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This Privacy Notice describes how we, Normies and/or its affiliates, collect, store, use, process, retain, disclose and protect your Personal Information.
INTRODUCTION This Privacy Notice describes how we, Normies and/or its affiliates ("Normies"), collect, store, use, process, retain, transfer, disclose and protect your Personal Information. This Privacy Notice applies to all websites, services and products (collectively referred to as the "Application"), except where covered by a separate privacy notice.
This Privacy Notice is provided in a layered format so you can click through to the specific areas set out below. Please read this Privacy Notice thoroughly to ensure that you understand our data protection practices. We want to make this easier to understand, so we wrote a summary that highlights all the important points. Unless otherwise defined, all capitalized terms used in this Privacy Notice shall have the same meaning ascribed to them in the applicable Terms and Condition between you and Normies. ACKNOWLEDGMENT AND CONSENT By accepting the Privacy Notice, you acknowledge that you have read and understood this Privacy Notice and you accept all of its terms. In particular, you agree and consent to us collecting, using, sharing, disclosing, storing, transferring, or otherwise processing your Personal Information in accordance with this Privacy Notice. In circumstances where you provide us with Personal Information relating to other individuals (such as Personal Information relating to your spouse, family members, friends, or other parties), you represent and warrant that you have obtained such individual’s consent for, and hereby consent on behalf of such individual to, the collection, use, disclosure and processing of his/her Personal Information by us. You may withdraw your consent to any or all collection, use or disclosure of your Personal Information at any time by giving us reasonable notice in writing using the contact details stated below. You may also withdraw your consent for us to send you certain communications and information via any “opt-out” or “unsubscribe” facility contained in our messages to you. Depending on the circumstances and the nature of the consent which you are withdrawing, you must understand and acknowledge that after such withdrawal of consent, you may no longer be able to use the Application or services. A withdrawal of consent by you may result in the termination of your account or of your contractual relationship with us, with all accrued rights and obligations remaining fully reserved. Upon receipt of your notice to withdraw consent for any collection, use or disclosure of your Personal Information, we will inform you of the likely consequences of such withdrawal so that you can decide if indeed you wish to withdraw consent. |
COLLECTION AND USE OF PERSONAL DATA Personal data is information that relates directly or indirectly to you, identified or identifiable from that information or from other information and information. Transacting and dealing with Normies, you may be asked to provide your personal data from time to time. Normies and its third party service providers may share Personal data with each other and use personal data consistent with this Privacy Policy. They may also combine it with other information to provide and improve Normies products and services. |
RETENTION OF PERSONAL INFORMATION Please note that there is still a possibility that some of your Personal Information may be stored by other parties or Users in some way (such as, through screenshots). Information submitted through communications between Users and Third Parties, which are conducted other than through the use of the Application (such as through telephone, mobile messaging, or other modes of communication) may also be stored in some ways. We do not authorize the storage of Personal Information in such manner and we shall not be liable to you for the same. To the extent permitted by Applicable Laws, we will not be liable for such storage of your Personal Information. You agree to hold us, as well as our officers, directors, employees, agents, suppliers, contractors and Affiliates harmless from and against any and all claims, losses, liabilities, expenses, damages and costs (including but not limited to legal fees and expenses on a fully indemnified basis) resulting directly or indirectly from the unauthorized storage of your Personal Information. |
SUMMARY
More elaboration on the above can be read in the below sections. |
PERSONAL INFORMATION THAT WE COLLECT
"Personal Information" means information that identifies or can be used to identify, contact, or locate the person or device to which the information relates. Personal Information includes, but is not limited to, email address, bank accounts, and wallet address. The type of Personal Information we collect depends on the circumstances of collection and the nature of the service requested or transaction performed. To the extent permitted by Applicable Laws, we may collect, use, store and transfer different types of Personal Information about you which we have categorized as follows:
We may create, use, license or disclose Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your Personal Information but would not be considered Personal Information as this data will not directly or indirectly reveal your identity as we will ensure: (i) that all identifiers have been removed such that the data, alone or in combination with other available data, cannot be attributed to or associated with or cannot identify any person, and (ii) the data is then combined with similar data such that the original data forms a part of a larger data set. |
