Noomi Privacy Policy

Privacy Policy

This Privacy Policy is issued by Venture Miles (Malta) Limited, a company incorporated under the law of Malta (“Company”, “we” or “us”). You have arrived at www.noomiwallet.com and/or are otherwise using our Products and Services (defined below).

We know you care about how your personal information is used and shared, and we take your privacy seriously. We are committed to protecting the privacy, confidentiality and security of the personal information we hold by complying with the requirements under applicable laws and regulations, specifically the General Data Protection Regulation (Regulation (EU) 2016679) and the Data Protection Act (Chapter 586 of the Laws of Malta). We are equally committed to ensuring that all our employees, agents and service providers uphold these obligations. Please carefully read the following to learn more about our privacy policy (“Privacy Policy”).

Contact Information

Data Controller: Venture Miles (Malta) Limited is a company incorporated under the laws of Malta, with registration number C 88404. Its registered office is at 93, Mill Street, Qormi QRM3102, Malta.

Venture Miles (Malta) Limited’s Data Protection Officer can be contacted by email at the following address: [email protected]

About this Privacy Policy

We are committed to keeping your information safe and secure. Please read this Privacy Policy so that you understand your rights in relation to this information, including how your information will be collected, used and processed. 

For the purposes of the data protection laws of the European Economic Area (“EEA”), the data controller is Venture Miles (Malta) Limited. 

Please read the following information carefully to understand our practices regarding your personal information and how we will use it.

What does this Privacy Policy cover?

This Privacy Policy covers our treatment of information, including Personal Information (as defined below) that we collect when you access or use our website(s), mobile applications or any other products and services provided by us (“Products and Services”).

This Privacy Policy does not apply to the practices of companies we do not own or control, or people that we do not manage. We gather various types of information from our users, as explained in more detail below. We use this information for you to interact with our Products and Services, including to personalise, provide, and improve our Products and Services, to allow you to set up a user account and profile, to contact you and allow other users to contact you, to fulfil your requests for certain products and services, and to analyse how you use the Products and Services. In certain cases, we may also share some information with third parties as described below.

By using our website, providing personal information and/or using any of our Products and Services, you acknowledge that:

  • we are not responsible for your own disclosure of your information to third parties through our Products and Services (for example, if you send your own contact information to another user through any platform operated by us);
  • you, and you alone, are responsible for the content of any profile or registration you create and its accuracy;
  • you agree to the terms of this Privacy Policy, as updated from time to time; and
  • if you have provided information to us relating to any other person, you:
    • have a right to provide that information;
    • have provided a copy of this Privacy Policy, as updated from time to time, to that person; and
    • each such person has agreed to the Privacy Policy.

In such cases, references in this Privacy Policy to terms such as “you” and “your” also refer to such persons contemplated above.

Your use of our Products and Services is at all times subject to the Terms of Use, which incorporate this Privacy Policy. Any terms not defined in this Privacy Policy have the meaning given to them in the Terms of Use.

What information does the Company collect?

We collect information when you set up your account for the Products and Services, including your name, address, email address and mobile number as further described below.

The type of information we may collect from you includes:

  • (1) personal information (“PersonalInformation”), including without limitation:

    • personally identifiable information, such as your name and date of birth;
    • contact information, such as your email address, telephone number and postal address;
    • national identity number(s) and place of birth;
    • social media handles and other social media profile information that you make available to us or to the public; and
    • third-party account credentials (such as your Facebook login credentials, Google login credentials)
  • (2) demographic information such as information regarding your gender, nationality and occupation (“DemographicInformation”);

  • (3) other information (“Other Information”) including without limitation:

    • financial information, such as credit card, bank account or other payment details;
    • usernames and passwords that you create when registering for an account with us;
    • details of any Products and Services that we provide to you;
    • records of our communications with you, including any messages you send us; and
    • communications you send when using our Products and Services;
  • (4) technical information, including the Internet protocol (IP) address used to connect your device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

  • (5) website information, including transaction record data, full Uniform Resource Locators (URL), clickstream to, through and from our server (including date and time), items you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page;

