Privacy and Cookie Policy

At Nuzai, we’re committed to protect and respect your privacy. This Privacy (“Privacy Policy”) governs your access to and use of this Website, nuzai.finance (the “Website”), and associated content, software, and mobile applications (collectively, the “Service”). This Privacy Policy also includes our Terms of Use which is located at (Prague, Czech Republic)

As used in this Privacy Policy, Personal Data means any information relating to an identified or identifiable natural person; Personal Data is intended to cover all information subject to personal data processing and privacy laws applicable to our business.

This Privacy Policy explains when and why we collect personal information about people who visit our Website or use our Services and how we use the personal information, the conditions under which we may disclose your personal information to others, and how we keep personal information secure. This Privacy Policy also explains how we use cookies and similar technology on our Website and in connection with our Services.

For purposes of data protection laws, except where this Privacy Policy does not apply, as described below, the Nuzai entity that will be the “controller” of your Personal Data will be the entity that delivers the products or services you (or the company for whom you are working or have a business relationship) are receiving or maintains the Site that you are using. You can identify the Nusai company that hosts a particular Site through the Site’s footer or “About” link. A list of Nuzai’s different business locations is available https://nuzai.finance

Although your data controller may be a specific Nuzai entity, contact and another customer-related information that we collect may be held in a customer relationship management or contact database which can be accessed by other Nuzai entities which may be located globally; further information about international transfers of information is provided below. To the extent required or permitted by applicable law, by visiting or using our Sites, you are consenting to us collecting and processing information about you in accordance with this Privacy Policy.

We may change this Privacy Policy from time to time, so please occasionally check this page to ensure that you are happy with any changes. By using our Website or our Services, you are agreeing to be bound by this Privacy Policy.

Nuzai (“Nuzai”, “we” or “us”) collects (a) the e-mail addresses of those who communicate with us via e-mail; (b) aggregate information concerning what pages users access or visit; (c) information volunteered by the user (such as survey information and/or site registrations); (d) financial information provided by the user for user syncing and information purposes only; and (e) information related to your use of the Website and/or the mobile application, including IP address, geographic location, and date and time of your request.

How Do We Use the Information?

Nuzai uses collected information for the following purposes:

  • To fulfill a contract or take steps linked to a contract such as processing your registration on our Website (or app) or sending you information about changes to our terms or policies;
  • Where it is necessary for purposes which are in Nuzai’s or third parties’ legitimate interests such as (a) to provide the information or content you have requested; (b) to contact you about our programs, products, features or services; (c) for internal business purposes such as identification and authentication or customer service, portfolio tracking and user preference syncing between devices; (d) to ensure the security of our Website, by trying to prevent unauthorized or malicious activities; (e) to enforce compliance with our Terms of Use and other policies; (f) to help other organizations (such as copyright owners) to enforce their rights; and (g) to tailor content, advertisements, and offers for you or for other purposes disclosed at the time of collection. If you do not wish to receive marketing information about our programs, products, features or services, you may send an email to us at nuzai.official@gmail.com
  • Where you give us consent, such as (a) where you ask us to send marketing information to you via a medium where we need your consent, including alerts via mobile push notifications; (b) where you give us consent to place cookies and to use similar technologies; and (c) on other occasions where we ask you for consent, for a purpose which we explain at that time.
  • Where we are legally required to do so. We may also provide access to your personally identifiable information when legally required to do so, to cooperate with police investigations or other legal proceedings, to protect against misuse or unauthorized use of our Website (or app), to limit our legal liability and protect our rights, or to protect the rights, property or safety of visitors of the Website or the public. In those instances, the information is provided only for that purpose.

