Privacy Policy

PRIVACY POLICY

Last Updated: September 2026

eData LTD, doing business as NeoPeople ("NeoPeople," "we," "us," or "our"), is committed to protecting the privacy, confidentiality, and security of personal information.

This Privacy Policy explains how personal information may be collected, used, stored, disclosed, and protected when individuals visit our website, communicate with us, or use the NeoPeople human resources, payroll, workforce management, employee self-service, recruitment, time and attendance, and related services (collectively, the "Services").

NeoPeople provides its Services primarily to businesses, government entities, public authorities, and other organizations ("Customers") that use NeoPeople to manage information relating to their employees, applicants, contractors, and other authorized users.

1. OUR ROLE IN PROCESSING PERSONAL INFORMATION

Information NeoPeople Collects Directly

When you visit the NeoPeople website, request information or a demonstration, communicate with us, or otherwise interact directly with NeoPeople, eData LTD may determine the purposes and means of processing that information.

In these circumstances, NeoPeople is responsible for the processing described in this Privacy Policy.

Information Processed on Behalf of Customers

Most workforce information within NeoPeople is provided or controlled by our Customers.

When an employer, government entity, public authority, business, or other organization uses NeoPeople to process information about employees, applicants, contractors, or other individuals, the Customer generally determines why the information is collected and how it is used.

In these circumstances, NeoPeople processes personal information on behalf of and according to the instructions of the Customer, subject to applicable law and contractual requirements.

If your personal information is contained in a NeoPeople account provided by your employer or another organization, questions or requests concerning your employment or workforce records should generally be directed first to that organization.

2. INFORMATION PROCESSED THROUGH NEOPEOPLE

The information processed depends on the modules, features, and configurations selected by each Customer.

Personal information may include:

• name, address, telephone number, email address, and other contact information;
• employee or personnel identification numbers;
• date of birth and other demographic information;
• employment status, hire date, job title, position, department, unit, location, and organizational assignment;
• employment history;
• salary, wages, compensation, allowances, bonuses, overtime, and other earnings;
• payroll calculations and payroll history;
• deductions and benefits;
• income tax and statutory contribution information;
• bank account or direct-deposit information, where applicable;
• government, tax, social-security, or other statutory identifiers;
• payslips and payroll-related records;
• attendance, working hours, schedules, shifts, overtime, and time records;
• leave, vacation, and absence information;
• recruitment and applicant information;
• qualifications, education, training, skills, and professional experience;
• performance and appraisal information;
• emergency contacts and dependent information;
• employee photographs, where provided;
• correspondence, requests, approvals, claims, and workflow records;
• documents uploaded to or generated by the platform;
• account, authentication, and access information;
• audit logs and security records; and
• other employment-related information entered into the platform by Customers or their authorized users.

Not every Customer uses every NeoPeople module, and therefore not every category listed above is processed for every individual.

3. PAYMENT-CARD INFORMATION

NeoPeople does not collect or process credit-card numbers, debit-card numbers, card security codes, or other payment-card credentials through the NeoPeople HR and payroll platform.

Payroll information, employee bank-account information, compensation information, and other employment-related financial information processed through NeoPeople are distinct from payment-card information.

4. BIOMETRIC INFORMATION

Certain NeoPeople deployments support biometric-enabled time and attendance functionality.

Where fingerprint-based biometric devices are used, the device converts characteristics of a fingerprint into a biometric template used for identification or verification.

NeoPeople does not store an image of the individual's fingerprint for this purpose.

Biometric templates processed through NeoPeople-supported systems are stored in encrypted form and are subject to access controls and security safeguards.

NeoPeople does not use biometric information for advertising, marketing, profiling for advertising purposes, or sale to third parties.

Where NeoPeople processes biometric information on behalf of a Customer, the Customer is responsible for determining the appropriate legal basis for collecting and using biometric information and for providing any notices, obtaining any permissions or consents, and establishing any policies required by applicable law.

Biometric information is processed only for authorized purposes associated with the applicable workforce-management functionality.

5. INFORMATION COLLECTED THROUGH OUR WEBSITE

When you visit neopeople.com or communicate directly with NeoPeople, we may collect information that you voluntarily provide, including:

• name;
• business email address;
• telephone number;
• organization or company;
• job title;
• country;
• information submitted through contact, partnership, or demonstration-request forms; and
• information contained in communications with us.