  • (6) location information, including when you use a location-enabled device to access the Products and Services, we may collect geographical location data or use various means to determine the location, such as sensor data from your device that may, for instance, provide data on nearby cell towers and wi-fi access spots;

  • (7) third party information, being information we receive from other sources, including from third parties who are entitled to disclose that information – you may have the option of registering an account and logging into or otherwise linking to that account using a third-party account such as Facebook, Google or other account provided by a third-party site or application. If you choose to provide or log into your account using your credentials for a third-party platform, we may have access to certain information from that site, such as your name, contacts or friend’s lists, account information, public profile, and email address;

  • (8) Compliance information, including information required to comply with governmental rules, anti-money laundering (“AML”) or “know-your-customer” (“KYC”) policies or other legal and/or regulatory requirements. We will require you to provide information including scanned or depicted documents from you, such as a photo of your passport or other identity card to show proof of identity as well as documentation that evidences your proof of address or documents or online database information to confirm your identity. We will also collect information about your device for fraud prevention, KYC or AML purposes and other information as may be required by applicable law. Such information may be required prior to activation of your account; and

  • (9) If you provide your third-party account credentials, you acknowledge that the above-identified information, as well as other information for that account (collectively, “Third Party Account Information”) may be transmitted into your account with us if you authorise such transmissions. You further acknowledge that Third Party Account Information transmitted to us is governed by this Privacy Policy. When using some features of our Products and Services, certain information may be required from you to register an account with us. Also, we may, from time to time, combine information from other sources with Information we collect from you in order to enhance our ability to serve you, prevent fraudulent transactions, tailor our content to you, offer you opportunities to purchase products or services that we believe may be of interest to you, and for any other purposes described in this Privacy Policy,

paragraphs (1) – (9), together “Information”.

We may collection Information through various forms and in various places within our Products and Services. To the extent we combine Demographic Information and/or Other Information with your Personal Information we collect from you, we will treat the combined data as Personal Information under this Privacy Policy.

Where we collect Personal Information from you, we will generally do so ourselves. However, in some cases we may collect Personal Information from a third party, such as through your representatives, contractors who provide services to us, or third parties who refer you to us because they think you may be interested in our Products and Services.

How do we use your Information?

You acknowledge and agree that we may use the Information we collect about you for the following purposes:

  • to verify your identity when you are dealing with us;
  • to determine your eligibility for any of our Products and Services;
  • to answer your queries and requests;
  • to notify you of any changes to the Privacy Policy and/or the Terms of Use;
  • to email you about your use of the Products and Services;
  • to enable us to provide our Products and Services and personalise your experience by better responding to your individual needs;
  • to improve our website(s) based on your information and feedback;
  • to process transactions;
  • to send periodic emails for keeping you informed of our activities, such as (the email address you provide for order processing, may be used to send you information and updates pertaining to your order, in addition to receiving, occasional company news, updates, related product or service information, etc.);
  • to comply with our legal and regulatory obligations and manage related risks;
  • to manage and resolve any legal or commercial complaints or issues;
  • to carry out market analysis and research; and/or
  • to carry out planning and forecasting activities and other internal business processes.

You are free to opt out of receiving email communications from us by navigating to the settings page within our Products and Services. However, you may be unable to opt out of some administrative communications that are reasonably necessary for us to provide our Products and Services to you, such as order confirmations or service notifications.

Where we use your Information to provide you with information or services which you have requested, we do so on the basis of our legitimate interests in fulfilling your request. Where we use your Information to send you marketing information which you have not directly requested, we will do so only on the basis of your express consent.

Direct marketing

There may be instances where we will use your Information to send you marketing materials, for example, we may send promotional email offers to you about our Products and Services in which we think you may be interested (including in some cases products and services that are provided by a third party). We may not use your Personal Information for direct marketing purposes unless we have received your express consent. You can opt-out of receiving marketing communications from us at any time by contacting us at [email protected]

If we receive your consent, we may use the following Information for the purpose of direct marketing:

  • personal identifying information, such as your name;
  • contact information, such as your e-mail address, mailing address or phone number; and/or
  • products and services portfolio information and demographic data held by us from time to time.

