Privacy Policy

Last Updated: March 25th, 2024.

Please read this Privacy Policy carefully before using the AIIME website (“the Site” or “our Site”). As used in this Privacy Policy, “AIIME” means Neptune Technologies LLC,, and its in-application and web experiences (collectively “Neptune”).

At Neptune, we take privacy and security seriously. This Privacy Policy outlines how Neptune (“we,” “our,” or “us”) process, store, transfer, and disclose the information we collect about you through our websites, mobile apps, and other online services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer service channels. Neptune collects or observes information through a variety of difference contexts and how we use, process, store, transfer, and disclose Personal Information varies based on the context through which it was collected.

Information we collect and how we collect it.

  • Information You Provide

We collect information you provide when you use our Services or otherwise engage or communicate with us as described below.

  • Identity Data, such as your name, date of birth, marital status, social security number, biometric identifiers, and other data on government-issued identification documents;
  • Contact Data, such as your email address, mailing address, and telephone number;
  • Financial Data, such as your bank account and payment card details, and information about your income, account balances, financial transaction history, credit history, tax information, and credit scores;
  • Profile Data, such as your username and password, your knowledge assessment results, your interests, preferences, feedback, and survey responses;
  • Stored Content, such as photos from your mobile phone gallery or contacts stored in your mobile device or email accounts. We only collect this information with your permission; and
  • Additional Data You Provide, such as via focus groups, survey responses, contests/sweepstakes, customer support, data you provide in memos when using our Pay & Request Service, or other means.
  • Information you provide us when using our Pay & Request Service: Pay & Request Recipient Contact Information: In order to conduct a money transfer using our Pay & Request payment Service, we collect information (including the name and an email address or phone number) from you about the intended recipient of the payment you request us to make.
  • Other Information You Provide: We collect additional personal information that you choose to provide to us, including your contact list information and photograph.  

Categories Of Types of Personal Information and Types of Information Defined

“Personal Information” is information relating to, directly or indirectly, an identified or identifiable natural person or household. This includes things like your name, postal address, telephone number, and email address, as well as less obvious information, which are included in the following defined categories. We plan to collect, and have collected within the preceding 12 months, the following categories of Personal Information:

  • Individual Identifiers This includes information like your name, email address, physical address, telephone number, login alias, IP address or Other Information that identifies you regardless of your relationship to Neptune.
  • Inferences This includes customer profiles, usage preferences, or other information about an individual’s anticipated or assumed actions or behaviors.
  • Customer Records This includes information like your Neptune name, job title, account number, customer identifier, or Other Information that relates to you as a customer of Neptune.
  • Education information This includes information about your educational history, such as the schools you have attended, the courses of study you followed, the status of any required continuing education for professional licensing, or Other Information relating to your education.
  • Commercial Information This includes payment card data, financial account information, account information, records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies of the customer, and Other Information necessary to collect and process payment for products and services ordered by the customer.
  • Electronic Network Information This includes information like browser and device data, and internet or network activity information, such as activity on our Websites and Services, data collected through cookies, pixel tags and other technologies, and Other Information that is generated through your use of the internet to access our websites.
  • Audio, electronic, visual, or similar information This includes information that is captured on audio or video recording, such as if a telephone or video call is recorded, or simply observable in such interaction or in an Offline Context.
  • Protected Class Information  This includes characteristics of protected classifications under California or federal law, such as sex, age, gender, race, disability, marital status, medical conditions, gender identity and expression, and military/veteran status.
  • Professional and Employment Related Information This includes your contact details, user name and password to be able to access the Careers Site where you can apply for jobs, and information about your current or past employers, memberships in professional associations or trade unions, and professional licensing status if you make such information publicly available in the context from which the Personal Information is collected, such as in your publicly available social media accounts, through a resume submitted to us, or by attending a professional event associated with an affinity group. This may also include your work authorization status, skills, information relating to references and any other information you elect to provide to us (e.g., employment preferences, willingness to relocate, current salary, desired salary, awards or professional memberships).
  • Sensitive Personal Information Protected under Law This includes characteristics of protected classifications under law, such as information about your age, race, ethnicity, religion, gender, gender identity, sexual preference, sex life, disability, political preference, trade union membership, philosophical views, religious beliefs, marital status, citizenship, immigration status, medical or health information, biometric information, biometric templates, veteran status, precise geolocation, background check information, judicial data or information on other judicial or administrative proceedings. This may also include an individual’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, or the contents of mail, email, and text messages unless we are the intended recipient of the communication. We may also collect other pieces of information of particularly sensitive nature, if you make such information publicly available in the context from which the Personal Information is collected, such as in your publicly available social media accounts, through a resume submitted to us, or by attending a professional event associated with an affinity group.
  • “Other Information” means any information that does not reveal your specific identity or does not directly relate to an identifiable individual, such as: browser and device data, App usage data, data collected through cookies, pixel tags and other technologies, demographic information and other data provided by you that does not reveal your specific identity, or other types of information that has been aggregated in a manner such that it no longer reveals your specific identity.

