Privacy Policy

1. Responsibilities

By using our Service You agree to the Terms of Service and this Privacy Policy.

Your responsibility under the Agreement between You and us is to carefully examine this Privacy Policy and provide the correct data about Yourself.

Our responsibility is to provide You with the most clear and up-to-date information on how we process Your data.

2. When do We Collect Your Data

We start collecting Your personal data when You start using our Service or our website. We collect it for the purpose of being able to provide You with our Service and for other purposes as indicated in the Section 3 below.

3. Data We Collect, Purposes, Legal Basis and Retention Terms

Depending on how You decide to Use the Service or whether Your subscribe or not, we may use the following data about You in accordance with the description below:

Whether the provision of personal data is required to comply with a legal obligation or conclude/perform a contract, but You do not provide us with the required information, we have the right to refuse providing the corresponding Service, entering into a contract or perform a contract without any negative legal consequences.

4. Recipients and Sources of Your Data

To effectively run our Service, we must partner with third parties and, therefore, we may exchange Your data with:

• Payment account and similar services providers (banks, card issuers, etc. - "Partners");
• Third parties and service You choose to use in connection with the Service (for example, e-commerce sites through which You use our Service, or “merchants”);
• Our trusted data aggregation partners (licensed open banking platforms);
• Our group companies;
• Our services providers like accounting, auditors, data storage and processing services, online communication and collaboration services providers, legal services providers, AML and sanctions screening services providers, anti-fraud monitoring services, corporate data databases, accounting services providers, developers and testers, marketing services providers, social media, e-commerce platforms and others.
• Regulators, supervisory authorities, courts and other authorized public or similar bodies (like ombudsmen, financial regulators, gambling regulators).

We also receive your personal data from:

• You or your employer;
• Merchants;
• E-commerce platform, social media and search engines;
• Regulators, supervisory authorities, courts and other authorized public or similar bodies (like ombudsmen, financial regulators, gambling regulators);
• AML and sanctions screening services providers, anti-fraud monitoring services;
• Event organizers (such as conferences, seminars and other);
• Professional associations;
• Public registers and compliance services providers.

5. International Transfers of Your Personal Data

Where Noda transfers Your personal data outside of the EU or EEA, we rely on the guarantees provided by the applicable legal acts, for example, as the EU General Data Protection Regulation (GDPR) provides: the adequacy decisions of the European Commission (Article 45 of the GDPR), standard contractual clauses and other safeguards provided by Articles 46 and 49 of the GDPR. If personal data is transferred to the US, Noda may rely on the corresponding personal data transfer framework in force. In certain cases, depending on the involved Noda entity, Noda might also rely on the UK International Data Transfer Addendum to the EU Commission Standard Contractual Clauses.

6. Your Rights

You have the following rights with regards to Your personal data:

• The right to know what kind of data we collect about You and how do we process it. You can also read how we use Your personal data in the Section 3.
• The right to request certain data to be erased. Please note that upon such a request we might not be further able to provide You with the Service (fully or partially).
• Restrict processing of Your data, object to the processing of Your personal data and withdraw consent, where applicable without affecting the lawfulness of processing based on consent before its withdrawal.
• The right not to provide any personal data to Us. In this case, we might not be able to provide our Service to You, fully or partially.

If You are unhappy with how we process Your personal data, You can always submit a complaint to use by writing to support@noda.live. If You consider that we are unable to handle Your request in accordance with the applicable law, You can lodge a complaint with a relevant supervisory authority. If You are located in the EU, the list of the supervisory authorities is accessible here.

7. Contact Details

If you have any questions, comments or complaints on how we use Your data, please send them to dpo@noda.live.

There can be other controllers of your personal data described in this Privacy Policy, except for NAUDAPAY LIMITED.

For more information, please contact us at dpo@noda.live.