We may use your Personal Information to market the following products and/or services to you, in each case subject to our legal and regulatory obligations:

  • purchasing and/or trading digital assets;
  • providing, managing or accessing mobile wallets for holding digital assets; and
  • other products or services related to digital assets.

If we use your Personal Information in any direct marketing communications, you have the right to request that we provide you with the source of that Personal Information. There is no fee for requesting this information. We will provide you with the source of the Personal Information, unless it is impracticable or unreasonable to do so.

We may also use and disclose your Information for other purposes in accordance with your requests or instructions.

Cookies

Through cookies we place on your mobile device or browser, we may collect information about your online activity after you leave or log out from our Products and Services. Just like any other usage information we collect, this information allows us to improve our Products and Services and to customise your online experience, and otherwise as described in this Policy. Cookies are unique identifiers that we transfer to your device to enable our systems to recognise your device and to improve your overall user experience. For instance, cookies allow us to preserve our users’ preferences and record session information, such as what pages a visit or items the user looks at, recognise the user’s browser or device type, and determine which pages and/or features are visited and by how many people. You may be able to change the preferences on your browser or device to prevent or limit your device’s acceptance of cookies, but this may prevent you from using some features or functionality of our Products and Services.

Your browser may offer you a “Do Not Track” option which allows you to signal to operators of websites and web applications and services (including behavioural advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites.

Is your Information secure?

Protecting your privacy is important to us, which is why we endeavour to protect the security of your Personal Information using commercially reasonable security measures to protect the confidentiality and security of the Information that we hold, and we update these from time to time to address new and emerging security threats of which we become aware.

We also take steps to monitor access to and modification of your Information by our staff members, and ensure that they are aware of and are properly trained in their obligations for managing your data privacy.

No website or Internet transmission is completely secure. Therefore, we cannot guarantee that your Personal Information will never be hacked or that your Personal Information is free from unauthorised access, data loss, or other breaches. Your use of the Products and Services is at your own risk. We encourage you to exercise caution when using our Products and Services by keeping your password safe and not sharing it with others.

How do we store your Information and how long do we keep it?

We generally store the Information that we collect in electronic databases, some of which may be held on our behalf by third party data storage providers in the United States. Sometimes we also keep hard copy records of your Information in physical storage facilities.

We retain your Information for so long as is necessary to achieve the purpose for which it was collected, based on our business needs or as required by law.

We retain the personal data processed by us for as long as is considered necessary for the purpose for which it was collected (including as required by applicable law or regulation). 

In the absence of specific legal, regulatory or contractual requirements, our baseline retention period for Information we collect in the provision of Products and Services is 10 years.

Your Personal Information is also processed by staff operating outside the EEA who work for us or for one of our service providers. We will take all steps reasonably appropriate to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. The Personal Information is transferred to staff in these countries by way of the European Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses), pursuant to Decision 2004/915/EC (in the case of transfers to a controller) and Decision 2010/87/EU (in the case of transfers to a processor). 

Sharing Information

We do not sell or trade your Personal Information to any third parties. We may share your Information with third parties as described in this section:

  • your representatives, advisers and others you have authorised to interact with us on your behalf;

  • our staff members who need the information to discharge their duties;

  • our affiliated entities within the same corporate group – in certain situations, businesses or third-party websites we are affiliated with may sell or provide products or services to you through or in connection with the Products and Services (either alone or jointly with us). You can recognise when an affiliated entity is associated with such a transaction or service, and we will share your Information with that affiliated entity only to the extent that it is related to such Products and Services or their related transaction. Please remember that the manner in which third party services use, store and disclose your information is governed solely by the policies of such third-party service providers. We have no control over the policies and practices of third party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to a website of an affiliated entity or business, please review all such business’ or websites’ policies;

  • our agents and service providers that assist us in operating our website, providing Products and Services to you, or otherwise conducting our business, for example, we may:

