Last updated: 9th June 2020
For your ease, we have provided summaries of some crucial provision in the Policy. However, in case of any conflict between the summaries and these provisions, the provisions shall prevail.
This Policy, incorporates and include our Terms and https://nuo.exchange/legal/terms and https://nuo.exchange/legal/kyc Any words and phrases not defined in this Policy shall mean the same as provided in the Terms.
Type of data
Data disclosed to third party mobile applications and
relation to the any misuse of such data by any third party mobile application or website.
Voluntarily disclosed data.
Data of Ineligible Users.
We have appointed a team to deal with all the grievances, reachable at email@example.com. You can contact the grievance team confidentially by email to enquire about the treatment of your data by us.
By using the App, you consent to providing us data in the ways listed below. We collect this data only to ensure that we can provide you our Services in the best manner possible. We use this data to facilitate the process of sale and purchase of Bitcoin and to improve your experience on the App. The data sought from you is essential for us to provide Services to you in a robust manner. Here is the manner in which we collect data from you.
Means of Gathering Data
Data you provide in the course of signing up, and using our Services.
Data you provide while creating your NUO Account. In order to use the Services, you, an eligible User, must register for a NUO Account and provide certain data about yourself. This may include your name, phone number, email ID, PAN, and M-PIN amongst other data. We may require you to share further data on a later date to confirm the veracity of your data or to enable any additional features on the App in the future.
Data you provide to fulfil the requirements of our KYC & AML Policy. Before you can begin using any Services on the App you must verify your identity and verify your source of funds as per the requirement of our KYC & AML policy available at https://nuo.exchange/legal/kyc. This includes details of your PAN Card, your Aadhaar information, your source of funds, declaration as to whether you are a politically exposed person, and live photo required for a liveliness test (if required). We may require you to provide us with such further data as we determine necessary and appropriate to verify your compliance with the AML regulations of any applicable jurisdiction or to respond to requests from any governmental authority, self-regulatory organization or financial institution in connection with its anti-money laundering compliance procedures, and to update such information as necessary.
Data to be accurate and complete. You must ensure that all the data and/or information you share with us is accurate, correct and complete, at all times. You must promptly inform if your data changes in a way which may impact your use of our Services. We will not be liable or responsible for any loss or damage that you or any other third parties incurs because of incorrect data by you or any other User.
Financial data. To be able to use the services, we may also need some of your financial data. This includes your bank name, bank account number, IFSC code, credit or debit card details, your UPI handle, and details of the bank account to which you wish to withdraw your funds.
Feedback information and other information.
If you call our call centers, we may record information provided by you to service you. Further, we may record the calls for quality and training purposes.
We may also collect any data you provide us when you participate in our referral programs or use any discount codes offered by us.
We may collect any data or information that you provide to us by way of feedback or comments on the App.
Data we collect about you from your usage of our Services.
Technical information. We collect technical information including your IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, platform and other similar information.
Data about your visit. We collect data about your visit including the full URL click stream to, through and from the App (including date and time), data about transactions and trades executed or attempted to be executed by you, material or information that you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction data (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
Data relating to fund balance and Bitcoin. We collect data relating to the INR balance in your NUO Account, the Bitcoins you hold, the changes in value of the Bitcoins you hold over time and fund addition requests and Withdrawal Requests executed by you while accessing Services through our App. We may collect data relating to such transactions provided by you or by a Selected Third Party (defined hereinafter).
Data collected through cookies. Limited personal data may be collected through the cookies and tracking technology, including but not limited to transaction data and other generic data such as number of visitors, device information, etc. Further, if any personal data has been previously provided, cookies may be tied to such data. Cookie and tracking data collected by us may be shared with third-parties which directly support our advertising/promotional activities and are involved in development/updating of our App.
Commonly used browsers are set up to automatically accept cookies, however you can modify your device’s settings to either alert you when you receive cookies or block cookies. If you disable/block cookies, it may affect the performance and functionality of our App and may also restrict your experience. If you use different devices to access our App, you would be required to modify each device’s settings individually to suit your cookie preferences.
Data we receive from
We may receive data about you if you use any of the other websites or apps we operate, or may operate in the future, or the other services we provide, or from Selected Third Parties such as our social media partners, KYC partners, marketing partners, etc. Such data may be shared internally and combined with data collected through use of the App. We collect non-personally identifiable data to track the total number of visitors to the App in aggregate form and identify the type of Internet web browser (e.g., Google Chrome®) and operating system (e.g., Windows®) used by the visitor. This data allows us continuously to improve the App and our Services.
