Our privacy policy describes what personal data neon Switzerland AG collects about you and otherwise processes when you use the neon app. Personal data is any information relating to an identified or identifiable natural person. This personal data is protected by data protection law and, in certain circumstances, through bank customer confidentiality.
Your personal data is only transmitted to third parties if this is nec- essary for the purpose of contract processing, if you have given your prior consent or if legal provisions permit or require this.
We inform you that the transfer of data via the internet (e.g. through communication by email) can involve security vulnerabilities. Abso- lute protection of the data against access by third parties is not pos- sible.
This policy may be updated at any time, and we will always notify you of any changes. The current version of the privacy policy is available here as a PDF file.
When you use the neon app, your personal data is collected, pro- cessed and used by:
neon Switzerland AG, Badenerstrasse 557, 8048 Zurich, Switzerland («neon»), email: help@neon-free.ch. More information about neon is provided in the legal notice of our price list.
This data privacy policy applies only to the use of the neon app and any personal information that may be collected and stored, for ex- ample as part of notified recording of telephone conversations with our employees, in order to comply with our legal obligations or for neon’s business purposes.
This data privacy policy explicitly does not apply to:
Visiting and the use of the neon website. Further information on data protection relating to the use of the neon website can be found in the applicable data privacy policy on our website;
other websites to which you will be directed via a link.
If you only use our services for informational purposes, or do so with- out a bank account, we do not collect any personal data, with the exception of data that your browser or end device transmits to facil- itate your visit to our website.
We collect, process and use your personal data in a lawful way and in good faith. Depending on the respective purpose of the data pro- cessing, neon processes your personal data on the following legal ba- ses:
neon processes personal data with primary priority as part of initiat- ing or executing contracts with you, in particular to manage, run, maintain and improve the neon app and services offered on it.
neon is required to comply with applicable laws and may be required by law or an official order to provide information, report your per- sonal data or hand over your personal data.
Where required, neon processes your personal data for purposes not related to the actual performance of the contract, in order to safe- guard its own legitimate interests or those of third parties, e.g. to monitor and control money laundering and other operational risks, for planning, product development and statistical purposes, for mar- keting and market research purposes, to provide adequate infor- mation about neon’s range of services and to safeguard and secure neon’s claims if any receivables are owed to neon or to you, and to ensure your safety and that of neon’s employees.
For further processing purposes not related to the actual perfor- mance of the contract (e.g. sending newsletters), the processing of your personal data can be based on your consent, which you can withdraw at any time.
neon endeavours to only store as much data concerning you as we require to be able to offer you the complete range of features at the highest possible security level. neon collects and processes personal data so that we are able to offer you use options in accordance with the contract. Your personal data will only be shared with third parties if we are legally obliged to do so, if you have given your prior consent to this, or if these third parties are able to assert a legitimate interest. We need your explicit consent for additional offers that require your personal data to be further processed. This applies in particular to the use of mobile payment solution providers.
After registering via neon or Hypothekarbank Lenzburg AG, you can then log in to the app using the contract number or your email ad- dress and a login code.
The neon app allows you to log in using fingerprint and facial recog- nition if the device you are using supports this function. In this case, neither neon nor the neon app will receive your biometric data. If you require further information on how identification by fingerprint or fa- cial recognition works, please contact the relevant provider of this function.
First and last name
Date of birth
Place of birth / place of origin
Gender
Marital status
Email address
Nationality
Home address
Mobile phone number
Sound and image recordings (e.g. telephone calls or picture or video recordings)
Commercial ownership & use
Tax domicile and US tax liability
Copy of ID document
Type of ID document
Date issued
ID number.
The neon app provides an overview of all transactions that are per- formed using your neon app and the neon bank account with Hy- pothekarbank Lenzburg AG. In all cases, neon stores the transaction data of all transactions in encrypted form.
Properly uninstalling the neon app will result in all data generated by the neon app locally on your device being deleted. Should you re- quest it, we subsequently erase all personal data (name, address, transactions, etc.) from productive systems, if permitted by law.
With respect to data stored by unstructured means, such as tickets for questions relating to technical issues or data that has been backed up, neon cannot guarantee complete erasure.
«Notifications» feature to receive current information about your ac- count, such as transactions (credits and debits), budget alerts and account balance updates. To use this feature, neon requires the login code of your neon bank account, which is stored in a secure data centre. This function uses the Apple Push Notification Service pro- vided by Apple Inc. («Apple»), the Google Cloud Messaging Service from Google Inc. («Google») or the HUAWEI Push Service from Huawei Device Co., Ltd. («Huawei»). If you use SwatchPay or GarminPay, the relevant terms and conditions of these providers shall apply. If you require further information on how these functions operate, please contact the relevant provider of the function. Neon will send you a relevant notification compatible with the operating system of your device. Notification will in all cases be transmitted in encrypted form.
