Privacy Policy

Effective Date: January 28, 2023

This Privacy Policy describes how Nortiyus and its applicable subsidiaries (collectively, “Nortiyus”, “we”, “us” or “our”) collects, uses, stores, shares, and protects your information. This Privacy Policy outlines our practices in connection with information collected through our websites and other Nortiyus services or products (“Nortiyus Services”).

This Privacy Policy provides a general overview of our privacy practices regarding your information. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions and which may be applicable to you when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements the other notices and is not intended to override them. You can learn more about certain jurisdiction-specific information in the applicable sections at the bottom of this Privacy Policy, including information for individuals residing in the European Economic Area (“EEA”), Singapore, Switzerland, the United Kingdom, and in California.

1. Overview

Purpose of this Privacy Policy 

We know how important privacy is to our users, which is why this Privacy Policy explains how we collect and use data.

2. The Data We Collect About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store, and transfer different kinds of personal data over the preceding 12 months about you, which we have grouped together as follows:

Identity Data includes first name, middle name, maiden name, last name, title, tax ID, marital status, date of birth, gender, identity document number, nationality, and any other information contained in any identification documents you provide to us (e.g., your passport or driver’s license).
Contact Data includes billing address, residential address, email address, and telephone numbers.
Financial Data includes bank account details.
Transaction Data includes details of your Nortiyus Services activity such as the amount, date, time, and recipient for each transaction.
Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Nortiyus Services.
Profile Data includes your username or similar identifier, password, your preferences, feedback, and any survey responses.
Usage Data includes information about how you use the Nortiyus Services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
Survey and Customer Feedback Data includes information you provide in any survey or feedback forms on Nortiyus Services.
Location Data includes information about your device location.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, genetic and biometric data).

3. How We Collect Your Personal Data

We use different methods to collect data from and about you, including through:

Direct interactions. You may give us your Identity, Contact, Financial, Profile, Usage, Marketing and Communications, and Location Data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when:
- You create or use your Nortiyus account;
- You send a wire transfer to your Nortiyus account;
- We need to request more information to verify your identity or to meet our legal obligations;
- You request marketing to be sent to you;
- You participate in a survey; or
- You give us some feedback.
Automated technologies or interactions. When you interact with our Nortiyus Services, we may automatically collect Usage and Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.
Third parties or publicly available sources. We may receive personal data about you from various third parties, including:
- Technical Data from analytics providers such as Google;
- Contact, Financial, and Transaction Data from providers of technical or payment services;
- Identity and Contact Data from verification or compliance services providers; and
- In providing personal data of any individual (other than yourself) to us, you agree that you have obtained consent from such individuals to disclose their personal data to us for processing.

4. How We Use Your Personal Data

We collect all of the information in Section 2 (The Data We Collect About You) so that we can provide you with the Nortiyus Services. The information we collect allows us to:

Deliver the full functionality of the Nortiyus Services;
Keep in touch with you—whether it be for providing customer service, notifying you of new features or updates to the Nortiyus Services, or providing security notices or information;
Verify your identity so that we can prevent fraud or unauthorized activity, and to comply with applicable laws; and
Fulfill any other purpose for which the information was collected.

We may combine your information with information we collect from other companies and use it to improve and personalize the Nortiyus Services, as well as our content and advertising.

Purposes for which we will use your personal data 

We have set out below a description of the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Support.

5. Cookie Policy

Cookies is a term used to describe a small text file (typically made of letters and numbers) that is downloaded and stored on your browser or your device by websites that you visit. They are sometimes considered as forming part of the “memory” of your use of websites and related services as they allow service providers to remember you and respond appropriately.

Cookies are typically split into 2 main types, namely:

Session cookies.  Session cookies are stored in your device’s memory only for the length of time of your browsing session. For example, session cookies allow you to move around our website and your account features without having to repeatedly log in. They are not accessible after your browser session may have been inactive for a period of time and are deleted from your device when your browser is closed down.
Persistent cookies. Persistent cookies are stored in your device’s memory and are not deleted when your browser is closed. Persistent cookies can helpfully remember you and your preferences each time you access our Services.

Nortiyus uses both of these types of cookies.

Cookies can also be further categorized as follows:

Strictly necessary cookies. These are cookies that are required for the necessary operation of our services. They include, for example, cookies that enable you to log into secure areas of our website and/or app.
Performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
Functionality cookies. These are used to recognize you when you return to our website. This enables us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
Targeting cookies. These cookies record your visit to our website, the pages you have visited, and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

Web beacons.

The term ‘web beacon’ is used to describe an object embedded in a webpage or email. This object is typically invisible to you, but it permits us to confirm whether you have viewed the web page and/or email (as the case may be). There are other names for ‘web beacons’ which you may come across—these include web bug, tracking bug, clear gif, and pixel tag.

Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact Support if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.