Privacy Policy

Last modified: January 09, 2019

Introduction

Thank you for using Neighbr!

This Privacy Policy describes how we collect, use, process, and disclose your information, including personal information, in conjunction with your access to and use of the Neighbr Platform and the Payment Services.

If you see an undefined term in this Privacy Policy (such as “Lender” or “Neighbr Platform”), it has the same definition as in our Terms of Service.

When this policy mentions Neighbr,” “we,” “us,” or “our,” it refers to the Neighbr company that is responsible for your information under this Privacy Policy (the “Data Controller”).

Privacy Policy also applies to the Payment Services provided to you by Neighbr Payments pursuant to the payment terms which can be found in our Terms of Service (“Payments Terms”).

Information we Collect

Information You Give To Us

Account Information. When you sign up for an Neighbr Account, we require certain information such as your first name, last name, email address, and date of birth.
Profile and Listing Information. To use certain features of the Neighbr Platform (such as creating a Request or sharing a Lender Item), we may ask you to provide additional information, which may include your address, phone number, and a profile picture.
Identity Verification Information. To help create and maintain a trusted environment, we may collect identity verification information (such as images of your government issued ID, passport, national ID card, or driving license, as permitted by applicable laws) or other authentication information.
Payment Information. To use certain features of the Neighbr Platform (such as creating a Request or sharing a Lender Item), we may require you to provide certain financial information (like your bank account or credit card information) in order to facilitate the processing of payments (via Neighbr Payments).
Communications with Neighbr and other Members. When you communicate with Neighbr or use the Neighbr Platform to communicate with other Members, we collect information about your communication and any information you choose to provide.

Information You Choose To Give Us


Additional Profile Information. You may choose to provide additional information as part of your Neighbr profile (such as gender, language and a personal description).
Other Information. You may otherwise choose to provide us information when you fill in a form, conduct a search, update or add information to your Neighbr Account, respond to surveys, post to community forums, participate in promotions or use other features on the Neighbr platform.

Information That is Necessary for the Use of Payment Services


Profile Information. When you use the Payment Services, the Payment Data Controller requires certain financial information (like your bank account or credit card information) in order to process payments and comply with applicable law.
Identify Verification and Other Information. If you are a Lender, the Payments Data Controller may require identity verification information (such as images of your government issued ID, password, national ID card, or driving license) or other authentication information, your date of birth, your address, email address, phone number and other information in order to verify your identity, provide the Payments Services to you and to comply with applicable law.

Information We Collect from Your Use of the Neighbr Platform

When you use the Neighbr Platform and the Payment Services, we automatically collect information, including personal information, about the services you use and how you use them. This information is necessary for the adequate performance of the contract between you and us, to enable us to comply with legal obligations and given our legitimate interest in being able to provide and improve the functionalities of the Neighbr Platform and Payment Services.


Geo-location Information. When you use certain features of the Neighbr Platform, we may collect information about your precise or approximate location as determined through data such as your IP address or mobile device’s GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings menu.
Usage Information. We collect information about your interactions with the Neighbr Platform such as the pages or content you view, your searches for items, Requests you have made, and other actions on the Neighbr Platform.
Log Data and Device Information. We automatically collect log data and device information when you access and use the Neighbr Platform, even if you have not created an Neighbr Account or logged in. That information includes, among other things: details about how you’ve used the Neighbr Platform (including if you clicked on links to third party applications), IP address, access dates and times, hardware and software information, device information, device event information, unique identifiers, crash data, cookie data, and the pages you’ve viewed or engaged with before or after using the Neighbr Platform.
Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Neighbr Platform, or engage others to track your behaviour on our behalf. You may disable the usage of cookies through your browser settings.
Payment Transaction Information. Neighbr Payments collects information related to your payment transactions through the Neighbr Platform, including the payment instrument used, date and time, payment amount, payment instrument expiration date and billing postcode, IBAN information, your address and other related transaction details. This information is necessary for the adequate performance of the contract between you and Neighbr Payments and to allow the provision of the Payment Services.

Information We Collect from Third Parties

Neighbr and Neighbr Payments may collect information, including personal information, that others provide about you when they use the Neighbr Platform and the Payments Service. We do not control, supervise or response for how the third parties providing your information process your personal data, and any information request regarding the disclosure of your personal information to us should be direct to such third parties.