Our servers may also automatically process limited technical information necessary to deliver and secure the website, such as IP addresses, browser information, HTTP request information, timestamps, and security logs.

NeoPeople does not use its website to collect precise device geolocation information.

NeoPeople does not obtain personal information about website visitors from data brokers, public databases, marketing partners, or social-media platforms for marketing-profile purposes.

NeoPeople does not currently use third-party advertising or behavioral-tracking technologies to create advertising profiles of website visitors.

6. HOW WE USE PERSONAL INFORMATION

Depending on the context and the Services selected by a Customer, personal information may be processed to:

• provide and operate the NeoPeople platform;
• create and administer authorized user accounts;
• provide human resources and employee-record management;
• calculate and administer payroll;
• manage time and attendance;
• manage schedules, shifts, and overtime;
• administer leave and absence;
• support recruitment and applicant management;
• support performance-management processes;
• provide employee and manager self-service functionality;
• process authorized requests, claims, approvals, and workflows;
• generate reports and workforce information;
• authenticate users and control access;
• maintain audit trails;
• protect the confidentiality, integrity, and availability of the Services;
• detect and investigate security events;
• provide technical and customer support;
• diagnose and resolve technical problems;
• maintain service reliability and performance;
• communicate service-related information;
• respond to inquiries and demonstration requests;
• improve the Services;
• comply with contractual and legal obligations; and
• establish, exercise, or defend legal rights.

NeoPeople processes Customer workforce information only for legitimate service, security, support, contractual, or legal purposes and in accordance with Customer instructions where NeoPeople is acting on behalf of the Customer.

7. CUSTOMER RESPONSIBILITIES AND ACCESS

Customers are responsible for determining which individuals are authorized to access their NeoPeople environment and for appropriately configuring user roles, permissions, workflows, and access rights.

NeoPeople personnel do not access Customer workforce information simply because it is stored in the platform.

Authorized NeoPeople personnel may access Customer information where reasonably necessary to provide requested support, maintain or secure the Services, investigate technical or security incidents, perform authorized maintenance, comply with lawful requirements, or otherwise provide Services authorized by the Customer.

Such access is limited to authorized personnel and is subject to appropriate security and access controls.

8. SERVICE PROVIDERS AND DISCLOSURE OF INFORMATION

NeoPeople does not sell employee or workforce personal information.

NeoPeople may use service providers where necessary to operate and support the Services.

NeoPeople currently uses Google Cloud infrastructure for hosting and related cloud services. Customer information may therefore be processed or stored within Google Cloud infrastructure in accordance with NeoPeople's service arrangements and applicable security controls.

NeoPeople does not currently use a separate third-party security or monitoring provider that receives Customer information.

Personal information may also be disclosed where reasonably necessary to authorized representatives of the Customer, at the direction of the Customer, to professional advisers subject to appropriate confidentiality obligations, to governmental or regulatory authorities where required by law, or in connection with a corporate transaction subject to appropriate protections.

9. CUSTOMER-AUTHORIZED INTEGRATIONS

NeoPeople may support integrations or data exchanges with third-party systems selected or authorized by Customers.

Depending on the Customer and jurisdiction, these may include banking systems, tax authorities, social-security or statutory agencies, accounting systems, biometric attendance devices, and other business or government systems.

Information is transmitted through such integrations only as necessary to provide the authorized functionality and subject to the Customer's instructions and applicable requirements.

10. DATA HOSTING AND INTERNATIONAL TRANSFERS

NeoPeople's cloud infrastructure is hosted in the United States.

As a result, personal information relating to individuals in Belize, the Caribbean, or other jurisdictions may be stored or processed in the United States.

Where applicable data-protection law requires safeguards for international transfers of personal information, NeoPeople will implement appropriate contractual, technical, organizational, or other lawful safeguards.

Customer-specific requirements concerning hosting, international transfers, or data location may also be addressed contractually.

11. INFORMATION SECURITY

NeoPeople maintains administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, loss, or destruction.

Depending on the applicable system and service, safeguards may include:

• encryption of information in transit;
• encryption of sensitive information at rest where appropriate;
• encryption of biometric templates;
• role-based access controls;
• user authentication;
• multi-factor authentication capabilities;
• access restrictions based on authorization;
• audit logging;
• security monitoring;
• network and infrastructure security controls;
• backup and recovery procedures;
• vulnerability and security management;
• controlled administrative access; and
• security testing and review.

Although NeoPeople maintains safeguards designed to protect personal information, no information system or method of electronic transmission can be guaranteed to be completely secure.

