Privacy policy

This Privacy Policy (“policy”) explains how Nemondo OÜ processes (e.g. collects, uses, stores, shares) and protects your personal data. We may update this policy from time to time. The latest version of this policy will always be accessible to you on our website. Should there be any amendments to the data processing purposes or any other material changes to this policy, we will let you know via our website or using the contact details you provide us.

This policy is concluded in accordance with the General Data Protection Regulation of the European Union (the “GDPR”). All terms such as “personal data”, “data controller”, “data processor”, “data subject”, “processing” have the meaning given to then in GDPR.

GDPR applies to all personal data processing activities conducted within European Union or towards residents of the European Union, meaning that any processing of data relating to an identifiable person who can be directly or indirectly identified. For further information, please contact privacy@nemondo.com.

Personal data means any information directly or indirectly relating to an identified or identifiable natural person (data subject), such as a name, an identification number, location data, an online identifier or factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Data Controller

While using the services on this website or communicating with us via our website, the controller of your personal data is Nemondo OÜ (registration code 14383513, legal address Hobujaama 4, 10151 Tallinn, Estonia) (“Nemondo”, “we” or “us”).

Should you have any questions about your personal data or this Privacy Policy, please contact privacy@nemondo.com.

Data we process and the purpose of it

We process your personal data in order to provide our services to you.

We are obliged to apply anti-money laundering and counter-terrorist financing (AML-CTF) procedures as well as identify persons (“know your client” or “KYC” procedures) to each and every client of our platform. This is a legal obligation from which we may not refrain.

During Nemondo KYC procedure we process the following data:

  1. Name, surname, age, date of birth (identification code, if applicable), nationality and other information of a client, who is a natural person, which would enable us to verify your identity;
  2. Contact information (your phone number, address, e-mail address);
  3. Employment information (area of activity, position, employer);
  4. Copy of identification document (which is passport, driver licence or other government issued ID with photo) of a client, who is a natural person, or representative or major shareholder of a client, who is a legal person;
  5. Registration documents of a client, who is a legal person, and names of the major shareholders and representatives of the client;
  6. A utility bill that matches with client’s name for proving client’s address;
  7. A utility bill of one of the major shareholders or representatives of a client matching with shareholder’s or representative’s name on its identification document.

If you register as a user on our platform, Nemondo or its affiliates acting on its behalf may process the following types of data for the provision of our services:

  1. Contact information - your name, address, phone number, email address, and other similar data like Skype ID, Telegram ID (if you contact us we would like to be able to respond to your inquiry);
  2. Financial information - if you are transferring payment to Nemondo or receiving assets from Nemondo it may be necessary for Nemondo to collect your bank account number, information about your transactions via our platform, bank wire details that we keep on file when we send payment as well as your cryptocurrency wallet receive code;
  3. For the KYC procedures, from time to time we have to ask you to review and renew the information you have provided us and from time to time we may ask additional information about your transactions (such as origin of assets, further information about your business or your counterparty, or the purpose and documentation of a transaction). This is necessary to protect both you and Nemondo.

We collect information provided to us by you yourself via our website or e-mail interaction. What is more, data is generated by you when you visit our website and use our services. This information may include your IP address, device information (including online identifiers, device name and type, operating system), location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website. Some data such as cookies and browser data are generated automatically, and the services can otherwise not be provided to you.

We may request information from public sources and third parties in relation to our legal obligations (including KYC procedure).

Legal basis for the processing of personal data

Nemondo processes your personal data to provide our services to you and for one or more specific purposes under the following basis:

  1. Our legal obligations

    Our Services are subject to laws and regulations requiring us to collect and use your personal data. For example, your personal data may be processed for KYC procedures, accounting.

  2. Performance of contractual obligations

    We process your personal data where it is necessary for the fulfilment of our obligations towards you deriving from the Terms of Service or any other contract concluded between us, should there be any. Processing your personal data in relation with our contractual obligations may involve setting up or closing your accounts, collecting or issuing necessary documentation, executing your orders, processing transactions, resolving your inquiries and administrating our platform and your user account.

  3. Legitimate interest

    We may have the right to process your personal data where it is in our legitimate interests to do so, provided that the personal data processing does not damage your interests or fundamental rights and freedoms.

    We may process your information in the day-to-day running of our business to ensure that our website is functional and secured, most importantly to protect the data of our customers, employees, and our property. It is in our interests to ensure that our processes and systems operate effectively and that we can continue operating as a business.

    We also process your personal information to better understand the way you use our services and to provide you a personalised experience. We use such information to customise, measure, and improve our Services and the content and layout of our website and applications, and to develop new services.

    Our interest as a business is to ensure that we provide you with the most appropriate products and services. For this purpose, we might process your personal data to send you relevant marketing information based on our services that you have used, including promotional offers, updates to our services, new cryptocurrencies etc. We use information about your usage of our services and your contact information to provide marketing communications. You can opt-out at any time.

  4. Consent

    If we find it helpful to you and us to conduct any other personal data processing activities which would not be covered by any of the aforementioned basis, we must ask for your consent.