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The Personal Information which we collect may be provided by you directly or by third parties (for example: when you register for or use the Applications, when you contact our customer services, or you otherwise provide Personal Information to us). We may collect information in various forms and for various purposes (including purposes permitted under Applicable Law). a. Information obtained from you or from your mobile device directly You may give us your Identity, Contact, Eligibility, Profile, Financial, and Payment Data, including in situations where requested by us or where required by Applicable Law, when interacting with us directly or by corresponding with us by post, phone, email or otherwise. This includes Personal Information you provide when you: i. register and create an Account with us using the Applications; ii. use the Applications, including if you register as a Service Provider or use the services as a User; iii. utilize any electronic money and/or electronic wallet facility provided by us (whether as payer or recipient); iv. apply as a registered or verified account holder of an electronic money facility; v. add a source of funds for payment in the Applications; vi. use the chat features in the Applications; and vii. give us feedback or contact us. b. Information collected whenever you use the Applications You may give us Technical and Location Data whenever you use and/or visit the Applications. Whenever you access the Applications through your Mobile Device, we will track and collect your geo-location information in real-time. In some cases, you will be prompted or required to activate the Global Positioning System ("GPS") on your Mobile Device to enable us to give you a better experience in using the Applications (for example, to give you information as to how close a Service Provider is to you. You can always choose to disable the geo-location tracking information on your Mobile Device temporarily. However, this can affect the functionalities available on the Applications. If you use and/or when a payment or transfer is made through the electronic money and/or electronic wallet facility provided by us (whether as payer or recipient), we may collect certain Financial, Profile and Payment Data relating to such payments and transfers. c. Information collected from third parties We may also collect your Personal Information from third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us, who collect your Personal Information and/or perform functions on our behalf, or whom we collaborate with). In such cases, we will only collect your Personal Information for or in connection with the purposes for which such third parties are engaged or the purposes of our collaboration with such third parties (as the case may be). Specifically if you register for a payment card or account through the Applications and/or access, add and/or link a payment card or account to the Applications (as applicable in your country), we may collect certain financial information and financial history of yours (including but not limited to payment card or account transaction history, payment card or account details and mapping and/or payment card or account status and states) from the issuer of such payment credential or any other third parties. d. Information about third parties you provide to us You may provide us with Personal Information relating to other third-party individuals (including Personal Information relating to your spouse, family members, friends, or other individuals). In such cases, you will, of course, need their consent to do so – see “Acknowledgement and Consent”, above, for further information. When you are using the chat features in our mobile applications, you will provide us with phone numbers stored on your mobile phonebook to enable you in using our chat features and for other purposes. |
THE USE OF PERSONAL INFORMATION
a. Where you are a User, we may use your Personal Information: i. to identify you and to register you as a User and to administer, verify, deactivate, or manage your account as such; ii. to facilitate or enable any verification as we may in our discretion consider necessary before the Service Provider provides you with the services or before we register you as a User; iii. to enable Service Provider to provide you with such of the services as you have requested; iv. to process and facilitate orders and payment transactions made by you, including where applicable, transactions made through any payment card or account available over the Applications; v. to notify you of any transaction or activities occurred within the Applications or other system linked to our Applications; vi. to facilitate account and/or wallet linking, if you initiate account and/or wallet linking feature between your Normies account or and third party platform (as applicable); vii. to communicate with you and to send you information in connection with the use of the Applications; viii. to notify you of any updates to the Applications or changes to the services available; ix. to process and respond to enquiries and feedback received from you; x. to maintain, develop, test, enhance and personalize the Application to meet your needs and preferences as a User; xi. to monitor and analyze user activities, behavior, and demographic data including trends and usage of the various services available on the Application; xii. to process and manage reward points (as applicable); xiii. to offer or provide services from our affiliates or partners (as applicable); and xiv. to send you direct or targeted marketing communications, advertisement, vouchers, surveys, and information on special offers or promotions.