Third Party Services. If you link, connect, or login to your Neighbr Account with a third-party service (e.g. Google, Facebook), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service.
Background Information. For Members in the United States, to the extent permitted by applicable laws, Neighbr and Neighbr Payments may obtain reports from public records of criminal convictions or sex offender registrations. For Members outside of the United States, to the extent permitted by applicable laws and with your consent where required, Neighbr and Neighbr Payments may obtain the local version of police, background or registered sex offender checks. We may use your information, including your full name and date of birth, to obtain such reports.
Cookies and Similar Technologies. We use cookies and other similar technologies, such as web beacons, pixels, and mobile identifiers. We may also allow our business partners to use these tracking technologies on the Neighbr Platform or engage others to track your behaviour on our behalf. You may disable the usage of cookies through your browser settings.
Other Sources. To the extent permitted by applicable law, we may receive additional information about you, such as demographic data or fraud detection information, from third party service providers and/or partners, and combine it with information we have about you. For example, we may receive background check results (with your consent where required) or fraud warnings from service providers like identity verification services for our fraud prevention and risk assessment efforts. We may receive information about you and your activities on and off the Neighbr Platform through partnerships, or about your experiences and interactions from our partner ad networks.

How We Use Information We Collect

Provide, Improve, and Develop the Neighbr Platform


• Enable you to access and use the Neighbr Platform.
• Enable you to communicate with other Members.
• Operate, protect, improve, and optimize the Neighbr Platform and experience, such as by performing analytics and conducting research.
• Provide customer service.
• Send you service or support messages, updates, security alerts, and account notifications.
• If you provide us with your contacts’ information, we may process this information: (i) to facilitate your referral invitations, (ii) send your requests for references, (iii) for fraud detection and prevention, and (iv) for any purpose you authorize at the time of collection.
• To operate, protect, improve, and optimize the Neighbr Platform and experience, and personalize and customize your experience, we conduct profiling based on your interactions with the Neighbr Platform, your search and booking history, your profile information and preferences, and other content you submit to the Neighbr Platform.

Create and Maintain a Trusted and Safer Environment


• Detect and prevent fraud, spam, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Verify or authenticate information or identifications provided by you (such as to verify your address or compare your identification photo to another photo you provide).
• Conduct checks against databases and other information sources, including background or police checks, to the extent permitted by applicable laws and with your consent where required.
• Comply with our legal obligations.
• Resolve any disputes with any of our Members and enforce our agreements with third parties.
Terms of Service and other policies.
• In connection with the activities above, we may conduct profiling based on your interactions with the Neighbr Platform, your profile information and other content you submit to the Neighbr Platform, and information obtained from third parties. In limited cases, automated processes may restrict or suspend access to the Neighbr Platform if such processes detect a Member or activity that we think poses a safety or other risk to the Neighbr Platform, other Members, or third parties.

Provide, Personalise, Measure and Improve our Marketing


• Send you promotional messages, marketing, advertising, and other information that may be of interest to you based on your preferences (including information about Neighbr or partner campaigns and services) and social media advertising through social media platforms such as Facebook or Google).
• Personalize, measure, and improve our advertising.
• Administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Neighbr or its third party partners.
• Conduct profiling on your characteristics and preferences (based on the information you provide to us, your interactions with the Neighbr Platform, information obtained from third parties, and your search and booking history) to send you promotional messages, marketing, advertising and other information that we think may be of interest to you.

How the Payments Data Controller use the Information


• Enable you to access and use the Payment Services.
• Detect and prevent fraud, abuse, security incidents, and other harmful activity.
• Conduct security investigations and risk assessments.
• Conduct checks against databases and other information sources.
• Comply with legal obligations (such as anti-money laundering regulations).
• Enforce the Payment Terms and other payment policies.

Sharing and Disclosure

With Your Consent

Where you have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your Neighbr Account or when you participate in promotional activities conducted by Neighbr partners or third parties.

Between Members


• When a Borrow submits a Request, certain information about you is shared with potential Lenders in your area, including your first name, request details and your karma.
• When you as a Lender accept a Request, certain information is shared with the Borrower to coordinate the Request; such as your first name and your collection address.

Profile, Listings and Other Public Information


• If you submit content in a community or discussion forum, blog or social media post, or use a similar feature on the Neighbr Platform, that content is publicly visible.
• We may also display information on the Neighbr Platform such as a the chance of a successful Request or recommended, which is determined by your past successful Requests.

Compliance with Law and Protection of our Rights

Neighbr and Neighbr Payments may disclose your information, including personal information, to courts, law enforcement or governmental authorities, or authorized third parties, if and to the extent we are required or permitted to do so by law or if such disclosure is reasonably necessary: (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against Neighbr, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Service, the Payment Terms or other agreements with Members, or (v) to protect the rights, property or personal safety of Neighbr, its employees, its Members, or members of the public.

These disclosures may be necessary to comply with our legal obligations, for the protection of your or another person's vital interests or for the purposes of our or a third party’s legitimate interest in keeping the Neighbr Platform secure, preventing harm or crime, enforcing or defending legal rights, or preventing damage.

Where appropriate, we may notify Members about legal requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud Neighbr’s property, its Members and the Neighbr Platform. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that Member about the request after the fact where appropriate and where we determine in good faith that we are no longer prevented from doing so.