Information We Collect Automatically

As is true of many digital platforms, we also collect certain information about you automatically when you use our Services, as described below.

  • Usage Information. We collect information about your activity on our Services, which includes device identifiers (like IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information.
  • Transactional Information. When you receive, submit, or complete a transaction via the Services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.
  • Location Data. We may collect the GPS location of your mobile device in accordance with your device permissions. You can stop the collection of this precise location information at any time (see the Your Control section below for details).  
  • Information Collected Through Tracking Technologies. We and our service providers also use technologies, including cookies and web beacons, to automatically collect certain types of usage and device information when you use our Services or interact with our emails. The information collected through these technologies includes your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information and other similar information. For information about how to disable cookies, please see the Your Controls section below.

Information We Collect from Other Sources

We also obtain information about you from other sources as described below.

  • Vendors and Business Partners. We collect information about you from companies that we do business with, such as name, contact data, inferences about your preferences and attributes, as well as inferred fraud risk, from identity verification and fraud prevention partners.
  • Publicly Available Data. includes contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.
  • Advertising Data. We collect information in connection with our ad campaigns that surfaced on other platforms, such as the ads you clicked on and other interactions with our ads.
  • Data from other users. If you are in another user’s contact list and they choose to share that list with us, then we will collect the contact information and your association with that user.


Unless otherwise limited by the context in which it was collected, Personal Information collected by Neptune is used for our legitimate business purposes, including:

  • For improving the content of the Neptune Platform, for example, by incorporating information that is relevant to our clients;
  • For preventing fraud or other illegal activities, such as willful attacks on Neptune information technology systems or the Neptune Platform;
  • For data analysis, for example, to improve the efficiency of the Neptune Platform
  • For audits, to verify that our internal processes function as intended and address compliance with legal, regulatory or contractual requirements;
  • For developing new products and services;
  • For enhancing, improving, or modifying our current products and services;
  • For identifying usage trends, for example, understanding which parts of the Neptune Platform are of most interest to users;
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users;
  • For operating and expanding our business activities, for example, understanding which parts of the Neptune Platform are of most interest to our users so we can focus our energies on meeting our users’ interests.

Additionally, we use the information we collect for purposes described below or as otherwise described to you at the point of collection:

  • Maintain and provide the Services, including to process account applications, authenticate your identity, repair our Services, support, process and record transactional information, and handle billing and account management;
  • Send you transactional or relationship information, including confirmations, invoices, technical notices, customer support responses, software updates, security alerts, support and administrative messages, and information about your transactions;
  • Communicate with you about offers and other things we think you will be interested in, such as newsletters, product announcements, partner offerings, surveys, contests or sweepstakes, events or announcements;
  • Personalize our Services, such as by suggesting content or customizing content or ads we show you;
  • Monitor and improve our Services, including analyzing usage, research and development;
  • Help protect the safety and security of our Services, business, and users, such as to investigate and help prevent fraud or other unlawful activity;
  • Protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
  • Comply with applicable laws and legal obligations, such as compliance obligations associated with being a regulated broker-dealer and compliance obligations associated with being a money services business.
  • Market research,  we may collect or otherwise observe Personal Information from individuals in the market research context, including Individual Identifiers, Inferences, Employment Records, Education information, Geolocation Data, Audio, electronic, visual, or similar information, Professional and Employment Related Information, Protected Class Information, and Sensitive Information Protected under Law.


We are committed to maintaining your trust, and we want you to understand when and with whom we share information about you. We share information about you in the instances described below.

  • Authorized third-party vendors and service providers. We share information about you with third-party vendors and service providers who perform services for us, such as identification verification, fraud prevention, advertising, mailing services, tax and accounting services, contest fulfillment, web hosting, and analytics services. We use an identification verification service provider to determine whether a selfie you take matches the photo in your government-issued identification. With your consent, we may record your voice and send this data to our third-party partner to authenticate you and to help prevent fraud. The information collected from your photo and your voice by our third-party vendors may include biometric data.
  • Companies in which you hold securities. Neptune may provide your name, address, email address, and securities positions to requesting companies in which you hold securities.
  • Substantial corporate transactions. We may share information about you in connection with a substantial corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding.
  • Legal purposes. We disclose information about you if we believe that disclosure is in accordance with, or required by, any applicable law or legal process or to protect and defend the rights, interests, safety, and security of Neptune, our users, or the public.
  • With your consent. We share information about you for any other purposes disclosed to you with your consent.

We share information with others in an aggregated or otherwise de-identified form that does not reasonably identify you.


