Noba Privacy Notice
Scope and Consent
This Privacy Notice (“Notice”) describes the ways Noba Technologies, Inc. (“Noba”, “we”, “our,” “us”) collects, stores, uses and protects 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. For California residents, please review our California Consumer Privacy Act Notice.
We may process information from the following users, defined as follows:
- Visitors of our Sites; and
- Consumers who use our Services to purchase cryptocurrency assets
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.
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)
During the user onboarding process, we may collect the following information. The elements we collect depend on our compliance and risk requirements and your risk profile.
- Full name
- Email address
- Physical address
- Phone number
- Date of birth
- Social security number or tax ID number if a U.S. resident
- Government-issued identification document if a non-U.S. resident, or if specifically requested from a U.S. resident
- Selfie photo and/or liveness check, if specifically requested
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, including those applicable to financial services institutions and/or our third-party service providers which require such information. We may also obtain information about our users from third parties that provide identity verification and fraud prevention services.
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.
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 business and to 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 filed with us and the handling of any complaints;
- Comply with applicable laws and regulations;
- Establish, exercise and defend legal claims;
- Monitor and report compliance issues;
- To approach you via email for marketing purposes, we request your consent, unless it 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 verify it with third parties and protect against, identify and prevent fraud and other prohibited or illegal activity, claims and other liabilities;
- Enforce our contractual terms.
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 five years or more after an account has been closed or become dormant.
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 that provide exchange and settlement services; cloud service providers that provide cloud infrastructure; providers of identity verification and other compliance solutions; and providers of customer service 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 Service.
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.
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 firstname.lastname@example.org. However, you may still receive other communications from us as permitted or required by law.
California Consumer Privacy Act Addendum
UPDATED SEPTEMBER 9, 2022
At Noba (“Noba”, “we”, “us”, “our”), we take our responsibilities under the California Consumer Privacy Act (“CCPA”) seriously. If you are a California resident, the following provisions apply to our processing of information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household subject to the CCPA. For such residents, the provisions of this CCPA Addendum prevail over any conflicting provisions in our Noba Privacy Notice.
California Personal Information We Collect
We have collected the following categories of California Personal Information within the last 12 months:
For each of these categories, we obtain California Personal Information from a variety of sources. These sources include: yourself, with respect to both online and offline interactions you may have with us or our service providers; other entities with whom you transact; others with whom you maintain relationships who may deal with us on your behalf; the devices you use to access our websites, mobile applications, and online services; identity verification and fraud prevention services; marketing and analytics providers; public databases; social media platforms; and others consistent with this CCPA Addendum. For more information, please see the “Why We Collect Personal Information” section of our Privacy Notice.
For each of these categories, we share personal information with a variety of third parties. These third parties include: service providers; marketing and advertising providers; analytics providers; law enforcement, government officials, or other third parties pursuant to a subpoena, court order, or other applicable legal process or requirement; and our users in cases of suspected fraud or in connection with an ongoing investigation.
Sale and Disclosure of California Personal Information
We do not disclose personal information of individuals to third parties for monetary or other valuable consideration.
Use of California Personal Information
For each of the above categories, we use the California Personal Information we collect for the business purposes disclosed within this CCPA Addendum. Please note that the business purposes for which we may use your information include:
- Audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
- Detecting and protecting against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecuting the same;
- Debugging to identify and repair errors in our systems;Short-term, transient use including contextual customization of ads or website;
- Providing services on our behalf or on behalf of another, including maintaining or servicing accounts, providing customer service, fulfilling transactions, verifying identity information, processing payments, and other services;
- Conducting internal research to develop and demonstrate technology; and
- Conducting activity to verify, enhance, and maintain the quality or safety of services or devices which we may own, control, or provide.
We may also use the information we collect for our own or our service providers’ other operational purposes, purposes for which we provide you additional notice, or for purposes compatible with the context in which the California Personal Information was collected.