Service Providers

Neighbr and Neighbr Payments uses a variety of third-party service providers to help us provide services related to the Neighbr Platform and the Payment Services. Service providers may be located inside or outside of the European Economic Area (“EEA”). Our service providers are based in Europe, India, Asia Pacific and North and South America.

For example, service providers may help us: (i) verify your identity or authenticate your identification documents, (ii) check information against public databases, (iii) conduct background or police checks, fraud prevention, and risk assessment, (iv) perform product development, maintenance and debugging, or (v) provide customer service, or payments services. These providers have limited access to your information to perform these tasks on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

Neighbr and the Neighbr Payments will need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

Social Media Platforms

Where permissible according to applicable law we may use certain limited personal information about you, such as your email address, hash it and to share it with social media platforms, such as Facebook or Google, to generate leads, drive traffic to our websites or otherwise promote our products and services or the Neighbr Platform. These processing activities are based on our legitimate interest in undertaking marketing activities to offer you products or services that may be if your interest.

The social media platforms with which we may share your personal data are not controlled or supervised by Neighbr. Therefore, any questions regarding how your social media platform service provider processes your personal data should be directed to such provider.

Please note that you may, at any time ask Neighbr to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@neighbr.co.

Social Media Platforms

We may also share aggregated information (information about our users that we combine so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

Other Important Information

Analysing your Communication

We may review, scan, or analyse your communications on the Neighbr Platform for fraud prevention, risk assessment, regulatory compliance, investigation, product development, research, and customer support purposes. For example, as part of our fraud prevention efforts, we scan and analyse messages to mask contact information and references to other websites. In some cases, we may also scan, review, or analyse messages to debug, improve, and expand product offerings. We use automated methods where reasonably possible. However, occasionally we may need to manually review some communications, such as for fraud investigations and customer support, or to assess and improve the functionality of these automated tools. We will not review, scan, or analyse your communications to send third party marketing messages to you, and we will not sell reviews or analyses of these communications.

These activities are carried out based on Neighbr’s legitimate interest in ensuring compliance with applicable laws and our Terms, preventing fraud, promoting safety, and improving and ensuring the adequate performance of our services.

Google Maps/Earth

Parts of the Neighbr Platform use Google Maps/Earth services, including the Google Maps API(s). Use of Google Maps/Earth is subject to Google Maps/Earth Additional Terms of Use and the to Google Privacy Policy.

Your Rights

Managing Your Information

You may access and update some of your information through your Account settings. If you have chosen to connect your Neighbr Account to a third-party application, like Facebook or Google, you can change your settings and remove permission for the app by changing your Account settings. You are responsible for keeping your personal information up-to-date.

Rectification of Inaccurate or Incomplete Information

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself within your Neighbr Account).

Data Access and Portability

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

Data Access and Portability

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the Neighbr Platform to you, you can request that we erase your personal information and close your Neighbr Account. Please note that if you request the erasure of your personal information:


• We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing safety. For example, if we suspend a Neighbr Account for fraud or safety reasons, we may retain certain information from that Neighbr Account to prevent that Member from opening a new Neighbr Account in the future.
• We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Neighbr and Neighbr Payments may keep some of your information for tax, legal reporting and auditing obligations.
• Information you have shared with others (e.g., Reviews, forum postings) may continue to be publicly visible on the Neighbr Platform, even after your Neighbr Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers.
• Because we maintain the Neighbr Platform to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period.

Objection to Processing

In some jurisdictions, applicable law may entitle you to require Neighbr and Neighbr Payments not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing Neighbr and/or Neighbr Payments will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing, or such processing is required for the establishment, exercise or defence of legal claims.

Where your personal information is processed for direct marketing purposes, you may, at any time ask Neighbr to cease processing your data for these direct marketing purposes by sending an e-mail to opt-out@neighbr.co.

Complaints

You have the right to lodge complaints about the data processing activities carried out by Neighbr and Neighbr Payments before the competent data protection authorities.

Security

We are continuously implementing and updating administrative, technical, and physical security measures to help protect your information against unauthorized access, loss, destruction, or alteration. Some of the safeguards we use to protect your information are firewalls and data encryption, and information access controls. If you know or have reason to believe that your Neighbr Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Neighbr Account, please contact us.

Changes to This Privacy Policy

Neighbr reserves the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Neighbr Platform and update the “Last Updated” date at the top of this Privacy Policy. We will also provide you with notice of the modification by email at least thirty (30) days before the date they become effective. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Neighbr Platform will be subject to the revised Privacy Policy.

Contact Us

If you have any questions or complaints about this Privacy Policy or Neighbr’s information handling practices, you may email us or contact us:
Neighbr, Legal Department, 54 Padwell Road, Southampton, UK