Neo Privacy Policy
Effective: Dec 1 2023

Neo Financial Technologies Inc., Neo Mortgage Services Inc. and their subsidiaries and affiliates (collectively “Neo”, “us” and “we”) value your privacy. We are committed to safeguarding your personal information. This Privacy Policy sets out our policies and procedures for the collection, use, retention, and disclosure of your personal information.

This Privacy Policy applies to the privacy practices of Neo on our website, located at https://www.neofinancial.com and any subdomains (the “Website”) and our “Neo Financial” web and mobile application (the “App”, and together with the Website, the “Platform”), and to our other interactions with you.

Neo is accountable for the collection, use, and disclosure of your personal information. When you apply for financial products and services such as a credit card, a deposit account or an investment account, Neo Financial Technologies Inc. is accountable for the collection, use and disclosure of your personal information. When you apply for a mortgage, Neo Mortgage Services Inc. is accountable for the collection, use and disclosure of your personal information. Our Privacy Officer oversees the protection of your personal information and ensures our compliance with our Privacy Policy and applicable privacy laws. Please see the contact details for our Privacy Officer at the end of this Privacy Policy, in section 7.

What information is in this Privacy Policy?
This Privacy Policy covers the following topics:

What Personal Information Do We Collect from You and How Do We Use It?
a. Personal Information We Collect for Our Own Use and Purposes
i. Information You Provide Us
ii. Information We Collect Automatically
ii. Information We Collect From Third Parties
b. Personal Information We Process on Behalf of Third-Party Organizations
Sharing of Personal Information
Your Choices
Safeguarding and Retention of Personal Information
Information About Our Privacy Governance Policies and Practices
Updates to our Privacy Policy
Contact Us
1. What Personal Information Do We Collect From You and How Do We Use It?
The types of personal information that we collect, and how we process it, depends on whether we are processing personal information for our own purposes, or on behalf of our financial, co-brand or other third party partners, as set out below.
A. Personal Information We Collect for Our Own Use and Purposes
We collect personal information about you to provide you with financial products and services you request. We do this by collecting information: (i) from you, when you provide us with your personal information directly; (ii) automatically, when you use the Platform; or (iii) from third parties, when you authorize us, or as otherwise permitted or required by applicable law.
(i) Information You Provide to Us
We collect the personal information that you provide directly to us for the following purposes:

