Last Updated: September 08, 2021
The “US Nota Services” shall mean exchanging fiat currency for US Nota, redeeming US NOTA for fiat currency, holding US NOTA, sending US NOTA, and receiving US NOTA and all other products or services offered at www.usnota.com or otherwise in connection with US NOTA. For purposes of the foregoing, NOTA’s “NOTA Pay” and “NOTA Earn” mobile applications are specifically excluded from the definition of US NOTA Services.
1. Important information and who we are
We are conscious that privacy is important to our users, which is why we only collect the information we need and will not share your personal information with any third-parties unless it is necessary. Even within NOTA, access to your personal information is limited to only those employees who require this information to handle matters relating to compliance, identity verification, fraud prevention and customer support.
It is important that the personal data we hold about you is accurate and current. If you need to add or change any information, you can just log in to your US NOTA Account and make the change in your settings. If it does not appear as if you can make the change yourself, please contact firstname.lastname@example.org and we will take care of it. Please keep us informed if your personal data changes during your relationship with us.
The US NOTA Services may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to review the privacy notice of every website you visit.
The following applies to EEA Customers only.
For the purposes of the General Data Protection Regulation (EU) 2016/679 (“GDPR”), EC Assets, LLC is the controller of your personal data and Nota Europe Limited has been appointed as its representative in the EEA.
Full name of legal entity: NOTA Europe Limited (as GDPR representative)
You have the right to make a complaint at any time to the Information Commissioner's Office (“ICO”), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the opportunity to deal with your concerns before you approach the ICO so please contact email@example.com in the first instance.
2. The data we collect about you
Personal data, or personal information, means information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, store, use, and transfer different kinds of personal data about you which we have grouped together as follows:
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data).
For non-EEA Customers only, in the event that NOTA integrates with other platforms, you may be prompted from time to time to grant Nota access to additional information from such platform (or grant such partner platform access to information you have provided to NOTA).
Information about criminal convictions
When you register for a US NOTA Account or otherwise use the US NOTA Services, we may receive information about your criminal convictions when we perform certain verification or compliance checks. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal obligations.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e. to provide the US NOTA Services to you). In this instance, we may have to close your US NOTA Account but we will notify you if this is the case at the time.
3. How we collect your personal data
We use various methods to collect data from and about you including through:
4. How we use your personal data
The following applies to non-EEA Customers only.
We collect all of this information so that we can provide you with the US NOTA Services safely and seamlessly. The information we collect allows us to:
We will never sell or rent your personal data to third-parties. We may combine your information with information we collect from other companies and use it to improve and personalize the US NOTA Services, as well as our content and advertising.
The following applies to EEA Customers only.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting firstname.lastname@example.org.
Purposes for which we will use your personal data
We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. You can contact Support if you need details about the specific legal ground that we are relying on to process your personal data where more than one ground has been set out in the table below.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason (and that reason is compatible with the original purpose). If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
We aim to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:
(i) Promotional offers from us
We may use your Identity, Contact, Technical, Profile and Usage Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you: (i) have requested information from us; (ii) use our US NOTA Services; or (iii) provided us with your details when you registered for a promotion and you have not opted out of receiving that marketing.
(ii) Third-party marketing
We will obtain your express opt-in consent before we share your personal data with any company outside the NOTA group of companies for marketing purposes.
(iii) Opting out
You can ask us or third-parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting email@example.com at any time.
5. How we share your personal data
Sharing with third-parties
We may have to share your personal data with the parties set out below for the purposes set out in Section 4 above:
6. International transfers
This Section 6 applies to EEA Customers only.
7. How we protect your personal data
8. Data retention
We will only retain your personal data for as long as required to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data, and whether we can achieve those purposes via other means, and the applicable legal requirements. If you want to close your US Nota Account, know that as certain members of the Nota group are regulated financial institutions, we may be required to retain certain information that you have provided for a number of years. For example, we are subject to various AML and CTF regulations which, in a number of jurisdictions, require us to retain certain personal data for a minimum period of five (5) years following the closure of your US Nota Account. For further details of retention periods for different aspects of your personal data please contact us firstname.lastname@example.org. In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
This Section 9 applies to EEA Customers only.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the “Your Legal Rights” section of the glossary to find out more about these rights:
Request access to your personal data
Request correction of your personal data
Request deletion of your personal data
Object to processing of your personal data
Request restriction of processing of your personal data
Request transfer of your personal data
Right to withdraw consent
If you wish to exercise any of the rights set out above, please contact email@example.com.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may also refuse to comply with your request in these circumstances.
What we may need from you
We may need to ask for specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We aim to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Children’s privacy
Unfortunately, if you are under 18, you cannot use the US NOTA Services. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we will delete it immediately.
This Section 11 applies to EEA Customers only.