Hypothekarbank Lenzburg AG is legally bound to verify your identity via a valid identification document when you open an account and to store certain details of the identification document. For this pur- pose, we offer you digital identification options that are carried out in accordance with the criteria of FINMA Circular 2016/7 «Video and Online Identification» («FINMA RS») of the Swiss Financial Market Su- pervisory Authority FINMA («FINMA»). Although the user generally
has a choice between online and video identification, in certain cases neon may prescribe the method.
Video identification is performed on behalf of neon and Hypothekar- bank Lenzburg AG by Intrum AG, Eschenstrasse 12, 8603 Schwerzen- bach (hereinafter «Intrum»). Identity is verified by means of a web- based video identification procedure using an encrypted transmis- sion channel.
On completion of the video identification procedure, Intrum will send you a text message containing a «transaction number» or «TAN». As instructed by Intrum, you confirm the correctness of the data that you have entered in the app via the entry field provided, as well as your identity, and you accept the respective GTCs and contractual conditions of Hypothekarbank Lenzburg AG, neon and Intrum.
Online identification is carried out by Hypothekarbank Lenzburg AG. which also relies on services provided by Intrum. Your identity is con- firmed, in part, using an electronic copy of your identification docu- ment transmitted in encrypted form.
Hypothekarbank Lenzburg AG will send you a TAN by text message for online identification. By entering the TAN in the entry field pro- vided by the app, you confirm the correctness of the data that you have entered in the app, as well as your identity, and you accept the respective GTCs and contractual conditions of Hypothekarbank Lenzburg AG, neon and Intrum.
For both procedures (video identification and online identification) neon transfers your personal data (first and last name, date and place of birth, nationality, email address, gender, mobile number, place of residence, preferred language) to Intrum. To verify that the video identification procedure has been carried out correctly, Intrum requires access to the camera on your terminal device and must be able to take photos of you and the front and back of your ID card or the front of your passport and, if applicable, your residence permit. These photos are transmitted to Hypothekarbank Lenzburg AG.
The conversation between you and Intrum is recorded and saved for statutory verification purposes. At the outset of the video identifica- tion, Intrum will request your express consent to create photos and record the conversation. Intrum AG transfers the data to Hypothe- karbank Lenzburg AG and it is then deleted from Intrum’s servers af- ter 90 days at the latest.
To continue with the online identification process, the app must be able to access the back camera on your device so photos of you as well as the front and back of your Swiss identification card or your alien's identity card can be taken. These photos, as well as any dis- crepancies that we discern between your personal data and details taken from your identification card or passport, will be transferred from Intrum to neon and Hypothekarbank Lenzburg AG. This data will be deleted from Intrum’s servers after 90 days at the latest.
For online identification, Intrum is tasked with verifying the authen- ticity of the identification card or passport that you present. For this purpose, Intrum uses a prescribed electronic process to check the integrity and the respective optical security features of the identifi- cation document. If the security features are not clearly visible or if any anomalies should become apparent, the photos taken during this process may be subject to manual checking by Intrum.
Customer support. For customer support, neon uses the systems from the company Freshworks Inc., San Mateo, California. So that neon can always give you the best possible help, the following infor- mation is stored exclusively for the purpose of support services: name, first name, email, contract number, product type, language, telephone number. The data thus stored will be stored in a data pro- cessing centre in the European Union in accordance with the
applicable contractual data protection provisions. More information is available here. neon keeps a record of all communications be- tween you and our customer support team, whether we communi- cate by email or chat or telephone, to help improve our ability to as- sist you with future enquiries.
The 24-hour customer support phone line in connection with use of the card is operated directly via Hypothekarbank Lenzburg AG.
Based on the data indicated above, neon can offer you additional functions. This currently includes automatically categorising your transactions and statistics for your account movements over set pe- riods of time and for set recipients, as well as giving you the option of sending money to other neon customers via the address book fea- ture and mobile payment services.
Non-personal (anonymous) data, such as statistics concerning the device you are using or transaction data, cannot be used to identify you personally. We use such data to continuously optimise the per- formance and offerings of the neon app.
Communication between neon and Hypothekarbank Lenzburg AG is fully encrypted using the standardised TLS/SSL protocol.
API») of Hypothekarbank Lenzburg AG and neon respectively. All bank transaction data is stored at Hypothekarbank Lenzburg AG’s data centre or Swiss data centres. These are ISO27001 certified. We are governed by the Swiss Data Protection Act and take appropriate technical and organisational security measures to protect your per- sonal data from unauthorised access and misuse.