    • employ other companies and people to perform certain tasks or services on our behalf, such as hosting services, and may share your Information with them to provide Products and Services to you; for example, we may use a payment processing company or financial institution to receive and process your credit card transactions or payments for us;
    • employ companies to call or email you to in order to provide better services to you, such as to welcome you when you sign up with us, to notify you of your transaction information, to remind you of your account inactivity, to provide codes for you to refer your friends to our Products and Services, or to notify you of an offer that you may be interested in. By providing the relevant communication means to us, you agree that we may, to the extent permitted by applicable laws and regulations, contact you for the above-mentioned purposes; and
    • unless we tell you differently, our agents do not have any right to use the Information we share with them beyond what is necessary to assist us;
  • prospective purchasers or successors of all or part of our business or shares in our company or a related entity – We may choose to buy or sell assets, and may share and/or transfer user information, including the Information, in connection with the evaluation of and entry into such transactions. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, Information could be one of the assets transferred to or acquired by a third party. We may also share your and of your Information, including usage information with our patent, subsidiaries and affiliates;

  • government authorities who ask us to disclose that information in order to:

    • comply with laws and regulations, court orders, or government requests;
    • enforce or apply our Terms of Use and other agreements, guidelines, policies, and regulations;
    • assist in any investigations or legal proceedings (including to respond to claims of alleged violations of any third-party rights); and/or
    • protect the rights, property, or safety of the Company, our employees, our users, or others; and
  • professional advisers who we engage to provide advice on our business.

We may share your User Data with our third-party partners, including investment managers.

De-identifying your Information

We may de-identify your Information (so that you are not identified) and provide that Information to our business partners and/or affiliated entities. We may also provide aggregate usage information to our business partners and/or affiliated entities (or allow them to collect that Information from you), who may use such Information to understand how often and in what ways people use our Products and Services, so that they, too, can provide you with an optimal online experience.

However, we never disclose aggregate usage or de-identified information to a business partner and/affiliated entities (or allow them to collect such information) in a manner that would personally identify you. For example, we use Google Analytics to grow our business, to improve or develop our services, to monitor and analyse use of our Products and Services, for our technical administration, to increase the functionality and user-friendliness of our Products and Services, and to verify that users have the authorisation needed for us to process their requests. To learn more about the privacy policy of Google Analytics, visit http://www.google.com/intl/en/analytics/privacyoverview.html.

You can opt out of the Google Analytics by visiting http://tools.google.com/dlpage/gaoptout.

Accessing and modifying your Information

You may access, review and edit your Information at any time by logging in to your account using your credentials.

To disable your account and remove your Information, please contact us at [email protected] with a request. 

If any Information you provided to us has changed, you should inform us. You are responsible for maintaining the accuracy of the Information you submit to us, such as your contact information. You may be able to access most of your Information via the Products and Services, for example, the Information you provided during the account registration process (i.e. your phone number, username, password, etc.) can be accessed by logging into your account and navigating to account settings. Through your account settings, you may access, and, in some cases, edit or delete the following information you have provided to us:

  • your username;
  • avatar photo; and
  • phone number.

You may be able to add, update, or delete Information. However, we may maintain a copy of the unrevised information in our records. This means your Information is not permanently removed from the system. In order to modify your name, date of birth, or email, you would need to contact us directly at [email protected].

In any event, you may request deletion of your account by contacting us by email at [email protected].

To protect the integrity and security of the Information we hold, we may ask that you follow a defined access procedure, which may include steps to verify your identity. There may be cases where we are unable to provide the information you request, such as where it would interfere with the privacy of others or result in a breach of confidentiality. In these cases, we will let you know why we cannot comply with your request.

Even if you do not request access to and/or correct your personal information held by us, if we are satisfied that, having regard to the reasons for which we hold your personal information, that personal information is inaccurate, incomplete, out-of-date, irrelevant or misleading, we may take reasonable steps to correct that information.

