Plan is committed to protecting the privacy of our customers' personal data and
we encourage you to read this privacy statement.
statement describes the personal data that Neo Plan Plus Company (Neo Plan
hereafter) collects from the members. It is also describes the methods we
collect data and why, how collected data will be used, who we can disclose
collected data to and why, how data can be corrected or deleted, the procedures
around protect of collected data, and the process and contact information that
customers can use to raise enquiries, concerns and complaints.
Our Commitment to Personal Data Protection.
Plan is committed to safeguarding our members' personal data by adherence to
the following obligations:
Security Policy and the related policies;
The Canadian Government's
Information Protection and Electronic Documents Act (PIPEDA);
local data protection laws and regulations; and
commitment to our members.
statement applies to the services and products offered by the Neo Plan and bind
all our employees. Neo Plan expects that all our service providers have
introduced data protection principals and technical measures that are similar
to the ones Neo Plan has adopted. This statement refers to personal data from
our Business members or the employees of our Business members and their
families such as a beneficiary under the Plan and in this statement,
we refer to this group of individuals or businesses as: "you".
What Information is collected and how is it done?
Plan collects personal data about you when you enroll, use or benefit from Neo Plan 's services or products or when this data is given to Neo
Plan by third parties, such as companies employing you or your relatives,
insurance companies, private medical insurers, assistance companies, financial
institutions, medical service providers, travel agencies and similar companies,
that are permitted to share this personal data.
data" constitutes information that will help someone to identify or
contact you, including, for example, your full name, address, telephone number or
email address, date of birth, gender, nationality, family status, information
related to your professional activity, status of your health and health of you
collected data does not permit the identification of individual persons, such
as statistics on the number of expatriates and travellers that are eligible in
a member company to receive assistance services or the number of people
visiting the Neo Plan website each month, this data is not considered to be a
provide certain personal data to Neo Plan when, you, for example:
assistance providing services under a medical services contract; seek a
consultation with our consultants;
Contact us to
receive Plan related consultations;
Contact us to
receive Plan member support services;
Contact us to
receive security consultations and security services;
Order services from
Neo Plan websites;
Submit forms and
questionnaires through our web sites;
requests or complaints.
to your agreement to the applicable terms and conditions, you may access
services through the Web, including but not limited to medical, health and
security information and other services which may be added by Neo Plan from
time to time.
you choose to pay for Neo Plan services or products by credit card directly
from the Neo Plan website, you will be required to provide Neo Plan with the
name of your credit card issuer, credit card number, expiration date and other
security information. When you choose to pay for Neo Plan services or products
by other means, we may ask you for your credit card details, contact details
and bank account details.
also provide information to us when you choose to email data to us, or you
participate in marketing and sales initiatives.
Plan will only gather data that is relevant for the purposes for which it will
be used and will not gather excessive or unnecessary data.
Plan shall take reasonable steps to ensure that data is reliable, accurate,
complete, and current, bearing in mind its intended use. You have a
responsibility to keep the data you provide to us updated and we will take
reasonable steps to facilitate this.
Acceptance and Links to other Websites
Neo Plan website may contain links to other websites, which are provided solely
as a convenience to you and not as an endorsement by Neo Plan of the contents
of other web sites. The other web sites may have their own policies, which Neo
Plan does not control, and thus are not addressed or controlled by this
statement or the Neo Plan Data Protection Policy.
cookie is a piece of data stored on your hard drive containing information
of a cookie is in no way linked to any personally identifiable information
while on the Neo Plan website. Neo Plan also uses ‘analytical cookies’. These
allow us to recognize and count the number of visitors logging into our web
site and to see how visitors move around the site when they are using it. This
helps us make sure sites are meeting users’ needs and to find out how we could
improve. The analytical cookies do not capture any personally identifiable
information. Most browsers are initially
set up to accept cookies. Though most cookies expire after a certain period of
time, you can choose to delete a cookie file at any time. You can do so by
resetting your browser to refuse all cookies or to indicate when a cookie is
sent. However, some Neo Plan features or
services may not function properly without cookies. Some of our service
providers (e.g. International SOS's service providers monitoring our
to or control over these cookies. This privacy statement covers the use of
How the Personal Data will be used
Plan will use your personal data to provide you with services and products
you paid for;
paid for by your
employer or your relative's employer;
paid for by an
association or institution (including an educational establishment) of which
you are a member;
part of services provided through the Plan or as
part of services that are provided to you.
Plan may also gather your personal data to assist us in managing services or
products provided to you or your employer. The personal information collected
from the App enables Neo Plan to provide better and more relevant services.
personal data may be transferred to companies within the Neo Plan group or to
service providers that are performing services for Neo Plan or acting as Neo
Plan’s agents. Neo Plan will require that any such service providers agree to
keep your personal data secure and confidential, use it only for the purposes
for which the personal data is transferred and use it only in accordance with Neo
personal data may be transferred to Government authorities, agencies and
institutions as required or permitted by applicable laws and regulations.