Signing-up for a Neo Profile. To access most financial products and services we offer you need to have a Neo profile. To create your Neo profile, we collect your email address, phone number, and a password that you select. We use this information to administer and authenticate your access to your Neo profile, to enable you to access products and services, and to update you about changes to the Platform.
Applying for Financial Products and Services. If you have a Neo profile, you can apply for a variety of financial products and services through the Platform. The personal information that we collect from you depends on the financial product or service that you apply for. In general, and in addition to your Neo profile information, we may collect your full name, date of birth, mailing and home address, move-in date, and employment or educational information to confirm your identity, process and update you about your application, prevent fraud, and comply with applicable legal and regulatory obligations (including those relating to money laundering, terrorist financing and financial dealings with certain sanctioned individuals).
If you apply for financial products and services, we may collect additional information from you as follows:
Deposit Account: If you apply for a deposit account such as a Neo Money Account, Neo High Interest Savings Account (HISA), or Neo Everyday Account, we may collect additional information including your reason for opening the account, Social Insurance Number (“SIN”), whether you pay taxes outside of Canada, and your Tax Identification Number. We may also collect certain documents to verify your identity, as well as information from your identity documents, such as your name and the type of document. We use this information to comply with legal and regulatory obligations (including tax reporting).
Credit Card: If you apply for a Credit Card, including, but not limiting to, the Neo Credit Card, Neo Secured Card, Tims® Credit Card powered by Neo or Hudson‘s Bay Mastercard® powered by Neo, we collect additional financial information, including income related information, living situation (i.e., move-in date, and whether you rent, own or live with family), housing costs, living expenses (e.g., utilities) (and, for residents of Quebec, we may collect name of employer, monthly credit or loan payments, and source of income) to assess your creditworthiness, and to confirm your eligibility for our credit products. With your consent, we will run a credit check to help assess your eligibility for a credit card and the credit limits. Please note that a Neo profile is not required for the Tims® Credit Card.
Neo Mortgages: If you apply for a Neo Mortgage, we collect additional information, including your address history, employment history, financial and transaction information, and SIN to confirm your identity, prevent fraud, confirm the status of your mortgage, conduct a credit check and to comply with applicable legal and regulatory obligations (including those related to mortgage suitability). We may also collect biometric information (such as an image of your government-issued identification) in certain cases. Providing your SIN for identity verification purposes is optional. In addition to this information, we collect income information (e.g. banking statements), tax information, living situation, housing costs, information regarding your assets and liability, information about the property you intend to purchase, and transaction information (e.g. payment history and parties to transactions) to process your mortgage application, assess your creditworthiness, and confirm which mortgage products and services are most suitable for you. Please note that a Neo profile is not required to apply for a Neo Mortgage.
Neo Invest: If you apply for an investment account provided by our investment account provider, we collect additional information, including your desired investment account type (i.e., TFSA, RRSP, or personal), and SIN in order to confirm your identity, prevent fraud, and comply with legal and regulatory obligations (including regulations relating to investment suitability and tax reporting). We also collect information about your account objectives, risk capacity, and investment timelines in order to comply with applicable legislation.
Delivering Financial Products and Services. If you have a Neo profile and have been approved for a financial product or service offered by Neo, we use your financial and transaction information, including card and account usage, payment history, and parties to transactions, to deliver the financial products and services to you, and provide you with relevant information about your account. We may use your contact information, such as your phone number, email address, or physical address, to contact you by mail, email, SMS message (message and data rates may apply), push notification, and telephone to update you on changes to the financial products and services, send you important updates about financial account opening disclosures, and important or useful messages about your financial accounts.
Authorized Users and Counterparties. When you provide the contact or identity information for another person (such as a counterparty or an authorized user), we may collect their name, email address, and phone number (and for business contact, payee name and account number).
Surveys/Research. From time to time, we may offer you the opportunity to participate in one of our surveys or other research projects. The information obtained through our surveys and customer research is used in an aggregated, non-personally identifiable form to help us understand our customers and to enhance our product and service offerings.
Contacting Us. When you contact us with a question or comment regarding our products or services by telephone, email, or online chat, we may collect your contact information, such as your phone number, email address, or physical address, along with additional information we need to respond to your inquiry. We collect this information to contact you by mail, email, SMS message (message and data rates apply), in-App messaging and telephone to respond to your question or comment. We may also collect certain information to verify your identity in connection with an inquiry about your account, such as a response to a security question. We also use customer inquiries to train our personnel, and for quality assurance purposes.
Personalized Marketing. With your consent, we may automatically collect information regarding your use of the Platform, including your transactions and the financial products and services that you use or are eligible for, to provide you with personalized marketing communications. For example, we try not to market products to you that you have already registered for. Personalized marketing is optional. You can manage your privacy preferences within the Platform. If you reside in Quebec, you are opted out of personalized marketing. You can also contact our Privacy Officer using the contact information set out at section 7 of this Privacy Policy.
Marketing Communications. In order to advertise and market products and services to you, and to customize the Platform for you, you may provide us with your mailing address, email, telephone number and marketing preferences. We use this information to contact you by mail, email, SMS message (message and data rates may apply), push notification, and telephone with marketing communications. You can request that we not contact you for the purposes of advertising, marketing, promotions, rewards programs, research by updating your privacy preferences within the Platform. You can also contact our Privacy Officer using the contact information set out at section 7 of this Privacy Policy.
(ii) Information We Collect Automatically
We collect the following personal information automatically when you use the Platform.