INFORMATION WE COLLECT FROM YOU OR YOUR REPRESENTATIVE

We only collect information from you/your representative or about you that is reasonably necessary for us to provide the relevant product or service, business relationship and/or communication consistent with the nature of such product, service, business relationship and/or communication. Based on the specific products, services, business relationship or Sites involved as well as requirements under applicable law, we may collect the following categories of personal information (“Personal Data”) that you or your representative (such as your employer, financial services provider, legal representative, company where you are an officer, director or significant shareholder) provide to us:

  • Fullname
  • Email address
  • Social media username
  • Telephone number
  • Mailing address
  • Company
  • Title
  • Business contact information
  • Employment, company officer or director, or shareholder status
  • Tax or National Identification Number
  • Date of birth
  • Trader identification, client identification or trading “short code”
  • Career or professional history and educational background
  • Financial holdings information
  • Your recorded voice (where you are advised in advance of the recording)
  • Photograph
  • Payment information (e.g., bank account or credit card number)
  • Username and password
  • Passport or government issued identification information (such as for security purposes when visiting our facilities)
  • Any other Personal Data you or your representative volunteers on or provides access to via any or our Sites and/or any Nuzai community forum, social media offering or blog, including, but not limited to, information related to your use of the Sites and interests in certain products or services

We may also automatically collect the following categories of information from devices (e.g., mobile, computer, laptop, tablet) used to visit or use our Sites (“Device Information”):

  • IP address
  • Device identifier
  • Log files
  • Cookies
  • Clear gifs
  • Flash LSOs

Certain Device Information may be deemed Personal Data in accordance with applicable law. Personal Data and Device Information are collectively referred to as “information.”

INFORMATION THAT WE COLLECT ABOUT YOU

Based on the specific products, services, business relationship or Sites involved (as well as requirements under applicable law), we may collect the following categories of Personal Data on our own or from third parties about you in accordance with applicable law:

  • Information about you available in news feeds, exchange data feeds and other public data sources (including the public internet)
  • Information provided by relevant regulators, government agencies and non-government credentialing or professional organizations
  • Information related to your status under economic sanctions, anti-money laundering and similar laws or other information that may impact our ability to engage in business with you or a company at which you are an employee, officer or director or significant shareholder
  • Information that you, your employer or other representative makes publicly available via your personal or company website or in social media profiles
  • Information related to your professional activities (such as consulting to public retirement funds) that is contained in documents released by a governmental body under Freedom of Information Act, Open Government License or similar laws and regulations
  • Information from event organizers for events that you have attended
  • Information from companies providing professional contact information to their customers/subscribers
  • Other Personal Data to the extent permitted by applicable law and reasonably necessary for the performance of our business obligations, compliance with laws applicable to our business or pursuit of our legitimate business interests

Provide you (or your employer/represented company) with our services and products and communicate with you about your (or your employer/represented company) accounts or use of our products, services and/or Sites

  • Perform or enter into a contract
  • Legitimate business interests
  • Comply with a legal obligation
  • Consent

Process transactions through one of our services including, but not limited to, processing financial transactions initiated by your or your representative

  • Perform or enter into a contract
  • Comply with a legal obligation

Comply with our obligations as an exchange, clearinghouse, broker-dealer, central shares depository, pension system administrator and/or other regulated/licensed business including, but not limited to regulations applicable to our EEA Regulated Entities such as, for example, the Markets in Financial Instruments Regulation

  • Perform or enter into a contract
  • Comply with a legal obligation

Perform transaction and regulatory reporting requirements under applicable law

  • Perform or enter into a contract
  • Comply with a legal obligation

Perform our obligations as a Self-Regulatory Organization, trading venue and/or market operator including, but not limited to, conducting surveillance of issuers and trading activities, conducting disciplinary proceedings and reporting suspected to misconduct to regulators and other authorities

  • Perform or enter into a contract
  • Legitimate business interests
  • Comply with a legal obligation

Monitor for security threats and fraud involving the use of our products, services, Sites or physical facilities

  • Legitimate business interests
  • Comply with a legal obligation

Maintain your status as a representative of an exchange or clearinghouse member or certified advisor to issuers

