Privacy Policy for NeoNomad Xchange (Pty) Ltd

Effective Date: 2022

Introduction

Welcome to the Privacy Policy of NeoNomad ("we," "us," or "our"). The protection of your privacy and the security of your personal information are of utmost importance to us. This Privacy Policy explains how we collect, use, disclose, and safeguard your personal information when you interact with our website, mobile application, or any other services we offer (collectively referred to as the "Services"). By accessing or using our Services, you acknowledge your consent to the practices described in this Privacy Policy.

This Privacy Policy is an integral part of our Terms of Service, governing the provision of our services by NeoNomad (Pty) Ltd ("NeoNomad") to you. To fully comprehend your rights and obligations, we encourage you to familiarize yourself with the Terms of Service. 

Please note that this Privacy Policy is subject to occasional updates, and it is your responsibility to stay informed about any changes. It is important to note that this Privacy Policy does not apply to the information practices of third-party companies that NeoNomad may engage with in relation to its business operations. These third-party entities, including their websites, platforms, or applications, have their own privacy policies and terms and conditions, which we encourage you to review before utilizing their services. Additionally, this policy does not cover individuals unrelated to NeoNomad who are neither managed nor employed by us. 

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information. If you do not agree with our practices, please do not use our Services.

Information We Collect

We may collect several types of information from you, including:

1. Personal Information: This may include your name, email address, phone number, and other identifying information necessary to create and manage your account.
2. Financial Information: We may collect financial information such as bank account details, credit card information, or cryptocurrency wallet addresses when necessary for the provision of our Services.
3. Transaction Information: We may collect information related to your cryptocurrency transactions, including transaction history, wallet addresses, and amounts involved.
4. Usage Information: We may collect information about how you use our Services, such as your IP address, browser type, device information, and browsing history.
5. Cookies and Tracking Technologies: We use cookies and similar tracking technologies to collect information about your interactions with our Services. You can control cookies through your browser settings.

How We Use Your Information

We collect and use the information we gather for various purposes, including:

1. Providing and Improving Services: We utilize your information to deliver, enhance, and secure our Services, which includes customer support and ensuring safety.
2. Account Management: Your personal and financial details are used for managing your account, processing transactions, and verifying your identity.
3. Communication: We may reach out to you using your provided contact information for important updates, newsletters, service-related notifications, and marketing materials. You have the choice to opt out of receiving marketing communications at any time.
4. Legal Compliance: Your information may be employed to fulfil legal obligations, such as adhering to anti-money laundering (AML) and know-your-customer (KYC) requirements.
5. Cookies: We and our third-party service providers make use of several types of cookies, including functional and analytical cookies, to collect Personal Information. Functional cookies are essential for the core functionality of our Services, while analytical cookies assist us in improving and enhancing our Services through website analytics. Our Services may also include content from third parties, like social media features, which might collect Personal Information. To learn more about managing cookies and opting out of certain data collection practices, please refer to the "Your Rights and Choices" section below.
6. Electronic Marketing: We may, from time to time, send you information about our products, services, news, and promotions or otherwise communicate with you for marketing purposes. These communications may be delivered through email, push or in-app notifications, text messages, or other means. We will ensure that all marketing communications are carried out in accordance with applicable laws, including obtaining consent or providing opt-out options.
   1. You have the right to opt out of receiving marketing communications at any point in time. To do so, you can simply click on the "Unsubscribe" option that is included in every marketing communication sent to you. Additionally, you can manage your communication preferences by adjusting the settings in your account through our app or website.
   2. Please note that by unsubscribing from marketing content, you will still receive important communications related to the security or operation of your account or the services provided by NeoNomad.
7. Other Business Purposes: In addition to the previously mentioned purposes, we also utilize Personal Information for various business-related activities to ensure compliance, manage risks, and uphold regulatory requirements. These purposes include but are not limited to conducting audits, maintaining security measures, complying with applicable laws and regulations, monitoring for fraud, and preventing unauthorized activities.
8. Apart from the situations described in this Privacy Policy, we will not disclose your Personal Information collected on our Services to third parties without obtaining your consent. However, there are specific circumstances in which we may disclose information:
   1. Your social handle and profile information may be publicly available through the Services.
   2. We may disclose information to third-party service providers who assist in services such as website hosting, data analysis, IT infrastructure, customer service, email delivery, auditing, and other related functions.
   3. If there is a reorganization, merger, sale, joint venture, assignment, transfer, or any disposition of our business, assets, or stock, we may disclose information to potential or actual acquirers, successors, or assignee's.
   4. Disclosure may be required by law or in good faith belief that it is necessary, including complying with legal processes, responding to requests from public or government authorities, enforcing our Terms of Use, protecting our rights, privacy, safety, and property, or allowing us to pursue available remedies.
   5. We reserve the right to use and disclose aggregated or de-identified information for any purpose unless prohibited by applicable law.

