Privacy policy
Nord Protocol Solutions LLC, a company incorporated under the laws of Saint Vincent and The Granadines (hereinafter referred to as “We”, “Us” and “Nord” and shall include any affiliates) understands the position We are providing the services through the interface/screen available on the mobile application called “NORDL” and through our web domain www.nordl.io (collectively referred to as “Platform”) and are committed to protecting the information and data shared by all of our users (hereinafter referred to as “You”, and “User”). The privacy mechanism outlined in this Privacy Policy, as amended from time to time, identify personal information (referred to as “Personal Information”) that may be collected, how such information is used, and the choices You have regarding our use of such information.
Please read this Privacy Policy carefully as by accessing or using the Platform, You agree to be bound by the terms described herein and all the terms incorporated by reference. Any information provided to Us is subject to this Privacy Policy. If You do not agree to any or all of the terms contained herein, do not use the Platform. Should You continue to access and use the Platform and provide your Personal Information, such act would constitute your consent to the terms contained herein. All capitalised terms shall have the meaning ascribed to them in the Terms and Conditions unless otherwise defined herein.
Personal Information
We do not knowingly collect Personal Information from children, and all information upload by a User shall be deemed to be uploaded in compliance of all applicable laws. While availing our services on the Platform You may provide Nord with certain Personal Information which are required for performance of the services on the Platform. Any data that is freely available to the public or made available to Nord through public sources or by way of right to information will not be considered as Personal Information.
Nord will take all reasonable measures to ensure that your Personal Information is not modified or used for any unauthorised purposes. Nord has implemented reasonable security practices and procedures that are commensurate with the information assets being protected and with the nature of our business. While We try our best to provide security that is commensurate with the industry standards, because of the inherent vulnerabilities of the internet, We cannot ensure or warrant complete security of all Personal Information that is being transmitted to Us by You.
When editing or deleting Personal Information shared by You at your request, We may ask you to verify your identity before We can act on your request. You have the right to access your Account with Nord and edit, modify or delete any Personal Information provided to Nord. However, We do not assure that We will delete all residual copies and archives made by any third party service providers for performance of their obligations.
During the course of provision of services or registration and creation of your Account, Wallet and undertaking transaction via Wallet the following Personal Information may be collected from the Users (collectively “Account Data”):
Name
Gender
Age
Nationality
Email address
Mobile number
Address (including country and ZIP/postal code)
KYC document including Government issued identity proof
Photograph (Live or Uploading)
Other details as Nord may deem necessary for provisioning services or required under applicable laws.
Nord may keep records of telephone calls received and made to their personnel for provision of the services or for making inquiries, orders, or other reasons for the purpose of administration of services. Nord may further keep records of all chats, conversations and information shared on the Platform by the User for the purpose of administration of the services.
During the use of the Platform via the internet, We may automatically receive technical information about your computer/device, including your IP address, your computer operating system, time-zone, browser type and browser plug-in details, due to the communication protocol settings on the Internet. When You browse our Platform, We may also collect information regarding the pages You viewed, the web addresses from which You arrive or click through to, time spent on certain pages, download errors and page response times. All these information help Us analyse user's trends and preferences, and thus assist us in improving our services.
Nord may include other optional requests for information from the Users with a view to customize the Platform to deliver personalized information to the User and for other purposes as mentioned in this Privacy Policy. Any such additional Personal Information will also be processed in accordance with this Privacy Policy.
Nord shall not be responsible in any manner for the authenticity of the Personal Information supplied by the User to Nord. If a User provides any Personal Information that is untrue, inaccurate, not current or incomplete (or becomes untrue, inaccurate, not current or incomplete), or Nord has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, Nord has the right to suspend or terminate your Account at its sole discretion.
Nord engages certain trusted third parties to perform functions and provide services, including, without limitation, facilitating payments, withdrawals and refunds, hosting and maintenance, API integration, data verification, and database storage and management. You hereby consent to your Personal Information to be shared with these third parties. Nord shall ensure that these third party who have been given such Personal Information shall only use the data for the specific purposes for which the Personal Information is provided and Personal Information is only shared pursuant to binding contractual obligations requiring such third parties to maintain the privacy and security of your Personal Information.
From time to time, Nord may also obtain your Personal Information from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms. Nord obtains Personal Information from third parties to comply with legal obligations, such as anti-money laundering laws.