Here is the manner in which the data collected according to Section 3 is used.
Reason of use
Manner of Use
For creating your NUO Account, doing your KYC and providing you Services.
We will use the data you provide to us and the data
we collect from you to:
create your NUO Account;
verify and process your personal details and payment details;
to inform you of promotions, offers, surveys, events, products and services, which may be of interest to you;
to enable you to add and withdraw funds to and from your NUO Account;
to carry out penny-testing of your bank account;
to facilitate and provide the Services offered through the App;
to update and back-up our records;
to carry out our obligations arising from any contracts entered into between NUO and you (including processing of any transactions executed or attempted to be executed by you) and to provide
you with the information and services, that you request from us;
to enhance the security of our App;
to ensure that content from the App is presented in the most effective and personalised manner for you and on your device;
to remember information to help you efficiently access your NUO Account;
to notify you about changes to our Services;
to send you Service-related notices or emails and other non-essential promotional material (Users will be provided the opportunity to opt-out of receiving such email communication by unsubscribing using the relevant link or by contacting us at firstname.lastname@example.org);
for KYC verification of PAN details and other identification documents provided by you. You understand that in order to verify that such information belongs to you: (a) we may send you
verification e-mails/one time passwords; and (b) share all such data with a third party, or
to prevent and identify suspicious /other illegal transactions in order to mitigate risks relating to money laundering and other illegal activities.
For tailoring our App for you, and ensure App safety.
We use the data you provide to us, data we collect about you to, and data we received about you from third sources to:
administer the App and for internal operations, including troubleshooting;
improve the App to ensure that the content, including interactive features is presented in the most effective manner for you and for your device;
keep the App safe and secure;
fulfil our obligations and compliances under applicable law including performing on-going due diligence and reporting suspicious/other illegal transactions.
For enabling customer support.
We use the data we collect from you, and data we collect about you, to provide customer support, including resolution of your concerns from the use of our Services, and to train our customer service executives.
For research and development.
We use the data provided by you, data we collect about you, and data we receive from other sources about you, for research, analysis, and product development to improve our UI/UX experience all of which will ultimately improve how you experience the App. This also helps us develop automated actions to be triggered in certain events, such as when we need to identify if photographs uploaded are not clear, fraud takes place, etc.
For enabling communications between you and us.
We use the data you provide to us, and data we collect about you to enable features (present and future) that allow you to contact us (through the App or otherwise). Similarly, we may use this data to contact you (through the App or any other channels that you give us access to, such as WhatsApp or Facebook).
For marketing and outreach.
We may use the data you provide to us, data that we collect about you, and data we receive from other sources about you, to market the App and our Services, to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you. This includes sharing your feedback, ratings and screen names for purely promotion and marketing purposes. Such promotion and marketing may be done via hoardings, banners, pamphlets etc.
For automated decisions.
We may use the data provided by you, and data we collect about you to provide automated features for customer responses, reimbursement tracking, etc. As our App grows, we will keep adding more automated features to the App.
For legal compliance and requirements.
We may use the data we collect about you, and data we receive from other sources about you, to investigate or address claims or disputes relating to use of our Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
We do not share any sensitive or personal data about you with any third parties unless necessary. However, we may enter into agreements or disclose the collected data in order to provide the Services to you. Here is the manner in which we share the collected data.
Person Shared With
Purpose for Sharing
Sharing with third parties.
Third Party Services. We may disclose and share your personal data with selected business partners and third parties including but not limited to service providers who authenticate KYC and other details as furnished/provided by the you to NUO, scheduled commercial bank(s) which provide(s) banking facilities to NUO, payment processing companies and other digital asset exchanges as NUO may require for providing our services, etc. (“Selected Third Party”).
We may share your data:
With any member of our Group. The term “Group” includes, with respect to any person, any entity that is controlled by such person, or any entity that controls such person, or any entity that is under common control with such person, whether directly or indirectly, or, in the case of a natural person, any Relative (as such term is defined in the Companies Act, 2013) of such person.
If we sell any business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets.
If NUO or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
Sharing for internal use.
While we do not disclose your sensitive personally identifiable data to any advertisers, we may provide them aggregate data about our Users (for example, we may inform them that any given number of women in a specified age group clicked on their advertisement on any given day) to select and serve relevant adverts to you.
Sharing with advertisers of advertising networks.
NUO reserves the right to share current and historical bids, asks, market prices, opening and closing range prices, high–low prices, trade prices, estimated and actual trade volumes, settlement prices and other aggregate data and information related to the trade on the App.