Neo Website. In general, you can visit our Website without telling us who you are. We may use information about your web browser, time zone, application and Website use, Internet Protocol (IP) address, mobile device ID, search and Website history, and screens visited, to evaluate existing products and services, develop new products and services, optimize our Website, perform analytics, and improve the customer experience we offer.
Cookies: We use “cookies”, which are small computer files that a website‘s server places on your computer so that we can recognize your computer or device when you return. You can set your browser to notify you when you receive a cookie or to reject cookies, but this may impair our ability to customize and test your experience, like remembering your preferred language or present location-specific information to you.
Analytics: The Website also uses web analytics services such as Google Analytics to help us gather and analyze information about the areas visited on the Website (such as the pages most read, time spent, search terms and other engagement data) in order to evaluate and improve the user experience and the Website. For more information or to opt-out using the Google Analytics opt-out browser add-on, see “How Google uses data when you use our partners' sites or apps”and “Google Analytics and Privacy”.
Third-Party Links: Our Website may contain links to other websites that Neo does not own or operate. We provide links to third-party websites as a convenience to the user. These links are not intended as an endorsement of or referral to the linked websites. The linked websites have separate and independent privacy policies, notices and terms of use. We do not have any control over such websites, and therefore we have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose, secure and otherwise treat personal information. We encourage you to read the privacy policy of every third-party website you visit.
Neo App. When you use the Neo App, we may collect and use information as follows:
Location Information: If you consent, we collect your location information by accessing your device‘s GPS coordinates so that we can provide you with location-based services, including information about nearby Neo Rewards partners. You can opt-out of location tracking at any time by turning off your location services for the App in the settings of your mobile device.
Push Notifications: If you provide your consent to receive push notifications, we may display push notifications on your mobile device such as welcome messages, product features and promotional offers. If you wish to stop receiving push notifications from us, you can turn off push notifications for the App in the settings of your mobile device.
App Usage Information and Analytics: As with many applications, certain limited data is required for the App to function on your device. This data includes the type of device hardware and operating system, unique device identifier, IP address, language settings, and the date and time the App accesses our servers. We use this information to help us understand the activity on the App, to monitor and improve the App, and to tailor your in-App experience. In addition, we may use third party service providers to collect analytical information about your use of the App, such as the App features used and time spent on the App, to help us tailor your in-App experience, improve our products and the quality of our App, and to manage and analyze data in order to better understand our users.
Additional Information: We will use commercially reasonable efforts, given the limitations imposed upon us by third party providers such as Apple and Google, to clearly disclose what, if any information is collected by the App, how it is used, and with whom it is shared. Please note, certain practices are outside of our control, for example, tracking by Google or Apple or your telecommunications carrier. We are not responsible for the actions of such third parties. You should always read and understand the policies of any third-party provider, such as Google with respect to Android apps and Apple with respect to iOS apps, and your telecommunications carrier, before making any purchase or downloading any app.
Interest Based Advertising. We may use third parties such as ad exchanges and data companies to serve our advertisements on our Website or other websites. These companies may use cookies, tracer tags or web beacons to report certain information about your visits to our Website, and other websites (such as web pages you visit and your response to ads) in order to measure the effectiveness of our marketing campaigns and to deliver ads that are more relevant and tailored to you, both on and off our Platform. To learn more about this behavioural advertising practice or to opt-out of this type of advertising, you can visit the Digital Advertising Alliance website here, or at or the Digital Advertising Alliance of Canada website here.
Automated Decision Making. When we process your personal information we may use automated decision making systems to help provide better products and services to you (i.e. to verify identity, assess internal risk or creditworthiness), for security, anti-money laundering, and fraud detection/prevention purposes. You may contact us for information regarding our use of these systems, including challenging a decision, in section 7.
(iii) Information We Collect from Third Parties
We collect personal information about you from third parties in the following circumstances:

Identity Verification. When you apply for certain financial products and services offered by Neo, we may use service providers to verify your identity. We may collect information from telecommunications providers, including name, phone number, and device information, to confirm your identity and prevent fraud. We will share your identity information, such as name, address and date of birth, with our service provider to complete a credit file identity verification and we will collect information from this verification, such as your name, date of birth, address and credit information. Our service providers may also collect and use biometric information (such as an image of your government-issued identification along with a real time image) to verify your identity. We collect the final result of the identity verification process (i.e., verified or not verified) as well as information from your identification, such as the ID number, in order to confirm your identity, prevent fraud, and comply with applicable legal and regulatory obligations (including those relating to money laundering, terrorist financing and financial dealings with certain sanctioned individuals).
Anti-Money Laundering and Sanctions Checks. When you apply for financial products and services offered by Neo, we use service providers to meet our regulatory obligations regarding anti-money laundering and sanctions. We review the final result of anti-money laundering checks (i.e., clear or not clear) in order to comply with applicable legal and regulatory obligations (including those relating to money laundering, terrorist financing and financial dealings with certain sanctioned individuals).
Credit Checks. When you apply for certain financial products and services offered by Neo, such as the Neo Credit Card (including the Tims® Credit Card) or a Neo Mortgage, we collect identity information and financial and transactional information from credit reporting agencies, such as TransUnion and/or Equifax. We use your name, address, SIN, and date of birth to obtain certain credit, financial, personal, and business information contained in your credit report, to the extent provided by a credit bureau, for the purposes of verifying your creditworthiness, assessing and managing our credit risks, establishing credit and hold limits, qualifying you for other products and services, and detecting and preventing fraud and other decisions about your account. We may also share information with credit reporting agencies on an ongoing basis in order for Neo and the credit reporting agencies to maintain accurate credit information within their databases, in accordance with applicable laws.
Third Party Accounts. If you consent and provide account details for bank accounts with other financial services providers in order to fund your account, we collect information about this bank account, including financial institution name and number, account number, transit number, and account balances from a service provider, such as Flinks, to facilitate these transactions.
Credit Cards Partners. If you apply for certain credit products through our partners, such as the Tims® Credit Card on the Tim Hortons platform, we collect information about you from our partners, such as TDL Group Corp. (“TDL”), in order to process your credit card application, including your name, email address, phone number, date of birth, mailing address, and employmen