfil orders in connection with Neos products and services and keep you informed about the status of your order;
  • Allow you to stream, save and share content through our services;
  • Identify and authenticate you so you may access certain content or use certain Neos services;
  • Increase and maintain the safety and security of Neos products and services and prevent misuse;
  • Communicate with you (including providing you with offers and other communications about Neos products and services) and provide customer support;
  • Allow you to interact with certain third-party products or services;
  • Perform analytics (including market and consumer research, trend analysis, financial analysis, and anonymisation of personal information);
  • Operate, evaluate, develop, manage and improve our business (including operating, administering, analysing and improving our products and services; developing new products and services; managing and evaluating the effectiveness of our communications; performing accounting, auditing, billing reconciliation and collection activities and other internal functions);
  • Personalise your experience with our products and services;
  • Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
  • Neos also may use the personal information it collects about you in other ways for which it provides specific notice at the time of collection and obtains your consent if required by applicable law.

Neos also may use the personal information it collects about you in other ways for which it provides specific notice at the time of collection and obtains your consent if required by applicable law.

1.4 Third-party analytics services

Neos uses third-party web analytics services on its websites and mobile apps. The service providers that administer these services use automated technologies to collect data (such as email and IP addresses) to evaluate use of Neos’ websites and mobile apps.

2. Information sharing

Neos does not sell or otherwise share personal information about you except as described in this Privacy Notice. Neos may share your personal information with (1) its affiliates and subsidiaries and (2) its service providers who perform services on its behalf, such as marketing, customer service, payment processing, order fulfilment and data analytics and storage. Neos does not authorise its service providers to use or disclose your personal information except as necessary to perform services on its behalf or comply with legal requirements.

Neos will share personal information with Aviva about Aviva customers who have purchased Neos SmartCams and downloaded the Aviva Connected app, including the customer’s name and email address, the number of Neos SmartCams purchased by the customer and the number of Neos SmartCams activated on the Aviva Connected app by the customer. Aviva is an independent data controller and will process this personal data for its legitimate interests in understanding how customers with smartcams engage with their home insurance policies, including by including contacting customers who purchase Neos SmartCams. Aviva may share this information with other Aviva Group Companies for the same purpose and will retain the personal data for up to 24 months. For more information about how Aviva processes customers’ personal data and how you can exercise your rights, see Aviva’s privacy policy at https://www.aviva.co.uk/services/about-our-business/products-and-services/privacy-policy/.

Neos also may disclose personal information about you (1) for fraud prevention purposes, (2) if it is required to do so by law or legal process (such as a court order or subpoena); (3) in response to requests by government agencies, such as law enforcement authorities; (4) to establish, exercise or defend its legal rights; (5) when it believes disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (6) in connection with an investigation of suspected or actual illegal activity; or (7) otherwise with your consent. Neos may provide third parties with anonymised and aggregated statistical information it holds (so that it does not directly identify you) about users of Neos products and services. Neos reserves the right to transfer any personal information it has about you in the event it sells or transfers all or a portion of its business or assets (including in the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution or liquidation).

3. Your choices

In accordance with the marketing preferences you set when creating your account or that you set with Neos at a later date, Neos may contact you by email, push notification, text, mail or phone, to keep you updated on products and services. You can let Neos know at any time that you do not wish to receive marketing messages by sending an email to Neos at avivaconnected@neos.co.uk or contacting the customer service team via webchat.

You also may opt out of receiving promotional communications from Neos by following the unsubscribe instructions in the communications you receive. Neos does need to send you certain communications about Neos products and services, and you will not be able to opt out of those communications. This includes, for example, information about billing.

4. How Neos protect personal information

Neos maintains administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorised destruction, loss, alteration, access, disclosure or use.

5. How Neos process and store your personal data

The personal data that Neos collects from you will be processed and securely stored within the European Economic Area (“EEA”). Some data, for specific services, may be transferred to, processed or stored at a destination outside the EEA. Neos will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.

6. Access to your personal data

You have the following rights in relation to your personal information:
  • the right to be informed about how your personal information is being used;
  • the right to access the personal information Neos holds about you;
  • the right to opt-out of receiving direct marketing messages; and
  • the right to request the correction of inaccurate personal information Neos holds about you.

To exercise any of the above rights, or if you have any questions relating to your rights, please contact Neos by using the details set out in the ‘Contacting us’ section below.

If you are unhappy with the way Neos is using your personal information you can also complain to the UK Information Commissioner’s Office or your local data protection regulator. Neos are here to help and encourage you to contact Neos to resolve your complaint first.

7. Changes to Neos' privacy policy

This privacy notice may be updated from time to time. When this notice is changed in a material way, the version date at the bottom of this page will be updated.

For significant changes to this notice Neos will try to give you reasonable notice unless it is prevented from doing so. Where required by law Neos will seek your consent to changes in the way it uses your personal information.

8. How to contact Neos

For any questions relating to this Privacy Policy or Neos’ data protection practices, or to make a subject access request or any other request regarding the information Neos holds, please contact Neos at:

Neos Ventures Ltd | 47 Bermondsey Street | London | SE1 3XT
Tel: 0203 210 3000 | Email: avivaconnected@neos.co.uk | Website: shop.neos.co.uk





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