i. to undertake associated business processes and functions; ii. to monitor usage of the Applications and administer, support and improve the performance efficiency, growth, user experience and the functions of the Applications; iii. to provide assistance in relation to and to resolve any technical difficulties or operational problems with the Applications or the services; iv. to generate statistical information and analytics data for the purpose of testing, research, analysis, product development, commercial partnership, and collaboration; v. to prevent, detect and investigate any prohibited, illegal, unauthorized or fraudulent activities; vi. to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us and/or any of our affiliates; vii. to enable us to comply with our obligations under any Applicable Law, including but not limited to responding to regulatory enquiries, investigations or directives, complying with statutory or regulatory filing, reporting, and licensing requirements, and conducting audit checks, due diligence and investigations; and viii. for any other purpose that we notify you of and, where required by Applicable Law, obtain your consent to. |
We may disclose to, allow access to, or share with Affiliates and other parties your Personal Information for any of the following purposes as well as for such other purposes as are permitted by Applicable Law: a. where you are a User, for the purpose of enabling a Service Provider, to perform or deliver a service, including to contact you; b. where you are a Service Provider, for the purpose of enabling a User to request or receive a service from you, including to contact you; c. where required or authorized by Applicable Law (including but not limited to responding to regulatory enquiries, investigations or directives, or complying with statutory or regulatory filing, reporting, and licensing requirements), for the purpose so specified in that Applicable Law; d. where instructed, requested, required or authorized by the government authorities, for the purpose as specified in the government policy, regulations or Applicable Law; e. where there is any form of legal proceeding between you and us, or between you and another party, in connection with, or relating to the services, for the purposes of that legal proceeding; f. in relation to any verification as we or other third party may consider necessary before the Service Provider provide you with the services or we register you as a User. g. where we enable our services in any third party’s platform, (i) to assist us in obtaining your Personal Information and/or (ii) to register you or allow you to use our services from such platforms; h. in an emergency concerning your health or safety (whether you are a User or a Service Provider) for the purposes of dealing with that emergency; i. in a situation concerning your health or public interest (whether you are a User or a Service Provider), we may share your Personal Information to the government authorities and/or other institutions that may be appointed by the government authorities or have a cooperation with us, for the purposes of contact tracing, supporting government initiatives, policies or programs, public safety and any other purposes reasonably needed; j. in connection with, any merger, sale of company assets, consolidation or restructuring, financing or acquisition of all or a portion of our business by or into another company, for the purposes of such a transaction (even if the transaction is eventually not proceeded with); k. in connection with insurance claim, we will share your Personal Information for the purpose of processing the insurance claim to the insurance company that we engage or have collaboration with; l. to third parties (including our agents, vendors, suppliers, contractors, partners and any others who provide services to us or you, perform functions on our behalf, or whom we enter into commercial collaboration with) for or in connection with the purposes for which such third parties are engaged, to perform certain disclosure to the relevant third parties which are technically required to process your transaction or for the purposes of our collaboration with such third parties (as the case may be), which may include allowing such third parties to introduce or offer products or services to you, authenticate you or connect with your Account, or conducting other activities including marketing, research, analysis and product development; and m. where we share Personal Information with affiliates, we will do so for the purpose of them helping us to provide the Applications, to operate our business (including, where you have subscribed to our mailing list, for direct marketing purposes), or for the purpose of them conducting data processing on our behalf. For example, a Normies affiliate in another country may process and/or store your Personal Information on behalf of the Normies group company in your country. All of our affiliates are committed to processing the Personal Information that they receive from us in line with this Privacy Notice and Applicable Law. Where it is not necessary for the Personal Information to be associated with you, we will use reasonable endeavors to remove the means by which the Personal Information can be associated with you as an individual before disclosing or sharing such information. We will not sell or lease your Personal Information. Other than as provided for in this Privacy Notice, we may disclose or share your Personal Information if we notify you and we have obtained your consent for the disclosure or sharing. |
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PROTECTING YOUR PERSONAL INFORMATION
Confidentiality of your Personal Information is of utmost importance to us. We will use all reasonable efforts to protect and secure your Personal Information against access, collection, use or disclosure by unauthorized persons and against unlawful processing, accidental loss, destruction and damage or similar risks. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, you acknowledge that we cannot guarantee the integrity and accuracy of any Personal Information which you transmit over the Internet, nor guarantee that such Personal Information would not be intercepted, accessed, disclosed, altered or destroyed by unauthorized third parties, due to factors beyond our control. You are responsible for keeping your Account details confidential and you must not share your Account details, including your password and One Time Password (OTP), with anyone and you must always maintain and fully responsible for the security of the device that you use.
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YOUR RIGHTS AS A USER
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ADDITIONAL NOTES
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CONTACT US How To Contact Us If you have any questions or complaints regarding this Privacy Notice or if you would like to access and/or correct your Personal Information, please contact the relevant DPO for your country:
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