Plan shall not collect, use, disclose or transfer your personal data except as
described in this Statement unless you give us your permission to collect, use,
disclose or transfer it for other purposes.
What Choices are Available to Users Regarding Collection, Use, Storage, Disclosure
or Transfer of the Personal Data?
are given the opportunity to 'opt-out' of receiving our services and products. You
may ‘opt-out‘ of email alerts for instance by replying
to the email or clicking the "unsubscribe" link.
will also be given the choice to prohibit Neo Plan from disclosing your
personal data to a third party or for purposes other than to provide services
you are receiving services as an employee or as a member of an employee's
family, or as a member of an association or institution, as a credit card
holder or the recipient of other financial services, the company, association
or institution that has contracted for our services and products on your behalf
will determine the method and means by which you can opt-out and opt-in. Note
that if you choose to 'opt-out', withhold, block or request that we delete your
personal data, you may not be able to receive the benefit of Neo Plan's
services and products.
How Can Users Correct Inaccuracies in their Personal Data?
can review the personal data that Neo Plan has collected from you by contacting
our: assistance center; customer service personnel; or by using your password
to access your records through our website. In order to update, delete, amend
or block any personal information that we create and that we are able to
change, contact us using the following e-mail address: [privacy@NeoPlanPlus.com]
or through the contact link on our website. Should you need our assistance to
access or make changes to your personal information, please submit your request
to us. Corrections or deletions of data resulting
solely from errors by Neo Plan or our service providers shall be paid for by Neo
Plan. In making your request to review, update, amend or block data, you will
be required to provide Neo Plan with details of the data requested and the
reasons why the data needs correction. Neo Plan will ask for proof of your
identity. Neo Plan may ask you to assist in verifying the accuracy of the
updates and the amendments to the personal data. Neo Plan may ask you to cover
the reasonable cost of accessing and providing copies of your personal data if
this is not provided through the Neo Plan website. Neo Plan will strive to
address your request as soon as practicable as and no later than thirty (30)
calendar days from the date your request is received and understood. If Neo
Plan is asked to destroy the personal data, Neo Plan shall use means that
prevents its recreation and Neo Plan shall take reasonable care to ensure that
there is no unauthorised disclosure during the destruction of the data.
What Kind of Security Procedures are Used to Protect the Loss, Misuse, or
Alteration of Your Personal Data under International SOS's Control?
Plan takes precautions to protect its users' information. Neo Plan has implemented policies that
forbid its employees from using or disclosing personal data in an inappropriate
or unlawful manner and maintains security measures to safeguard the personal
data that it maintains from unauthorized access, misuse, alteration, loss or
Collected by Electronic Means
you provide Neo Plan with personal data through online forms and other
electronic methods, the data is protected using industry-standard encryption.
Information Security Policy and the Information Security Procedures and
Neo Plan employees are required to follow the Information Security Policy. The
policy is implemented through the Information Security procedures and
processes. These are periodically reviewed and updated, as the information
security landscape is in a constant state of flux. All new employees are required to sign a
written confirmation that they have read and understood the Information
Security Policy and a confidentiality agreement. Employees also have
confidentiality obligations in their contracts of employment with Neo Plan.
How do I resolve disputes with Neo Plan relating to Personal Data?
you are unsatisfied with the manner in which your question or concern was
addressed, in respect of our online services, you may contact Neo Plan at
you do not wish to make a complaint through our online services, you may direct
all enquiries, concerns or complaints regarding the collection, use, storage,
correction, deletion, blocking, disclosure or transfer of personal data to the
Data Protection Administrator using the contact details attached to this
Plan will investigate all concerns and complaints and will address them
expeditiously. An acknowledgement of the identity of the employee addressing
the complaint and the approximate length of time that will be taken to review the
complaint will be provided no later than five (5) business days from the date
the complaint is received and understood. Regular updates shall be given to you
on the progress of the review if the review is likely to take longer than seven
(7) business days.
have the right at any time, to raise your issues with a data protection
authority or to take your case to a court.
you receive services from Neo Plan through an employer or through a relative's
employer or through an association or institution, or an insurance or financial
services program and your personal information has been improperly collected,
used, stored, disclosed, amended, destroyed, blocked or transferred as a result
of the actions or inactions of the employer, association or institution,
insurance company or financial services company, then you will be directed by Neo
Plan to such employer, association or institution, insurance company or
financial services company. Neo Plan will not be liable for resolving disputes
between you and such companies, associations or institutions.
13. Changes to this Statement
Plan reserves the right to change this policy at any time by notifying users
through its website of the existence of a new privacy statement. This statement
and the policies outlined herein are not intended to and do not create any
contractual or other legal rights.
Updated: June 2012