Sharing and Disclosure

We prioritize the privacy and confidentiality of your personal data. However, there are specific circumstances in which we may share your information with third parties, as explained below:

1. Service Providers: We may share your information with trusted service providers who support us in delivering and improving our services.
2. Internal Sharing: Your information may be accessible to individuals employed by our organization, ensuring the proper delivery of our services.
3. Legal Compliance: We may disclose your information to comply with legal requirements, respond to legal requests, or safeguard our rights and interests.
4. Business Transactions: Should a merger, acquisition, or asset sale occur, your information may be transferred to the involved entity.
5. Financial and Other Institutions: We may share your information with partnered institutions to process authorized payments and facilitate the provision of our products and services.
6. Third-Party Cryptocurrency Service Providers: When you send cryptocurrency over the blockchain, your information may be shared with third-party cryptocurrency service providers for transaction screening and processing purposes.

Please rest assured that we commit to maintaining the privacy and confidentiality of your personal data. We will not share it with other entities unless:

1. You have provided explicit permission to do so.
2. It is necessary to comply with applicable laws, regulations, legal processes, or governmental requests. This includes meeting tax obligations, adhering to anti-money laundering reporting requirements, responding to law enforcement requests, or enforcing our Terms of Use and other agreements. Furthermore, sharing information may occur to protect our rights, property, or the safety of ourselves, our customers, or others.
3. There is a requirement to transfer rights and obligations as specified within our agreement with you.

Security

At NeoNomad, we prioritize the security of your personal data. We continuously assess and implement appropriate technical and organizational measures to safeguard your information. Our team members receive comprehensive training on handling personal data securely and responsibly. While we take necessary precautions to protect your data, we cannot guarantee absolute security. It is crucial that you take responsibility for securing your NeoNomad account login credentials and comply with the guidelines outlined in NeoNomad's Terms of Use.

Your Rights and Choices

NeoNomad collects and uses data necessary to provide and improve our services, as well as to fulfil our obligations. However, depending on your location, you may have certain rights regarding your personal data. These rights include:

1. Access and Correction: You can access and update your personal information through your account settings.
2. Data Portability:  Requesting a copy of the personal data we hold about you.
3. Asking for the transfer of your personal data to yourself or a third party in a structured, commonly used, and machine-readable format.
4. Objecting to the processing of your personal data, including for marketing purposes.
5. Opting out of sharing your personal data with our affiliates or third parties for specific purposes outlined in this policy or for marketing their products and services to you.
6. Deletion: Requesting that we correct, delete, or restrict the processing of your personal data, subject to legal obligations. 

These rights are granted to you in accordance with relevant privacy laws, such as the Protection of Personal Information Act (POPIA) in South Africa, which we comply with. To exercise any of these rights without discrimination, please submit a support ticket. Please note that there may be limitations on these rights based on specific circumstances. This could be due to legitimate reasons for processing your personal data, such as legal obligations or legitimate interests on our part, or because these rights do not apply to the personal data, we hold about you.

In our commitment to transparency and compliance, we would like to inform you that we and third parties, like Google, utilize various tracking technologies, including cookies, to collect information about your browsing activities and device data. You have multiple options to manage data collection, such as adjusting your browser settings to block cookies, using privacy-oriented browser plugins, or utilizing platform-specific opt-out tools like Google's Ads Settings.

While we do not sell personal information for monetary gain, we do use third-party cookies for advertising purposes. To understand how to opt out of our use of cookies and tracking technologies, please refer to the instructions provided in this section of our Privacy Policy.

We respect and value your privacy rights, and we assure you that there will be no discrimination against you for exercising these rights.

Data Retention Period

NeoNomad will retain your personal data, in accordance with this Privacy Policy and the Terms of Use, for as long as your relationship with us continues. Additionally, we may retain your data for a duration necessary to fulfil our legitimate business purposes, such as complying with legal obligations, preventing fraud, resolving disputes, enforcing agreements, and safeguarding the interests of NeoNomad and its customers. We will also retain your data as required by applicable laws and regulations. By using our services, you agree to the retention of your personal data by NeoNomad, as outlined in this Privacy Policy and the Terms of Use.

International Transfers of Your Personal Data

Given that NeoNomad operates globally to provide our products and services, it may be necessary to transfer, store, and process your personal data in countries outside of your own jurisdiction. Please be aware that the data protection laws of these countries may differ from those of your own country. For instance, data that is collected within your country may be transferred, stored, and processed in other countries.

By accepting this Privacy Policy and providing your personal data, you expressly consent to the transfer, storage, and processing of your personal data outside of your jurisdiction.

Data Breaches

In the event of a data breach, we will adhere to local law requirements by promptly notifying you and, if applicable, the relevant supervisory authority.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for legal and regulatory reasons. Any changes will be posted on this page, and the "Effective Date" at the beginning of the policy will be updated accordingly.

By continuing to use our Services after changes to the Privacy Policy become effective, you consent to the revised policy.

Consent

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to the collection, use, and disclosure of your personal information as described herein.

Contact Us

If you have any questions or concerns about our Privacy Policy or the handling of your personal information, please contact us Here.