We use third-party advertising and analytics services to better understand your online activity and serve you targeted advertisements. Third-party companies collect information about your use of our Services and other websites and online services over time through cookies, device identifiers, or other tracking technologies. The information collected includes your IP address, web browser, mobile network information, pages viewed, time spent, links clicked, and conversion information. We and our third-party partners use this information to, among other things, analyze and track data, determine the popularity of content, and deliver advertisements targeted to your interests on our Services and other platforms, as well as to provide advertising-related services to us such as reporting, attribution, analytics, and market research.


Personal Information. Personal information may be accessed, changed/corrected, or deleted directly by through the context it was collected. For example, Personal Information collected in the Products and Services context can be accessed, changed, or deleted through the features and functionality of the Products and Services, and Personal Information collected in the Interactions with Job Applicants context may be accessed, changed, or deleted through the job application tools. In the event, however, you cannot access, change/correct, or delete Personal Information through the context in which it was collected, or if you would like to restrict the use of your Personal Information, object to the processing of your Personal information or request to receive an electronic copy of your Personal Information for purposes of transmitting it to another Neptune (to the extent this right to data portability is provided to you by applicable law), you may contact us at write to us at the address at the end of this document, or via our Site Feedback form. We will respond to your request consistent with applicable law.

In your request, please make clear what Personal Information you would like to have changed, whether you would like to have your Personal Information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your Personal Information. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to respond to your request as soon as reasonably practicable. We may exempt certain Personal Information from requests pursuant to applicable data protection laws or other laws and regulations.

Account profile.  You can update certain account profile information by logging into your account. For example, you may choose to upload a photograph of yourself, but are not required to in order to use our services. You may also choose to update your username.  

Access to your device data.  You may disconnect our mobile app’s access to certain stored device information through your device’s settings. For instance, you can withdraw permission for the app to access your contact list or photo gallery.

How to control your communications preferences.  You can stop receiving promotional emails from us by clicking the “unsubscribe” link in those emails. We may still send you service-related or other non-promotional communications, such as account notifications, receipts, security notices and other transactional or relationship messages.

Disabling certain data sharing.  You can limit how we share your data with our marketing partners to market our Services more effectively to you across sites and apps. When disabled, we will no longer share personal information with these partners for these purposes.

Cookie controls.  Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject these technologies. If you choose to delete or reject these technologies, this could affect certain features of our Services. If you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.


This section provides additional details about the personal information we collect about California and Virginia residents and the rights afforded to them under the California Consumer Privacy Act (“CCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”). Please note that the CCPA does not apply to what is referred to as nonpublic personal information collected by financial institutions (like Neptune), as that information is subject instead to other financial privacy laws. Additionally, the VCDPA does not apply to any Neptune entities that are financial institutions. As a result, the CCPA and VCDPA do not apply to most of the information that Neptune collects.

Subject to certain limitations and exceptions, the CCPA and VCDPA provide California and Virginia residents, respectively, with certain rights. Depending on the state in which you are a resident, you may have the right to:

  • Confirm whether Neptune processes your personal information;
  • Correct inaccurate personal information;
  • Request details (in a readily usable format) about the categories and specific elements of personal information we collect;
  • Delete your personal information;
  • Opt out of any sales, sharing, targeted advertising, or profiling for certain decisions (as these terms are defined in the CCPA and/or VCDPA); and
  • Not be discriminated against for exercising these rights.

We collect the following categories of personal information: identifiers (such as name, email address and IP address), Internet or other electronic network activity information (such as engagement with promotional messages and ads), and inferences (such as gender, based on your first name). For California residents, the preceding list reflects Neptune’s processing in the past 12 months.  

California and Virginia residents may make a request to exercise rights under the CCPA and VCDPA, respectively, that are not otherwise exempt under applicable law. If you are a Neptune app user, a request may be made by logging into your Neptune account, navigating to the Security and Privacy menu, and selecting the option to either Download Personal Data or Request Data Deletion. You may also request assistance by sending an email to We may verify the request by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly. If you are a Virginia resident and Neptune is unable to satisfy your request to exercise a right available to you under the VCDPA, you are entitled to appeal our decision by emailing


We do not knowingly collect or solicit any information from anyone under the age of 18 on these Services. In the event we learn that we have inadvertently collected personal information from a child under age 18, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 18, please contact us at to


Our Services are currently designed for use only in the United States. If you are using our Services from another jurisdiction, your information may be processed in the United States or other countries that may not provide levels of data protection that are equivalent to those of your home jurisdiction.


This Privacy Policy will evolve with time, and when we update it, we will revise the “Effective Date” above and post the new Policy and, in some cases, we provide additional notice (such as adding a statement to our website or sending you a notification). To stay informed of our privacy practices, we recommend you review the Policy on a regular basis as you continue to use our Services.


If you have any questions or comments about this Privacy Policy or would like to request information required to be disclosed under global privacy laws, please send us your questions and feedback., please contact us at