‍Scope and Consent
‍This Privacy Notice (“Notice”) describes the ways Noba Technologies, Inc. (“Noba”, “we”, “our,” “us”) and its subsidiaries collect, store, use and protect information. Noba’s services include websites, mobile applications, products, and any other features, technologies or functionalities, including customer support (“Services”) offered by us. This Notice applies to www.noba.com and all other Noba sites on which it appears (the “Sites”).

Our privacy practices may vary among the countries or territories in which we operate to reflect local practices and legal requirements.

We may process information from the following users, defined as follows:

1. Visitors of our Sites; and
2. Consumers who use our Services

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What kind of information do we collect?
‍We collect different kinds of information when users interact with us.  The information we collect depends on the type of user.  We collect information you choose to provide to us when interacting with our Services.  We may also collect information automatically from your devices. The following sections provide you with some more information.

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‍1.  Visitors of Our Sites
‍We may collect the following information relating to visitors of our Sites:

• Technical information, including IP address; the type of browser, devices and operating systems you use; identifiers associated with the device(s) you use to access our Sites; the pages on our Site that you visit and the features you use; access dates and times; and if you navigated from or navigate to another website, the address of that website; and information regarding your internet service provider
• Email address (e.g., if you join our waitlist, subscribe to our blog, opt in to receive other marketing materials, or submit a support request)
• First name (e.g., if you submit a support request - full name is optional)

We may also collect information about a visitor’s computer or other access devices for purposes including fraud prevention. The information we collect may be collected automatically using cookies or other similar technologies. For more information about our use of cookies, please see our Cookie Policy.
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‍2. Users
‍During the user onboarding process, we collect the following information:

• Full legal name
• Email address
• Phone number
• Date of birth
• Country of residence

In addition, we may collect the following information depending on our compliance and risk requirements and your risk profile.

• Physical address
• Government-issued identification document
• Selfie photo and/or liveness check

We use this information for risk management purposes (i.e. to verify a user’s identity and prevent fraud) and to comply with laws and regulations. We may also obtain information about our users from third parties that provide identity verification and fraud prevention services.

Further, you have the option to allow us access to your contact list to facilitate peer-to-peer transfers between users of the Noba App. This occurs in-app with your consent. Access to your contact list may be revoked at any time via your device settings. You also have the option to activate biometric login (i.e., FaceID or fingerprint) via your phone when using the Noba App. This occurs in-app with your consent. Biometric login may be turned off at any time via your Noba App settings.

‍3.  Additional Collection
‍Noba may collect additional information in connection with its efforts to combat fraud, illegal activity, or comply with laws and regulations. Additionally, Noba may collect information regarding the effectiveness of our email and other communications. For example, we may know if you follow a link in an email we send to you. We may also obtain information about you from other third parties, such as information about your use of this Site or our Services. We may also collect information about former, existing and prospective vendors and customers (“Partners”). This includes limited personal information about employees and agents of such Partners (“Partner Employees”) at the beginning and throughout the course of the Partner relationships, such as professional contact information.

‍How we use cookies
‍We may collect information about your activities on our sites via first-party or third-party cookies or through other identifiers or technologies, including similar technologies as they may evolve over time. We refer to these technologies collectively as cookies. The information collected by cookies may be shared with and used by us, by others acting on our behalf, or by third parties subject to their own privacy policies. For more information about our use of cookies, please see our Cookie Policy.

‍Why we collect personal information
‍We use the information we collect to operate our business, provide our Services, for other purposes as permitted or required by law, and to provide you with a smooth, efficient, and customized experience. Specifically, we may use your information to:

• Provide our Services (including customer support);
• Process transactions and send notices about your transactions;
• Resolve disputes, collect fees, and troubleshoot problems;
• Communicate with you about our Services and inform you of matters that are important for your Account and/or use of the Sites.  We also use your personal data to respond to any questions, comments or requests you may file with us and to handle any complaints;
• Comply with applicable laws and regulations;
• Establish, exercise and defend legal claims;
• Monitor and report compliance issues;
• Approach you via email for marketing purposes if we obtained your consent (unless consent is not required by law). You always have the option to unsubscribe from our mailings, e.g., via the unsubscribe link in our newsletter;
• Perform risk management, including comparing information for accuracy and verifying it with third parties and protecting against, identifying and preventing fraud and other prohibited or illegal activity, claims and other liabilities;
• Enforce our contractual terms.

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‍How we protect and store personal information
‍We take the security of our information seriously. We use administrative, technical, and physical security designed to safeguard personal information in our possession, and we maintain internal policies and procedures to address our data security. However, we cannot guarantee the security of the information that we collect and store. We will notify relevant authorities and users in the event of a data breach, if required under applicable law.

We retain data as required or permitted by law. For example, we retain users’ identification and account information for seven years or more after an account has been closed or become dormant.
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‍How we share data with third parties
‍We may disclose the information we gather with our affiliates and third parties. For example, we may share information with:

• Service providers that help with our operations and enable us to deliver our Services, such as regulated financial institutions; cloud service providers; providers of identity verification and other compliance solutions; and providers of customer support solutions.
• Law enforcement, government officials, regulatory agencies, banks, and other third parties pursuant to a subpoena, court order or other legal process or requirement, if applicable to Noba; or when we believe, in our sole discretion, that the disclosure of information is necessary to report suspected illegal or fraudulent activity or to investigate violations of our Terms of Use.

Please note that these third parties may be in countries where the laws on processing information may be less stringent than in your country. Transfers of your data may be subject to additional legal protections we have put in place.  

‍Your Choices
‍You can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited. You may control how your browser accepts cookies. For more information, please consult your browser’s help documentation.

You may also manage your cookie preferences using our Cookie Management Center.  For more information about our use of cookies, please see our Cookie Policy.

As of the last updated date of this Notice, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personally identifiable information regarding your online activities over time and across third-party web sites or online services.

If you do not wish to receive marketing communications from us, you can click the “unsubscribe” link usually found at the bottom of the e-mail, or you can send a request to support@noba.com. However, you may still receive other communications from us as permitted or required by law.  

‍Changes to this Notice
‍We may amend this Notice at any time by posting a revised version on our website. The revised version will be effective at the time we post it. You are responsible for periodically reviewing this Notice.

‍Contact Information
You may contact us with questions or concerns about our Privacy Notice and privacy practices at support@noba.com.  

If you wish to submit a data subject rights request, you may do so by sending an email entitled “Data Subject Rights Request” to support@noba.com. In the email, please indicate the specific right(s) you are seeking to exercise and the applicable data privacy law or regulation upon which you are relying to exercise your rights.

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