01 Introduction

Welcome to NEOM Coin ("we," "us," or "our"). We operate the digital mining platform accessible at theneomcoin.com and any associated mobile applications (collectively, the "Platform").

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Platform. By accessing or using NEOM Coin, you agree to the collection and use of information in accordance with this policy.

Your privacy matters. We are committed to maintaining the trust you place in us. We never sell your personal data to third parties for marketing purposes. Period.

02 Information We Collect

We collect several types of information in connection with the Platform:

Account Information

  • Full name and display name
  • Email address and phone number
  • Date of birth and nationality
  • Encrypted password credentials
  • Referral codes and referrer details

KYC & Identity Verification

  • Government-issued identification documents (passport, national ID)
  • Proof of address documentation
  • Facial recognition data (for liveness verification)
  • Residency and citizenship status

Financial & Transaction Data

  • Wallet addresses and transaction hashes
  • Deposit and withdrawal history
  • Mining plan subscriptions and returns
  • Bank account details (for fiat withdrawals)
  • NEOM Coin transfer history between users

Technical Data

  • IP address and device fingerprint
  • Browser type, version, and operating system
  • Login timestamps and session duration
  • Pages visited and actions taken on the Platform

03 How We Use Your Data

We use your information for the following purposes:

  • To create and manage your NEOM Coin account
  • To process mining plan subscriptions and calculate returns
  • To execute withdrawals, deposits, and NEOM transfers
  • To verify your identity in accordance with anti-money laundering (AML) regulations
  • To process residency pathway applications and eligibility verification
  • To send transactional notifications (login alerts, withdrawal confirmations, ROI updates)
  • To send platform updates and promotional offers (you may opt out at any time)
  • To detect, prevent, and investigate fraud, security breaches, and prohibited activities
  • To comply with legal obligations, court orders, and regulatory requirements
  • To improve and optimize the Platform through analytics
  • To respond to your support requests and enquiries

04 Data Sharing & Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your data only in the following limited circumstances:

  • KYC/AML Providers: Identity verification partners who help us comply with regulatory requirements
  • Payment Processors: Banking and blockchain infrastructure providers needed to execute transactions
  • Residency Partners: Saudi Arabia immigration and NEOM residency program partners (only with your explicit consent)
  • Analytics Providers: Aggregated, anonymized usage data for platform improvement
  • Legal Compliance: When required by law, regulation, legal process, or governmental authority
  • Business Transfers: In connection with a merger, acquisition, or sale of assets (with prior notice)

Residency data: Your information will only be shared with NEOM residency program partners after you expressly opt into the residency pathway and provide separate written consent.

05 Data Security

We implement enterprise-grade security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

  • AES-256 encryption for all data at rest
  • TLS 1.3 encryption for all data in transit
  • Multi-factor authentication (MFA) on all accounts
  • Cold storage wallets for the majority of platform holdings
  • Multi-signature authorization for large transactions
  • Regular third-party security audits and penetration testing
  • Real-time anomaly detection and intrusion prevention systems
  • Staff security training and strict access controls

No method of transmission over the internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee absolute security.

06 Cookies & Tracking

We use cookies and similar tracking technologies to enhance your experience on the Platform:

  • Essential Cookies: Required for the Platform to function (session management, authentication)
  • Analytics Cookies: Help us understand how users interact with the Platform (e.g., pages visited, time spent)
  • Security Cookies: Help detect and prevent fraudulent activity and unauthorized access
  • Preference Cookies: Remember your settings and preferences across sessions

You can control cookie settings through your browser. Note that disabling essential cookies may affect Platform functionality.

07 KYC & Regulatory Compliance

As a digital asset platform, we are required to comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations. This means:

  • All users must complete identity verification before withdrawing funds
  • Enhanced due diligence may be required for high-value transactions or residency applications
  • We are required to report suspicious transactions to relevant financial authorities
  • We may freeze accounts pending investigation of suspected fraudulent activity
  • KYC documents are retained for a minimum period as required by applicable law

We partner with certified KYC/AML providers who process identity verification under their own strict data protection frameworks.

08 Your Privacy Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

  • Access: Request a copy of the personal data we hold about you
  • Correction: Request correction of inaccurate or incomplete data
  • Deletion: Request deletion of your account and personal data (subject to legal retention requirements)
  • Portability: Request your data in a structured, machine-readable format
  • Objection: Object to processing of your data for direct marketing purposes
  • Restriction: Request restriction of processing in certain circumstances
  • Withdraw Consent: Withdraw consent for optional processing at any time

To exercise any of these rights, contact us at privacy@theneomcoin.com. We will respond within 30 days.

09 Data Retention

We retain your personal data for as long as your account is active and as required by law:

  • Account data: retained for the duration of your account plus 5 years after closure
  • Transaction records: retained for 7 years for financial regulatory compliance
  • KYC documents: retained for 5 years after account closure (AML requirement)
  • Communication records: retained for 3 years
  • Analytics data: retained in anonymized form indefinitely

10 International Data Transfers

NEOM Coin operates globally. Your data may be transferred to and processed in countries outside your home jurisdiction, including Saudi Arabia, the United Arab Emirates, and other jurisdictions where our infrastructure and partners operate.

We ensure that all international transfers are protected through appropriate safeguards including standard contractual clauses, adequacy decisions, and equivalent data protection frameworks.

11 Children's Privacy

The NEOM Coin Platform is strictly intended for users 18 years of age or older. We do not knowingly collect personal information from minors. If you believe a minor has created an account, please contact us immediately at privacy@theneomcoin.com and we will take prompt action to remove the account and associated data.

12 Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the "Last Updated" date at the top of this page. For material changes, we will notify you via email or a prominent notice on the Platform at least 14 days before the changes take effect.

Your continued use of the Platform after any changes constitutes your acceptance of the updated Privacy Policy.

13 Contact Us

If you have any questions about this Privacy Policy or our data practices, please reach out:

  • Email: privacy@theneomcoin.com
  • General Support: support@theneomcoin.com
  • Platform: theneomcoin.com/contact

Data Protection Officer: For formal data protection enquiries or to exercise your rights, write to dpo@theneomcoin.com. We aim to respond to all requests within 30 days.