Rights of users

Data subjects have certain rights in relation to the Personal Information we hold. We set out how to exercise those rights below. Please note that we will require you to verify your identity before responding to any requests to exercise your rights.

We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at [email protected]

You may contact our Data Protection Officer at any time to exercise your data subject rights, including:

  • the right to receive information about the data processing and a copy of the processed data (right to access, Art. 15 GDPR)
  • the right to demand the rectification of inaccurate data or the completion of incomplete data (right to rectification, Art. 16 GDPR)
  • the right to demand the erasure of personal data and, in case the personal data has been made public, the information towards other controllers about the request of erasure (right to erasure, Art. 17 GDPR)
  • the right to demand the restriction of the data processing (right to restriction of processing, Art. 18 GDPR)
  • the right to receive the personal data concerning the data subject in a structured, commonly used and machine-readable format and to request the transmittance of these data to another controller (right to data portability, Art. 20 GDPR)
  • the right to object to the data processing in order to stop it (right to object, Art. 21 GDPR)
  • the right to withdraw a given consent at any time to stop a data processing that is based on your consent. The withdrawal will not affect the lawfulness of the processing based on the consent before the withdrawal (right to withdraw consent, Art. 7 GDPR)
  • the right to lodge a complaint with a supervisory authority if you consider the data processing to be an infringement of GDPR (right to lodge a complaint with a supervisory authority, Art. 77 GDPR)

If we have collected Personal Information by obtaining your consent, you also have the right at any time to withdraw that consent by contacting us.

Please contact us at [email protected] if you have any questions or to exercise your rights. 

Your choices about our collection of your Information

You can always opt not to disclose Information to us. However, without the Information, we may not be able to provide you with our Products and Services (or with some of the features and functionality offered by our Products and Services) or to respond to queries or request that you submit to us.

Third party links and tracking

Occasionally, at our discretion, we may include links to third party products or services on our website. These third-party sites have separate and independent privacy policies, we do not verify their content. If you click on a link to a third-party website or service, a third party may transmit cookies to you. This Policy does not cover your use of a third-party website or service or the use of cookies by any third parties, and we are not responsible for their privacy policies and practices. You should review the applicable third-party privacy policies before using their website or services.

Please be aware that third parties may continue to track your online activities even after you have left our Products and Services, and those third parties may not honour “Do Not Track” requests you have set using your browser or device.

Children and Company

Our Products and Services are intended to be used by adults, as defined under any applicable law in each specific case. If you are under legal age, you should not use our Products and Services. We do not knowingly collect or solicit personal information from anyone under the legal age_. _If you are under legal age, please do not attempt to register for the Products and Services or send any Information about yourself to us. If we discover that we have collected Information from a child under legal age, we will delete that Information as quickly as possible. If you believe that a child under legal age may have provided us Information, please contact us at [email protected].

Will we change this Privacy Policy?

We are constantly trying to improve our Products and Services. We may also change this Privacy Policy from time to time, to take into account changes to our standard practices and procedures or where necessary to comply with new laws and regulations.

While the latest version of this Privacy Policy will always be available on our website at www.noomiwallet.com, we may alert you to changes by placing a notice on the website at www.noomiwallet.com, by sending you an email, and/or by some other means. If you have opted not to receive notice emails from us (or you have not provided us with your email address), those notices will still govern your use of the Products and Services, and you are still responsible for reading and understanding them. If you use the Products and Services after any changes to this Policy have been posted, that means you agree to all of the changes.

Because of possible changes in law, a change to this Privacy Policy may become necessary. In this case, we will inform you about such changes. Insofar as the changes affect a processing which is based on your consent, we will ask you for a new consent, if necessary.

 This Privacy Policy was last updated on 4 October 2018.

What should I do if I have a concern?

If you are concerned about the way in which we are managing your Information and think we may have breached any applicable privacy laws, or any other relevant obligation, please contact [email protected]

What if I have questions about this Privacy Policy?

If you have any questions or concerns regarding our Privacy Policy or become award of misuse of the Products and Services by any person, please send our Data Protection Officer a detailed message at [email protected]