As with banks, we rely on the services of carefully selected third par- ties, such as our data centre. Your personal data is always protected.
Third-party providers. In order to use technical or organisational ser- vices provided by third parties that we require in order to meet the purposes set out in this Privacy Policy or for our other business activ- ities, your personal data may be stored in the systems of these ser- vice providers, such as your transaction data, which is stored in en- crypted form in an ISO27001 certified data centre in Switzerland, but also personal data stored within the customer support systems of Freshworks Inc., San Mateo, California in accordance with the appli- cable data protection regulations in a data centre in the European Union. Our service providers are bound by the respective data pri- vacy laws and are also contractually obliged to process personal data exclusively on our behalf and in accordance with our instruc- tions. We oblige our service providers to comply with technical and organisational measures to ensure that personal data is protected.
To enable statistical analysis of your usage behaviour, neon uses carefully selected analysis services and tracking technologies from Google. The data collected in this way is anonymised. The only data collected is how the neon app is used, e.g. page views and loading times, but never personal or customer-identifying data or content. The data transmitted to Google is not merged with other Google data. The data collected in this way is exclusively used for trouble- shooting and optimising the customer experience.
The collected information about usage of the neon app is transferred to Google servers, generally in Europe, and stored there for a maxi- mum of 14 months (to allow comparison of app performance throughout this period). The data is not used for any other purpose or transferred to third parties.
You can find further information in the data privacy policy and func- tionalities of Google.
Whenever we send you an email, you have the option to unsubscribe from additional product information or emails – the exception is emails required for maintaining or terminating the customer rela- tionship, e.g. updates to our general terms and conditions («GTC»).
For the purpose of sending emails, neon saves your email address, first name and chosen language and, where necessary, saves cus- tomer segment attributes with our service provider who sends the emails. This service provider is contractually bound to provide an ad- equate level of data protection.
Notification and transmission of personal data to third-parties care- fully selected by us inside and outside of Switzerland takes place if this is necessary to provide services (e.g. for payment orders), if this is required by law (e.g. as part of the automatic exchange of infor- mation) or if you have consented to this. neon ensures (e.g. through the use of corresponding standard contractual clauses of the
European Commission) that the recipients of personal data guaran- tee an adequate level of data protection at all times and wherever located.
As part of providing customer support, all personal data as de- scribed in section 4 is stored in a data centre in the European Union via the systems of the company Freshworks Inc., San Mateo, Califor- nia in accordance with the General Data Protection Regulation (GDPR).
We process and store your personal data for the entire duration of the business relationship (from initiation, account opening to termi- nation of a contract) and beyond in accordance with the statutory retention and documentation obligations. It is possible that personal data will be retained for the period during which claims can be as- serted against our company and insofar as we are otherwise legally obliged to do so or if legitimate business interests require this (e.g. for evidence and documentation purposes). As soon as your personal data is no longer required for the purposes stated above, it will be deleted or anonymised to the extent possible.
For operational data (e.g. system protocols, logs), shorter retention periods of twelve months or less generally apply.
contact customer support so that we are able to correct it without delay. You have the option of changing any data yourself in the neon app. You also have a right to block, erase or destroy this data. We reserve the right to apply any restrictions provided for by law.
If you have given your consent to the use of data, you can revoke this consent at any time with future effect. Revocation of consent may result in our services no longer being available to you without re- striction or the user relationship being terminated. We will inform you in advance of any resulting costs.
This Data Privacy Policy is immediately effective. neon reserves the right to make changes to it at any time. You will be notified of these changes by email and they shall be deemed accepted after 30 days in the absence of any objections having been submitted. If no notice of objection is received within this period, beginning at the point upon which the email message is received, the amended terms and applies shall be deemed to have been agreed and accepted.
In the course of the notice of changes to the Data Privacy Policy, neon shall inform the customer separately of their right to object, the objection period and the implication of the customer not raising an objection.
Links in the document:
neon data privacy policy app: https://www.neon-free.ch/media/neon_app_privacy_policy.pdf
neon data privacy policy website: https://www.neon-free.ch/media/neon_datenschutz_website_en_de.pdf
Apple Push Notification Service: https://www.apple.com/legal/privacy/pdfs/apple-privacy-policy-de-ww.pdf
Google Cloud Messaging Service: https://cloud.google.com/terms/data-processing-terms?hl=de
Huawei Push Service: https://developer.huawei.com/consumer/de/doc/10134
Freshworks Inc.: https://www.freshworks.com/de/
Data privacy policy of Freshworks: https://www.freshworks.com/de/dsgvo/
Data privacy policy and functionalities of Google: https://www.google.com/policies/privacy