Last Updated: 2024-12-28

NODELY PRIVACY POLICY

This Privacy Policy (“Policy”) explains how we handle the personal data of our services users. We want you to know that we take your privacy seriously. We make sure that your personal data is processed in line with the rules set out in the GDPR (Regulation (EU) 2016/679) and the Personal Data Protection Act of 10 May 2018, along with other data protection laws. When you use our services, we may need to process some information about you, including personal data. We only collect and use the personal data that’s necessary to provide and improve our services.

IDENTITY OF THE CONTROLLER

The Controller of your personal data is: Nodely sp. z o.o. a company incorporated in Poland, with its registered office in Warsaw at Żwanowiecka 53, 04-846, entered in the Register of Entrepreneurs by District Court for the City of Warsaw in Warsaw, XIV Commercial Division of the National Court Register under KRS number 0001061171, with NIP (tax identification number): 9522246503, share capital of PLN 50,000 (“Nodely”, “we”, “us”, “our”).

CONTACT WITH THE CONTOLLER

You can contact us in the following ways:

  • address: Nodely sp. z o.o. ul. Ĺ»wanowiecka 53, 04-846, Warsaw, Poland.
  • email: [email protected].

SCOPE OF DATA

We may collect and process the personal data which you provide us. When you use our services and/or sent a query via contact form, we may process certain information, including things like your [name (if you decide to provide it), email address, business name, payment card number, name and surname of payment card holder, billing address including country of origin or residence, address of cryptocurrency wallet (if you pay for services by USDC or EUROC stable coins), tax identification number, phone number (if you contact us by call) and other data provided when contacting us].

For operational and security purposes, we create and store logs that may contain IP addresses. However, these IP addresses are anonymized to prevent any personal identification.

Your personal data will be processed for the following purposes:

Provision of services

We will process your personal data to provide electronic services detailed in the Terms of Service, including in particular in connection with access to technologies selected by you and your payment of a subscription fee, and our managing of service-related matters (based on Article 6(1)(b) of the GDPR).

We will process your personal data to fulfil legal and tax obligations imposed on us such as the payment of income tax, etc. (Article 6(1)(c) of the GDPR).

Our legitimate interests

We will process your personal data to protect ourselves against potential claims, answer your queries sent via contact form and/or handling requests related to technical issues with the website or services we provide (Article 6(1)(f) of the GDPR).

Your data may also be processed based on your consent (Article 6(1)(a) of the GDPR). In such cases, at the time you grant consent, we will inform you of the purposes of the processing. If you provide consent, you have the right to withdraw it at any time. However, the withdrawal of consent will not affect the lawfulness of processing carried out based on consent before its withdrawal.

CATEGORIES OF RECIPIENTS

We share and/or entrust your personal data with trusted entities that provide services essential to our operations, including:

  1. accounting, legal and tax advisors who assist with compliance and regulatory matters;
  2. software developers as well as other employees and contractors that we collaborate with to provide services to you and that support our infrastructure.

Your personal data may be shared with private or public entities if required by law or other official judicial or administrative decisions.

Our website may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. The specific rules about how your personal data is handled by those platforms can be found in their privacy policies, which are available on their websites and apps. We encourage you to check them out for more details.

We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

DATA RETENTION PERIOD

Your personal data will be processed for as long as you use our services. We may process your personal data after the termination of the Terms of Services if it is required by decisions of state authorities or applicable laws such as tax regulations (this will typically be a period of 6 years after the termination of the Terms of Services). The data processing period may be extended if processing is necessary to protect our legitimate interest such as pursuing or defending against legal claims for the period specified by the statute of limitations for claims under the Terms of Service. After the processing period expires, personal data is irreversibly deleted or anonymized.

YOUR RIGHTS

In relation to the processing of your personal data, you have the following rights:

  1. Access Your Data: You have the right to access the content of your data (Article 15 of the GDPR).
  2. Rectify Your Data: You can request corrections if your data is inaccurate or incomplete (Article 16 of the GDPR).
  3. Delete Your Data: You may request the deletion of your data (Article 17 of the GDPR).
  4. Restrict Processing: You have the right to limit the processing of your data (Article 18 GDPR).
  5. Transfer Your Data: You can request to receive your data in a structured, commonly used format, or ask us to transfer it to another controller (Article 20 of the GDPR).
  6. Object to Processing: You may object to the processing of your data (Article 21 of the GDPR).
  7. Avoid Automated Decisions: You have the right not to be subject to decisions based solely on automated processing, including profiling (Article of the 22 GDPR). Please note, however, that your data is not used for profiling. Providing your data is voluntary but essential for us to conclude the Terms of Service with you and provide services to you and/or contact you. If you do not provide it, we may be unable to conclude the Terms of Service with you and/or deliver the services and/or answer on your queries sent via contact form.

NO COOKIES POLICY

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners to make their websites work, as well as to provide reporting information. If you’d like to learn more about cookies, you can check out https://www.allaboutcookies.org.

We do not use cookies. We have designed our website to provide information and services without the need for cookies. This means:

  1. No Persistent Cookies: We do not store any persistent cookies on your device.
  2. No Session Cookies: We do not use temporary cookies that expire after a browsing session.
  3. No Third-Party Cookies: We do not allow third-party services to store cookies on your device through our website. Our decision not to use cookies is part of our commitment to protect your privacy and ensure a seamless user experience. We respect your right to privacy and aim to maintain the integrity of your online experience without the need for tracking or identifying individual visitors.

TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Your personal data will not be transferred outside the territory of the European Economic Area.

Due to the nature of our business, we may use the services of entities located outside the European Economic Area (EEA) such as: Stripe Payments, Amazon Web Services, Google LLC. When we transfer data to a recipient outside the EEA, the transfer is based on the Standard Contractual Clauses (Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council), where the data recipient is an entity processing personal data on our behalf. The content of these clauses is publicly accessible on EUR-lex, the EU’s database for legal instruments (https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX%3A32021D0914). Please note that privacy laws outside the EEA may not offer the same level of protection as the GDPR. Therefore, we implement safeguards to protect your data during transfer, including encryption and, wherever possible, anonymization to maintain confidentiality. Additionally, we limit the information provided to such entities as necessary for service delivery.

If you would like more information about these data transfers and the specific safeguards we employ, please feel free to contact us for further details.

AUTOMATED DECISION – MAKING

Your personal data is not subject to automated decision-making, including profiling.

RIGHT TO LODGE A COMPLAINT

If you consider that the processing of your data is unlawful, you have the right to file a complaint with the supervisory authority, the President of the Office for the Protection of Personal Data in Poland. However, we recommend that you first contact us directly before you do so. We respect you and your information, so we will try to find a solution to satisfy you.

We may update the rules outlined in this Policy as needed due to new technological or legal developments. If we make any changes, we’ll publish the changes on our website and/or send a notification to your email address.

This Privacy Policy is effective as of: 2024-12-28