    You have right at any time to withdraw your consent to processing of personal data. The withdrawal of consent does not affect the legality of the processing done prior to the waiver of consent or the processing of data under any other basis.

Personal data we share with third parties

While providing services to you it may be necessary for us to share your personal information with third parties. Nemondo does not share your personal information with third parties unless it is necessary to provide services to you or required by law. Nemondo may share your personal data with:

  1. Identity verification services in order to prevent fraud. This allows Nemondo to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal data that can be used solely in connection with provision of identity verification and fraud prevention services;
  2. Service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services (client support, platform developers). Our contracts require these service providers to only use your data in connection with the services they perform for us and prohibit them from selling your data to anyone else. We provide to them only data inevitable for them to provide us their quality services;
  3. Financial institutions with which we partner. Financial institutions will be provided only basic data to send and receive bank wires;
  4. Companies or other entities that we plan to merge with or be acquired by. Should such a combination occur, we will require that the new combined entity follows this Privacy Policy with respect to your personal information. You will receive prior notice of any change in applicable policy;
  5. Law enforcement agencies, officials or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure or when Nemondo is the victim of a fraud or other crime (in the latter case, for example, data associated with the perpetrators may be shared with law enforcement).
  6. Other third parties with your consent or direction to do so.

Third parties to whom we will transmit personal date, can be in the European Economic Area and outside of it in countries where the European Commission has not assessed the level of data protection or considered the respective country to be sufficient by way of its adequacy decision. Personal data is transferred outside the European Economic Area only if it is in compliance with GDPR and only if appropriate safeguards can be applied.

If you require us to transfer your data to any third party outside of the European Economic Area, due to the lack of adequate data protection levels, personal data may not be secured in these countries.

How we protect and store personal data

Your personal data security is important for Nemondo. Nemondo has implemented the necessary organizational, physical and informational security measures to protect your personal data against any misuse, unauthorized access, disclosure, alteration or destruction. This applies, inter alia, to personal data we transmit abroad.

Your personal data is received through our online platform, hosted under our AWS Cloud Server https://aws.amazon.com and is securely stored in our Amazon S3 buckets https://aws.amazon.com/s3/. All personal data is automatically backed up on a regular basis.

Your personal data is only accessible to authorized persons, who are obliged not to disclose your personal data to anyone.

While you are a customer of Nemondo we will securely store your personal data till it is necessary for providing our services to you. Your personal data will be deleted when the Nemondo User Agreement is no longer valid, the need for the processing of such data has been exhausted or in any other case required by the law, including when you withdraw your consent to this privacy policy. In any case we will maintain anonymous data, including transaction data which is not directly linkable to you as a customer.

Automated processing and direct marketing

Nemondo may use automated processing of your personal data for KYC procedures, which are necessary for entering into, or performance of, a contract between you and Nemondo. For that, Nemondo may process your name and identification details, the number of transactions you have made, your average order size, your location (residency, country of origin), and type of client (natural or legal person) to identify clients and transactions potentially breaching AML-CTF regulations. When any suspicions activities have been detected by the system, any decisions which would affect any data subjects will be made personally, not via automated processing.

In order to design post sale marketing campaigns, to update you on our promotions and other updates and make offers to you (direct marketing) we may use information about the transactions you have made, your average transaction size, your location (residency), type of client (natural or legal person).

You can opt-out from direct marketing and updates at any time by clicking the “Unsubscribe” link in the footer of our e-mails. After that, no e-mails of such kind will be sent to you until you decide to opt-in.

Rights of the data subject under this privacy policy

You may request information about your personal data, which we process, and submit requests for correcting any of your incorrect personal data.

Pursuant to applicable laws, you may request deletion or limiting of the processing of your personal data. We cannot satisfy these requests if we have ongoing contractual relationships (meaning that we need to process your personal data to fulfil our obligations under the contract concluded between us), if we need to process your personal data to fulfil our legal obligations, or any other limitations set out in the applicable law apply.

You may also object to our data processing, if you find that we process your personal data or parts of your personal data in violation of your rights. We can continue to process your personal data if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable law.

You have the right to withdraw your consent provided for any data processing activity at any time. The withdrawal of consent shall not affect the lawfulness of other data processing activities not based on the respective consent.

You have the right to lodge a complaint to an appropriate data protection authority for the protection of your rights. If you wish to raise a complaint on how we have handled your personal information, we would suggest you contact our data protection officer who will investigate the matter and hopefully the problem will be solved in a timely manner.

How we use cookies

When you access our website or content or Nemondo services, we or companies we work with may place small data files called cookies or pixel tags on your computer or other device. We use these technologies to:

  1. Recognize you as a Nemondo customer;
  2. Customize Nemondo Services, content, and advertising;
  3. Measure promotional effectiveness;
  4. Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.

We may use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or until they expire.

We may also use Local Shared Objects, commonly referred to as "Flash cookies," to help ensure that your account security is not compromised, to spot irregularities in behaviour to help prevent fraud, and to support our sites and services. We encode our cookies so that only we can interpret the information stored in them.

You are free to decline our cookies if your browser or browser add-on permits but doing so may interfere with your use of Nemondo website or services.