  • Perform or enter into a contract
  • Comply with a legal obligation

Register or establish an account for you (or the company for whom you are an employee, officer or director) as a customer

  • Perform or enter into a contract
  • Legitimate business interests
  • Comply with a legal obligation

Register you (or your employer/represented company) to receive services or information through one or more of our Sites

  • Perform or enter into a contract
  • Consent

To the extent permitted by applicable law, identify you (or your employer/represented company) as a prospective customer for products or services and provide you with relevant information and/or invitations to events

  • Legitimate business interest
  • Consent

Manage our relationship with you (or your employer/represented company) as a customer, business prospect and/or information recipient

  • Perform or enter into a contract
  • Legitimate business interest
  • Consent

To pursue or enforce our legal rights related to our business, products, services or Sites and/or defend against claims made against us

  • Perform or enter into a contract
  • Legitimate business interest

Communicate with you (or your employer/represented company) about your account or use of our products, services or Sites

  • Legitimate business interest
  • Consent

Create informational materials and statistical extracts for our products and services

  • Perform or enter into a contract
  • Legitimate business interest
  • Consent

Develop, provide content for, operate, deliver, and market our services and Sites

  • Perform or enter into a contract
  • Legitimate business interest
  • Consent

Develop and deliver marketing of our products and services and those of our advertisers, sponsors and partners

  • Legitimate business interest
  • Consent

Improve the quality of our Sites and tailor them to your preferences

  • Legitimate business interest
  • Consent

Implement social networking features you have activated (e.g., Facebook “Like” button and LinkedIn integration)

  • Consent

How Do We Share Your Information?

We do not share or sell your personal data to other organizations for commercial purposes, except to provide products or services you’ve requested, when we have your permission, or under the following circumstances:

  • It is necessary to share information in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Terms of Service, or as otherwise required by law.
  • We transfer information about you if Nuzai is acquired by or merged with another company. In this event, Nuzai will notify you before information about you is transferred and becomes subject to a different privacy policy.
  • We provide such information to trusted businesses or persons for the sole purpose of processing personally identifying information on our behalf. When this is done, it is subject to agreements that oblige those parties to process such information only on our instructions and in compliance with this Privacy Policy and appropriate confidentiality and security measures.
  • We provide such information to third parties who have entered into non-disclosure agreements with us.
  • We provide such information to a company controlled by, or under common control with, Nuzai for any purpose permitted by this Privacy Policy.
  • We may aggregate, anonymize, and publish data for statistical and research purposes only. For example, we may compile and share information related to the popularity of certain products tracked by users. In any such instance, the information will not be able to be traced back to any individual.

Complaints

Should you wish to raise a concern about our use of your information (and without prejudice to any other rights you may have), you have the right to do so with your local supervisory authority, although we hope that we can assist with any queries or concerns you may have about our use of your personal data.

Children

The Nuzai service is not intended for children under the age of 18, and we do not knowingly collect information from children under the age of 18.

Users aged 18 or younger should not submit any personal information without the permission of their parents or guardians. By using the Nuzai platform and services, you are representing that you are at least 18 years old, or that you are at least 16 years old and have your parents’ or guardians’ permission to use the Service.

Data Storage

Nuzai uses third-party vendors and hosting partners to provide the necessary hardware, software, networking, storage, and related technology required to run Nuzai and the related Website and mobile application. Nuzai owns the code, databases, and all rights to the Nuzai Website and mobile application and Services.

Security

We take precautions to ensure the security of your personal information. However, we cannot guarantee that hackers or unauthorized personnel may gain access to your personal information despite our efforts. You should note that in using the Nuzai service, your information will travel over the Internet and through third-party infrastructures and mobile networks, which are not under our control.

We cannot protect any information you transmit to other users, nor does this Privacy Policy apply to. You should never transmit personal or identifying information to other users.