12. DATA RETENTION

NeoPeople retains personal information only for as long as reasonably necessary to provide the Services and satisfy Customer instructions, contractual requirements, security requirements, and applicable legal obligations.

Active Customers

While a Customer continues to use NeoPeople, the Customer generally determines how long employee and workforce records should be retained, subject to applicable law and the functionality of the Services.

When an individual employee leaves an organization, the Customer remains responsible for determining the appropriate retention period for the employee's HR and payroll records based on applicable employment, payroll, tax, regulatory, and other legal obligations.

Customer Termination

Following termination of a Customer's NeoPeople service, Customer data may be retained for a period of up to six (6) months to permit appropriate transition, recovery, legal compliance, or other legitimate post-termination requirements.

After the applicable retention period, Customer data will be deleted, anonymized, or rendered inaccessible in accordance with NeoPeople's data-retention and deletion procedures, except where continued retention is required by law.

Residual copies contained in backups may remain until those backups are overwritten or deleted according to the applicable backup lifecycle.

13. PRIVACY RIGHTS

Depending on your location and applicable law, you may have certain rights concerning your personal information, including rights to request access, correction or deletion; object to or restrict certain processing; withdraw consent where applicable; request information concerning processing or disclosures; request portability where provided by law; and make a complaint to an applicable data-protection or privacy authority.

These rights may be subject to exceptions and limitations under applicable law.

Employee and Customer-Controlled Information

If NeoPeople processes your personal information on behalf of your employer, a government entity, or another Customer, you should generally submit your privacy request to that organization first.

Because the Customer controls the employment or workforce record, NeoPeople may refer the request to the Customer or assist the Customer in responding to a valid request.

NeoPeople will not independently alter or delete Customer-controlled employment records where doing so would conflict with the Customer's lawful instructions or applicable legal obligations.

14. DATA PROTECTION LAWS

NeoPeople provides Services to organizations in multiple jurisdictions, including countries in the Caribbean and the United States.

Personal information will be handled in accordance with privacy and data-protection laws applicable to the particular processing activity.

Depending on the jurisdiction, Customers and individuals may have additional rights or obligations concerning collection, use, access, correction, retention, disclosure, international transfer, or deletion of personal information.

Nothing in this Privacy Policy is intended to restrict rights granted to individuals under applicable law.

15. CHILDREN AND DEPENDENT INFORMATION

NeoPeople is a business and workforce-management platform and is not directed toward children for general consumer use.

However, a Customer may enter information concerning an employee's dependents or other minors where reasonably necessary for employment, benefits, statutory, emergency-contact, or administrative purposes.

In those circumstances, NeoPeople processes the information on behalf of the Customer and according to Customer instructions and applicable law.

16. MARKETING COMMUNICATIONS

Individuals who contact NeoPeople, request information, or otherwise establish a business relationship with us may receive appropriate communications concerning NeoPeople products, services, demonstrations, events, or related business matters.

Where required, marketing communications will be sent only with an appropriate legal basis or permission.

Recipients may unsubscribe from marketing communications using the unsubscribe mechanism provided in the communication or by contacting NeoPeople.

Service, security, transactional, account, and Customer-support communications are not considered marketing communications and may continue where necessary to provide the Services.

17. THIRD-PARTY LINKS AND SERVICES

The NeoPeople website or platform may contain links to or integrations with third-party websites, systems, or services.

Where a third party independently determines how it processes personal information, its own privacy policies and practices apply.

NeoPeople is not responsible for the independent privacy practices of third-party websites or services that NeoPeople does not control.

18. CHANGES TO THIS PRIVACY POLICY

NeoPeople may update this Privacy Policy periodically to reflect changes in our Services, technology, security practices, legal requirements, or data-processing activities.

The "Last Updated" date at the beginning of this Privacy Policy will identify the most recent revision.

Where required by applicable law or appropriate because of the significance of a change, NeoPeople may provide additional notice to affected Customers or users.

19. CONTACT US

Questions about this Privacy Policy or NeoPeople's privacy practices may be directed to:

eData LTD
Doing business as NeoPeople
Belize

Email: info@neopeople.com

If your request concerns employment, payroll, attendance, biometric, recruitment, or other workforce information maintained in NeoPeople by your employer or another organization, you should generally contact that organization first.

NeoPeople will cooperate with its Customers as appropriate in responding to valid privacy and data-protection requests.