Sharing with law enforcement when needed.
If any governmental authority or law enforcement officers request or require any information and we think disclosure is required or appropriate in order to comply with laws, regulations, or a legal process, or to detect/ prevent actual or potential occurrence of identity theft, fraud, money laundering, abuse of the App and other illegal acts.
We may also share your data with law enforcement agencies for responding to claims that any advertisement, posting or other content on our App violates the intellectual property rights of a third party.
Lastly, we may share your data with law enforcement agencies to enforce our Terms and other agreements, or to protect the rights, property, or safety of NUO, our Users or others. This includes exchanging information with third parties for the purposes of fraud protection and KYC verification.
It is important for us that you remain in control of your data. Here are your rights to restrict our usage of your data. You may exercise these rights by contacting us at email@example.com.
Right to rectification
If you learn or believe that any personal data about you is inaccurate, incomplete or outdated then you have the right to provide us with the accurate, complete and up to date data and have us rectify such data at our end immediately. We urge you to ensure that you always provide us with accurate and correct information/data to ensure your use of our Services is uninterrupted.
Right to erasure
You can demand us to erase your personal data and we will do so without undue delay, provided that the data is no longer required by us and there is no legal requirement to retain the data. Multiple legal basis may exist in parallel and we may still have to retain certain personal data at any time, despite your request to delete it.
Right to withdraw consent
You can withdraw your consent to this Policy by selling all Bitcoins, withdrawing your INR and deleting your NUO Account. However, if you continue to use any of our Services, we will have the right continue processing your data till you stop using them.
Right to opt-out
Marketing opt-outs. We may email and notify you from time to time about our latest offerings and updates. You may opt out of receiving such promotional emails from us by writing to us. You may also opt out of receiving emails and other messages from us by following the unsubscribe instructions in those messages. However, even if you have opted out of receiving information from us, we will still send non-promotional communications, such as receipts for amount remittance etc.
Push notifications. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the App.
Steps we take
We use technical and organizational security measures to protect your personal data. These measures are appropriate to the nature, scope and purpose of processing personal data, the risks associated with such processing, and the likelihood and severity of the harm that may result from such processing. The transfer of personal data between your end device and us is carried out in an encrypted form (TLS encryption). You can identify an encrypted connection for example by the lock symbol in the address line of your browser. If you communicate with us by e-mail, access by third parties cannot be ruled out. In the case of confidential information, we recommend using the mail, i.e., post or encrypted e-mail communication (PGP).
Your personal data is accessible only by our authorized employees and Selected Third Parties, and is otherwise kept secure. We have in place appropriate technical and security measures to prevent unlawful access to or accidental loss of data collected including those prescribed under applicable laws. All data you provide to us is stored on our secure firewalled servers. Any data collected during processing of payment transactions electronically will be encrypted using Secure Socket Layer (SSL) technology.
Steps you must take
You are responsible for keeping the details of your NUO Account and details of any other password-accessible part of the App confidential. You must not share your password with anyone. You must log out when you leave any section of the App protected by a password. We recommend closing the browser completely and re-opening it before accessing other websites over the internet.
Although we will do our best to protect your personal data, we cannot guarantee, give no warranties, and shall not be liable for breach of the security of your data transmitted through the App due to malicious attacks, errors, commission or omissions not wilfully initiated by us. Any transmission of personal data is at your own risk. Once we have received your data, we will use strict physical, electronic, and procedural safeguards to try to prevent unauthorised access.
We will retain any information and data provided by you for as long as you continue to have a NUO Account with us and for a further period of 5 (five) years after deletion of your NUO Account, for resolution of disputes, for investigations or ongoing prosecutions or in case of any suspicious/illegal transactions, for enforcement of any agreements, and/or as necessitated under applicable laws. The retention period may be extended in accordance with the applicable law.
However, we make no warranties and shall not be liable regarding non – availability or non – retention of any information and/or data provided by you beyond the deletion of your NUO Account.
We may from time to time send you Service-related announcements when we consider it necessary to do so (such as when we temporarily suspend the App for maintenance, or security, privacy, or administrative-related communications). We send these to you via SMS/push notifications/email/instant messaging, as we deem fit.
We may occasionally update this Policy. Use of our Services after an update constitutes consent to the updated notice to the extent permitted by law. If we make significant changes, we will notify you of such changes in advance. Please take the time to periodically review this Policy for the latest information on our privacy practices.