Retention of Your Personal Information

We retain information as long as it is necessary to provide the Services requested by you and others, subject to any legal obligations to further retain such information. Information associated with your account will generally be kept until it is no longer necessary to provide the Services or until you ask us to delete it or your account is deleted, whichever comes first. Additionally, we may retain information from deleted accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with investigations, enforce the Terms of Use, and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Information about you that is no longer necessary and relevant to provide our Services may be de-identified and aggregated with other non-personal data to provide insights that are commercially valuable to Nuzai, such as statistics related to the use of Nuzai’s Website and application.

MARKETING COMMUNICATIONS

We process Personal Data within the scope of our marketing and market segmentation. With market segmentation, we mean that we categorize our customer base based on professional affiliations and functions, alignment with our services and products and information gathered from public sources of information. For customers or users of our Sites, we may also use information gathered from your use of our products, services and/or Sites for marketing purposes to market our products and services to you, as well as to tailor advertisements of products and services of our advertisers, sponsors and partners to you when you are on our Sites. You always have right to request that we stop using your personal data for direct marketing purposes.

To the extent required by applicable law, you have the right to object to the processing of your personal data based on a legitimate interest as legal basis. You also always have the right to withdraw your consent at any time when we need your consent in order to process your personal data. If you withdraw your consent, you will no longer receive information and offers that are tailored for you. Please see the section below for more information about your rights.

If you no longer wish to receive marketing communications from us, you may opt-out of receiving marketing-related emails by (1) using the unsubscribe method provided in our communications; (2) if you created an online account when you registered to receive our emails, you may log-in to your account on the applicable Site and make changes to your communication preferences; or (3) you can opt-out by updating your preferences in the Email Alert section of our Sites. In particular, you have the right to object to our use of your Personal Data for direct marketing and in certain other situations (in accordance with applicable law) by contacting us nuzai.official@gmail.com. If you are having difficulty unsubscribing from our email marketing communications using the above methods, please contact us at nuzai.official@gmail.com.

We will try to comply with your request as soon as reasonably practicable as required by applicable law. Please note that we may need to retain certain information for record keeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In addition, please note that even if you opt-out of receiving marketing communications from one or all of our Sites, we may need to send you service-related communications.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

To the extent required by applicable law, in our capacity as the controller of your Personal Data, we will also provide you with the opportunity to be informed of whether we are processing your Personal Data and at any time to access, correct, update, oppose, delete, block, limit or object to our use of your Personal Data. The foregoing rights will be afforded to you free of charge (except to the extent that your requests are manifestly unfounded or excessive, in which case, we may charge an administrative fee or refuse to meet your request).

To prevent fraudulent activity, we may require you to authenticate your identity when you contact us. We will try to comply with your request as soon as reasonably practicable and within timeframes required by applicable law. Please note that in some instances, due to the nature of the information that we receive, we may require you to provide additional information that will help us identify which information is yours. For requests subject to the European General Data Protection Regulation, we will respond to your request within one month of our receipt of it. We may extend this period by two further months taking into account the complexity of your request or the number of requests that we have received; we will inform you of any such extension within one month of receiving your request along with the reasons for the delay and information about your right to file a complaint with the supervisory authority.

The following sets out a summary of your rights to the extent that your Personal Data is processed subject to the European General Data Protection Regulation:

  • Right to access, rectification, erasure and restriction of processing. You have the right to request:
    • Access to your personal data. This means that you have the right to request information on our use of your Personal Data. You also have the right to request a copy of the Personal Data being processed at no cost. However, we may charge you a reasonable administrative fee to provide you with additional copies of the Personal Data. If you make your access request by electronic means such as email, we will provide you with the information in a commonly used electronic format.
    • Rectification of your personal data. We will at your request, or at our own initiative, rectify, anonymize, erase or complement Personal Data that you or we discover is inaccurate, incomplete or misleading. You also have the right to complete the Personal Data with additional data if relevant information is missing.
    • Erasure of your personal data. You have the right to request that we erase your Personal Data if we do no longer have an acceptable reason for processing the data. Given this, erasure shall be made by us if:
    • the Personal Data is no longer necessary for the purposes for which it was collected,
    • we use your Personal Data with your consent and you withdraw your consent,
    • you object to the processing of your Personal Data based on our legitimate interest and there is no overriding legitimate ground for the processing,
    • the Personal Data has not been lawfully processed,
    • we are required to erase the Personal Data due to a legal obligation, or
    • you are a child and we have collected the personal data in relation to the offer of information society services.

