At NaudaPay Ltd. ("We", "Us", "Our", "Noda"), We respect Your privacy and data security. We aim to provide clear information on how We will Use Your data and how You can control that. Therefore, We strongly suggest that You carefully read this Privacy Policy before using services provided by us (collectively, the "Service").

In case You have any further questions or concerns please feel free to reach out to privacy@naudapay.com, We will be happy to address them.

This Privacy Policy, along with the Terms of Service shall constitute the entire Agreement (further - "Agreement") between You and Noda. By using the Service, You acknowledge that You accept and agree to be bound by the terms in the Agreement.

1. Ours and Your responsibilities

By Using Our Service You agree to the Terms of Service and this Privacy Policy.

Your responsibility under the Agreement between You and Us (Terms of Service) is to carefully examine this Privacy Policy and provide the correct data about Yourself.

Our responsibility is to provide You with the most clear and up-to-date information on how We process Your data, ensure the Service safety and security, and keep Your data safe.

2. When do We collect Your data

As soon as You sign up for Our Service We start collecting Your personal data. We collect it solely for the purpose of being able to provide You with Our Service and won't process it in any other way. For the same reason, We may forward Your data to Our third party providers (please find the full list in Section 6).

3. Kinds of data We collect

Depending on how You decide to Use the Service or whether Your subscribe or not, We may collect the following information from You:

  • Your personal data: name and last name, date of birth, address, email, phone (so that We could provide You with access to the Service; provide You with good customer service and User experience; to process payments; to provide You with insights, messages and updates - upon Your authorisation)
  • Your financial and bank data (including but not limited to bank or payment account information, transaction data, loan and investment data), so that We could provide the primary functions of the Service to You, including making payments as per Your authorisation and explicit consent. We may also collect and process personal data provided to Us by your Payment Account Provider, as long as it is needed for Us to fulfil Our obligations associated with the Agreement.
  • Your ID and other documents may be requested from You as prescribed by law (for Us to verify Your identity and conduct due diligence, for compliance and Our Service safety reasons)
  • Data about how You Use the Service (We may collect it, only to have the overall statistics; if collected, this data is purely depersonalised and cannot be linked to You)
  • Information about Your device and other technical information: Your IP address, time zone, geolocation, browser/platform used to access the Service (this is needed for Us to be able to adequately perform under the Agreement between You and Us (please refer to the Terms of Service), as well as for Our legal interests and obligations (e.g. detect fraud and keep Our platform secure).

We will keep the aforementioned data for as long as You keep Using the Service and have a registered account with us. As soon as You choose to delete Your account and have Your data erased, We may keep it for another 30 days after which it will be fully erased.

Please note that even if You do decide to have Your data erased and delete Your Noda account, We still might hold some data about You that would be strictly needed for the purposes like fraud prevention, security, and improving of Our Service (no personal data will be kept in this case).

We will never keep any personal data about You for longer than needed or for any other purposes rather than listed in this Privacy Policy.


4. Your Rights

  • The right to know what kind of data We collect about You and how do We process it. For further details, please read section 3 or contact Us at privacy@naudapay.com.
  • The right to request certain data to be erased or the right to be fully forgotten. Please note that upon such a request We might not be further able to provide You with the Service (fully or partially). Please contact Us directly in case You have such a request.
  • Restrict processing of Your data and withdraw consent. At any time given, You can change the data processing settings right HERE or by contacting Us directly.
  • The right not to provide any personal data to Us. In this case, We might not be able to provide Our Service to You, fully or partially.

You always have the right to file a complaint to the Information Commissioner's Office at www.ico.org.uk in case You are unhappy about how We process Your data.

5. How do We ensure Your data is safe with Us

As soon as We get access to Your data We will comply with the most up-to-date UK and EU security guidelines, to ensure Your data is safe. Administrative, physical, and technical security policies and procedures are put in place, for this purpose.

Your data is stored on Microsoft Azure servers that are continuously backed up. All of the sensitive personal data will always be encrypted upon its transmission to the 3rd parties. We will only transfer Your data to outside of the EEA when strictly prescribed by the applicable laws and regulations, or in order for Us to fulfill Our contractual obligations with You. In such a case, We will take additional measures of data protection.

Upon transferring to the 3rd Parties listed in section 6, We will Use data encryption. We also have strict data processing agreements and procedures with the 3rd Parties, under which We act as Data Controllers and We closely control how Your data is processed by Our partners.

However, please remember that You are responsible for the safety of the login and password information to Your account. We do not hold responsibility for the security of Your credentials.

For more information on data security, feel free to contact privacy@naudapay.com.

6. How do We exchange Your data

To effectively run Our Service, We must partner with third parties and, therefore, We may exchange Your data with:

  • Payment Account Providers (banks, card issuers, etc. - "Partners")
  • Third parties and service You choose to Use in connection with the Service
  • Our Trusted Data Aggregation Partner (https://truelayer.com)
  • Potentially, other third parties, if we have to do so to fulfil our legal obligations

7. Cookie policy

As soon as You open the website we automatically start receiving small text files containing some basic information about You (e.g. Your IP or browser information) - these are cookies.

We will only use cookies to the extent You authorise us to and We will notify You with a banner if and what kind of cookies We may collect, asking You to specify Your preferences in this regard.

We may use cookies to remember Your choices and preferences, to improve the overall experience and help Us to make Your use of the Service more personalised.

Some of the cookies are strictly necessary for the Service operation and we must collect them. For any of the rest, You can always choose to not let us collect these or withdraw Your consent, at any time given.

You can always turn off cookies directly in Your browser settings. Unfortunately, We cannot guarantee full availability and proper functioning of Our website in case You choose to refuse cookies.

We will not share Your cookies with third parties, without Your authorisation.

8. Changes to the Privacy Policy

We may change the Privacy Policy, from time to time, in accordance with the changes in the applicable laws and regulations or changes in Our business procedures. Thus, We suggest that You check this page for the newest updates, from time to time. In case of any major updates, We will always make sure to notify You via the email address You have indicated upon registration.