Your California Rights
If you are a California resident, you have certain rights related to your California Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. If you wish to submit a request under the CCPA, please do so by sending a request entitled “Data Subject Rights Request under CCPA” to email@example.com and indicate in the email the specific right(s) you are seeking to exercise.
Right to Access/Know. You have the right to request that we disclose to you:
- the categories of California Personal Information we have collected about you
- the categories of sources from which the California Personal Information is collected;
- our business or commercial purpose for collecting or selling California Personal Information;
- the categories of third parties with whom we share California Personal Information; and
- the specific pieces of information we have collected about you.
To the extent that we sell your California Personal Information within the meaning of the California Consumer Privacy Act or disclose such information for a business purpose, you may request that we disclose to you:
- the categories of California Personal Information that we have collected about you;
- the categories of California Personal Information about you that we have sold within the meaning of the California Consumer Privacy Act and the categories of third parties to whom the California Personal Information was sold, by category or categories of personal information for each third party to whom the California personal information was sold; and
- the categories of California Personal Information about you that we disclosed for a business purpose.
Right to Delete. You have the right to request that we delete California Personal Information about you which we have collected from you.
Right to Opt-Out and Right to Opt-In. You have the right to direct us to not sell your personal information at any time (the “right to opt-out”) by managing your cookie preferences in our Cookie Management Center.
Verification. As required under applicable law, we may take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide information to verify your identity in response to exercising requests of the above type, including name and account information. We may limit our response to your exercise of the above rights as permitted under applicable law.
Nondiscrimination. Subject to applicable law, we may not discriminate against you because of your exercise of any of the above rights, or any other rights under the California Consumer Privacy Act, including by:
- Denying you goods or services;
- Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
- Providing you a different level or quality of goods or services; or
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.
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.
You may contact us with questions or concerns about our Privacy Notice and privacy practices at firstname.lastname@example.org.
If you wish to submit a data subject rights request, you may do so by sending an email entitled “Data Subject Rights Request” to email@example.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.
What Are Cookies?
Cookies are a standard feature of websites that allow us to store small amounts of data on your computer about your visit to a website. Cookies help the website owner learn which areas of the website are useful and which areas need improvement. Cookies also improve your experience by, for example, remembering your preferences, such as your language preference or login information.
Some cookies are required for technical reasons in order for a website to operate, also known as "Strictly Necessary" cookies. Some cookies allow a website to count visits and traffic sources so the site owner can measure and improve the performance of the site, also known as “Analytics” cookies. Some cookies enable a website owner to serve targeted advertisements, also known as “Targeting” or “Marketing” cookies.
What Cookies Do We Use?
Our Site uses both first-party cookies (which are set by us) and third-party cookies (which are set by a server located outside the domain of our Site) for several reasons. The specific types of first-party and third-party cookies served through our Site and the purposes they perform are described in the tables below.
We do not use Targeting or Marketing cookies.
Strictly Necessary Cookies. These are cookies which make our Site function when you take certain actions, whether you are logging in, managing email preferences, or filling out forms. Since they are essential for our Site to function, we cannot turn them off. You can set your browser to block or alert you about these cookies, but as a result, parts of the Site will not work. These cookies do not store any personal data.
Analytics Cookies. These are cookies that are not required to make our Site function but are critical to help us understand and enhance the quality and performance of our Site based on our users’ navigation throughout the Site (also known as “telemetry information”). Since these cookies are not essential for our Site to function, users can turn them off in our Cookie Management Center or by setting your browser to block or alert you about these cookies. These cookies are configured to collect and store your browser version and IP address.
How Do I Manage Cookies?
You can choose whether to accept our cookies (except Strictly Necessary Cookies) by clicking on the appropriate opt-out button in our Cookie Management Center, which can be found in our Site’s footer and our Manage Cookies pop-up, or by blocking cookies at any time by activating settings on your browser. You may wish to refer to this article for information on commonly used browsers. Note that blocking our Strictly Necessary Cookies will impact your experience on our Site and the services we are able to offer you.