User Consent
A prerequisite for obtaining access to the Platform and usage of the services provided on the Platform is the acceptance of this Privacy Policy. This Privacy Policy shall apply to all individuals that use the Platform. You grant your consent to be bound by the terms of this Privacy Policy by accessing the Platform or registering on the Platform in the manner as provided for in the Terms & Conditions (or) submitting any information to Nord while creating your Account, Wallet, KYC verification process, undertaking transactions through the Platform, or otherwise through electronic communication or other communication with Nord (or) using the features and services offered by Nord on the Platform.
As part of providing our services to You, We may need to send routine communications to You, such as order transaction emails and other administrative messages through email and notifications posted on the Platform or through other means available, including SMS and other forms of messaging. Though We prefer to communicate with the users via email and SMS, as may be deemed necessary, You agree to receive our phone calls or any other mode of communication as may be deemed appropriate.
When You register with the Platform or otherwise access the Platform You also consent to allowing Us to periodically send emails about information, which You may find interesting and in line with your interests. If You do not wish to receive promotional information from Us, You can, at any time, choose to opt out of receiving such promotional communications by following the process mentioned in the promotional communication.
You must ensure to provide Us with the correct or up-to-date information at the time of creation of your Account, Wallet and during the use of the Platform. This will allow Us to contact you for further correspondences with respect to the services provided on the Platform. We are not responsible for any inaccurate information You provide to Us, which may affect your experience when using the Platform and the services.
If, at any time, You want to access, update, modify or eliminate any information provided by You or which forms a part of the Account/Wallet created with Nord, You may do so by accessing your account and then changing your information as required (provided that change of certain information may require additional checks and processes). You may also withdraw your consent for use of your Personal Information provided and stop using the services for which consent is required. Nord reserves the right to stop providing any services to which consent has been withdrawn.
We may, in future, request other optional information from You in order to customise the Platform to deliver personalised service to our users.
Use of Personal Information
Nord collects and retains your Personal Information only to the extent that it is necessary to render our services to You and for regulatory purposes. Any Personal Information submitted by You on the Platform or collected by Us will be used only for the purposes mentioned below:
for registration of the User on the Platform.
for creating Wallet.
for facilitating transactions from the Wallet including Platform related services.
for completing KYC verification process, preventing fraud and complying with applicable laws including money laundering and anti-terrorist financing laws.
to carry out our obligations arising from your requests for Services on the Platform.
to comply with any filings, returns or statements required under applicable laws (including taxation laws).
to comply with any information requests made by any government, judicial or quasi-judicial authorities.
to improve the Platform's functionality, and to customise your future experience with Us.
to make sure that our Platform's Content is presented in the manner that is most effective for You.
to monitor and remove, where required, User Content posted or uploaded on the Platform.
to ensure that the transactions made on the Platform are made in the most efficient manner.
to deliver personalized information and target advertisements to the User.
for conducting research on efficient administrative practices on the Platform.
to communicate with You about any changes to our services.
to display details about your portfolio, transactions, trades and other features available on the platform through the mobile application called NORDL and the website at www.nordl.io operated by Nord Protocol Solutions LLC, which may be controlled by you in the manner provided therein.
Non-personally identifiable information, exclusively owned by Nord may be used in an aggregated or non-personally identifiable form for internal research, statistical analysis and business intelligence purposes including those for the purposes of determining the number of visitors and transactional details, and Nord may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates.
addressing grievances, complaints and queries raised by the Users and take appropriate action against the same.
maintaining back up as per our data retention policy.
ensuring that the provisions of the Terms & Conditions and Privacy Policy are complied with by all Users.
We may share information about You with your consent or at your direction.
International transfer of Personal Information
Nord may transfer your data outside of the relevant jurisdiction. Nord puts in place suitable technical, organizational and contractual safeguards (including Standard Contractual Clauses), to ensure that such transfer is carried out in compliance with applicable data protection rules, except where the country to which the data is transferred has already been determined by the European Commission to provide an adequate level of protection.
Disclosure of Personal Information
Nord in the course of performance of the services may need to disclose/ transfer certain Personal Information to third parties for the purposes mentioned in this Privacy Policy and the Terms & Conditions. The third parties to whom such information may be disclosed include:
Affiliates, subsidiaries, related party or member of group companies as may be necessary to achieve the purposes set out in clause 3 above and who may use and disclose your Personal Information for the same purposes as Us.
Service providers as may be necessary to achieve the purposes set out in clause 3 above.
Payment service providers such as payment gateways to facilitate transactions on the Platform.
In case of P2P transactions, some Personal Information may be shared with the counter party to such transaction to the extent We deem required, in our discretion, to resolve any dispute.
To our employees, agents, consultants and professional advisors for the purpose of ensuring provision of services on the Platform, subject to the fact that our employees, agents, consultants and professional advisors shall be bound by obligations of confidentiality.
