Neobank Capital — Acceptable Use Policy (AUP)

Effective Date: 18 september 2023

Issued by: Neobank Capital

Approved by: Chief Information Security Officer (CISO) & Legal Team

1. Purpose

The purpose of this Acceptable Use Policy (AUP) is to define the rules and guidelines for using Neobank Capital’s technology systems, digital platforms, applications, and online services.

The AUP ensures that all users:

1. Use resources responsibly, securely, and ethically.
2. Protect personal, financial, and company data.
3. Comply with applicable laws, regulations, and internal policies.

2. Scope

This policy applies to:

1. All employees, contractors, consultants, and temporary staff.
2. Customers and users of Neobank Capital’s websites, mobile applications, APIs, and online services.
3. All information systems, devices, networks, cloud environments, and endpoints operated by or on behalf of Neobank Capital.

3. General Acceptable Use

Users must:

1. Use systems only for authorized purposes related to Neobank Capital’s business or legitimate personal use where applicable.
2. Protect login credentials, authentication tokens, and private keys. Sharing accounts is strictly prohibited.
3. Access only data and systems for which they are authorized.
4. Comply with applicable laws including GDPR, UK GDPR, anti-money laundering (AML), and financial regulations.
5. Report security incidents immediately to the Security Team or DPO.
6. Use company-issued devices or approved secure platforms for accessing Neobank Capital services.

4. Prohibited Activities

Users are strictly prohibited from:

4.1 Unauthorized Access

1. Attempting to access systems, data, or accounts without permission.
2. Circumventing security controls, firewalls, or authentication mechanisms.

4.2 Malicious Activities

1. Deploying malware, ransomware, spyware, or other harmful code.
2. Interfering with services, networks, or platforms (e.g., DoS/DDoS attacks).
3. Exploiting system vulnerabilities or attempting penetration testing without prior authorization.

4.3 Data Misuse

1. Accessing, copying, modifying, or sharing personal or financial data for unauthorized purposes.
2. Removing or bypassing data protection, encryption, or masking measures.
3. Using data to engage in fraud, money laundering, or illegal activity.

4.4 Content and Communication Misuse

1. Sending phishing emails, spam, or other unsolicited communications.
2. Publishing content that is illegal, offensive, or violates copyright.
3. Impersonating Neobank Capital, employees, or partners online.

4.5 Resource Abuse

1. Using Neobank Capital’s systems for high-volume cryptocurrency mining, personal profit, or unrelated heavy computation.
2. Consuming excessive bandwidth, storage, or computing resources without authorization.

5. Customer-Specific Use

Customers must:

1. Comply with terms of service, privacy policy, and applicable laws.
2. Use Neobank Capital services only for lawful financial transactions.
3. Protect login credentials, wallet keys, and API keys.
4. Report any suspected compromise immediately.

6. Security Requirements

1. Enable Multi-Factor Authentication (MFA) on all accounts.
2. Use strong, unique passwords and rotate credentials regularly.
3. Maintain up-to-date antivirus, anti-malware, and OS/firmware security patches.
4. Store sensitive financial or personal information only in encrypted formats approved by Neobank Capital.

7. Enforcement

1. Violations of this AUP may result in:
2. Suspension or termination of accounts or access.
3. Employment or contractor disciplinary action, up to termination.
4. Legal action for criminal or civil violations.
5. Neobank Capital reserves the right to monitor system usage to ensure compliance with this policy, consistent with applicable laws.

8. Reporting and Incident Response

1. Users must report any suspected misuse, breach, or security incident immediately.
2. Reports should be submitted to:
3. Security Team: security@neobank.capital
4. Data Protection Officer (DPO): privacy@neobank.capital
5. Neobank Capital will investigate and take appropriate corrective action.

9. Policy Review and Updates

1. This policy is reviewed annually or sooner if:
2. Regulatory requirements change.
3. New security risks or technologies emerge.
4. Organizational or operational changes occur.
5. Updates must be approved by the CISO and Legal Team.

10. Acknowledgment

1. All employees, contractors, and customers are deemed to have read, understood, and agreed to this policy by accessing Neobank Capital systems or services.
2. Formal acknowledgment may be required for internal staff as part of onboarding.

Contact Information

Data Protection Officer (DPO)

📧 privacy@neobank.capital

Chief Information Security Officer (CISO)

📧 security@neobank.capital