However, there might be requirements under applicable law, or other compelling reasons, that prevents us from immediately erasing your Personal Data. In such case, we will stop using your Personal Data for any other reasons than to comply with the applicable law, or the relevant compelling reason.

  • Right to restrict processing: This means that we temporarily restrict the processing of your Personal Data. You have the right to request restriction of the processing when:
    • you have requested rectification of your personal data in accordance with this Privacy Policy, during the period of time we are verifying the accuracy of the data,
    • the processing is unlawful and you do not want the Personal Data to be erased,
    • as data controller, we no longer need the Personal Data for the purposes for which it was collected, but you require us to retain the information for the establishment, exercise or defense of legal claims, or
    • you have objected to our legitimate interest for the processing in accordance with this Privacy Policy, during the period of time we determine whether the legitimate interest overrides your privacy rights.

We will take all reasonable and possible actions to notify any recipients of your Personal Data regarding any rectification, erasure or restrictions carried out by us. At your request, we will also inform you with which third parties we have shared your Personal Data.

  • Right to object to processing. You have the right to object to the processing of your Personal Data based on our legitimate interest. If you object to such processing, we will only continue with the processing if we have a compelling legitimate reason for the processing that outweighs your interest, rights or freedoms, or if continued processing is necessary for the establishment, exercise or defense of a legal claim.
  • Right to portability. You have the right to receive certain of your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller. You only have this right when your personal data is processed by automated means and our legal basis for the processing is the performance of a contract between you and us.
  • Right to lodge a complaint. You have the right to lodge any complaints regarding our processing of your personal data with the supervisory authority.

SECURITY OF YOUR INFORMATION

We take reasonable technical, administrative, and physical security measures to protect your information, including applying generally accepted industry standards to protect the information submitted to us during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure, so we, unfortunately, cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed under the “Contact Us” heading below.

INTERNATIONAL TRANSFERS

Some of the parties with which we may share your information, as detailed in “How We Share Your Information”, may be located in countries that do not provide an equivalent level of protection as your home country. Where required, Nuzai has implemented appropriate cross-border transfer solutions to provide adequate protection for transfers of certain personal information, including, but not limited to, the European Commission’s Standard Contractual Clauses (available at https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en). To the extent permitted by applicable law, by using our Sites, and providing us information about you, you consent to the international transfer of information about you to the above parties.

COOKIES AND SIMILAR TECHNOLOGIES

When you use our Sites, we along with our affiliates, subsidiaries and third party service providers may use “cookies” and similar technologies (e.g., log files, clear gifs, pixel tags and Flash LSOs) (collectively, “technology”). This technology may involve placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences (e.g., language) and generally improving your experience on our Sites. Specifically, we may use such technology for purposes such as to:

  • Provide us with general analytics about our Sites, including demographic information in a non-identifiable form, in order to improve our Sites’ performance and customize users’ experience;
  • Enable us to help you make better use of our services or Sites such as by suggesting how you can improve your use of different features or functionality or help address technical issues that you encounter in using our services or Sites;
  • Support security measures, such as requiring re-login into your account or additional authentication when using a new device to access our Sites;
  • Measure the success of our marketing campaigns and compile statistics about the Site’s usage and email response rates;
  • Allow you to engage in our social media offerings on our Sites (e.g., Facebook “Like” button and LinkedIn integration); and
  • More effectively market our Sites and advertise other Sites that may be of interest to you.