To government institutions/ authorities to the extent required
under the laws, rules, and regulations and/ or under orders of any relevant judicial or quasi-judicial authority;
for the purposes of prevention, investigation and prosecution of cyber incidents;
for reporting any offences committed by User including suspicious transactions, fraud, money laundering;
to protect and defend the rights or property of Nord;
to fight fraud and credit risk;
to enforce Terms & Conditions (to which this Privacy Policy is also a part);
for verification of any information provided by Users; or
when Nord, in its sole discretion, deems it necessary in order to protect its rights or the rights of others.
To third party ad servers, ad agencies, technology vendors and research firms to serve advertisements to the User.
Where substantially all our assets are acquired by a third party, Personal Information may be one of the assets that is transferred or acquired by a third party. Under such circumstances, Nord would attempt to ensure that the third party acquiring Nord follows the provisions of this Privacy Policy and process your Personal Information as set forth in this Privacy Policy.
Duration for Retaining Personal Information
Under normal circumstances the Personal Information collected by Nord will only be retained for such periods of time as may be required for the provision of Services. We may retain the other information throughout your use of the Platform and for a period of five (5) years thereafter or such other period as may be prescribed by applicable laws. Confidentiality of such information shall be maintained during the period of retention.
Nord may be required to retain Personal Information in relation to the Users for records which may be required to be submitted to the appropriate authorities as and when required. Nord shall keep confidential all information retained for such record keeping purposes.
Upon deletion of Your Account, we shall retain Your information as per our AML Policy, for a minimum period of five (5) years or such other longer period as prescribed under law, to ensure compliance with our legal requirements, applicable laws and/or to comply with any requisition / requests from any legal, regulatory, statutory or other authority. Please also refer to AML Policy for more details.
Security Policy
Nord takes careful precaution to protect our Users' Personal Information from unauthorised access, improper use or disclosure or unauthorised modification. To prevent unauthorised access, We have put in place the latest industry-standard security technology and procedures to safeguard the Personal Information We collect online including technical, operational and physical security controls. Your Personal Information is encrypted and is protected with the most secure encryption software, which encrypts all information You input. We store your Personal Information on the computer servers placed in a secure environment. Nord also ensures that all third party service providers to whom Personal Information is provided take similar precautions with the information. Even though We have taken significant steps to protect your Personal Information, We, including the Platform cannot fully eliminate security risks associated with Personal information. We further disclaim any responsibility for any intercepted information sent via the internet, and You hereby release Us from any and all claims arising out of or related to the use of intercepted information in any unauthorized manner.
We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information. Our security procedures mean that We may ask you to verify your identity to protect you against unauthorised access to your account password. We recommend using a unique password for your Nord account that is not utilized for other online accounts and to sign off when you finish using a shared computer.u
Third Party Links
The links to third-party advertisements, third party websites or any third party electronic communication services (referred to as “Third Party Links”) may be provided on the Platform which are operated by third parties and are not controlled by, or affiliated to, or associated with Nord unless expressly specified on the Platform. If you access any such Third Party Links, We request You review the website's privacy policy. We are not responsible for the policies or practices of Third Party Links.
Cookies
Our Platforms use cookies and tracking technology (including pixels) depending on the features offered. Cookies are small files that are placed on your device (either temporarily or until manually deleted by you) in order to distinguish you from other Users of our Online Platforms. We also use local storage to provide you with a customised experience when you browse our Online Platforms and to improve advertising. This also allows us to improve the Online Platforms and our Services. Third parties may also use such cookies and tracking technology if you interact with any content provided by them through our Online Platforms, however we endeavour to identify these cookies before they are used and allow you to accept or deny them.
Limited personal data may be collected through the cookies and tracking technology, including but not limited to transaction information and other generic information such as number of visitors, device information, etc. Further, if any personal data has been previously provided, cookies may be tied to such information. Cookie and tracking information collected by us may be shared with third-parties which directly support our advertising/promotional activities and are involved in development/updating of our Online Platforms.
Amendment and Updates
We reserve the right to amend this Privacy Policy from time to time to ensure that this Privacy Policy is consistent with any developments on Nord. We will make available the updated Privacy Policy on the Online Platforms. You are encouraged to visit the Online Platforms from time to time to ensure that you are well informed of our latest policies in relation to personal data protection. All communications, transactions and dealings with us shall be subject to the latest version of this Privacy Policy in force at the time.
This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us. We may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated.
Grievance Officer
If You have any compliant or grievances or concerns with respect to Platform or this Privacy Policy, please inform such matters to the designated Grievance Officer through electronic mail at contact@nordl.io
