Privacy Policy

Updated, December 2019

What information does this privacy policy cover?

This Privacy Policy applies to Personal Information collected on websites, mobile applications, or controlled widgets embedded in communication platforms with a link to this Privacy Policy (“Sites”). It does not apply to any other information collected by Nummo through any other means. By “Personal Information,” we mean information that identifies you personally. It covers how we collect, use, and share that Personal Information as of the date that this Privacy Policy is posted. This Policy also doesn’t apply to any Sites maintained or operated by other companies or linked to our Sites.

Your Consent to Transfer Your Personal Information to the United States. Nummo is headquartered in Switzerland. If you decide to use this Site, your Personal Information may be transferred to the United States, and processed in several countries according to the terms described in this Privacy Policy. The laws in the United States or other countries may not be considered adequate by authorities in your home country. If you prefer not to have your Personal Information transferred outside your home country, don’t use this Site. Otherwise, by using this Site, you expressly consent and authorize Nummo to transfer your Personal Information to destinations outside your home country, and process it according to the terms of this Privacy Policy.

What types of personal information do we collect about our users?

We generally collect only Personal Information you voluntarily provide to us. We don't require you to give us Personal Information to access public areas of our Site. This is true unless you live in a country that defines Personal Information to include network identifiers like your Internet Protocol addresses. Certain secure areas of our Site, however, enable authentication or require you to provide Personal Information when you use specific features on our Site. For example, we may collect Personal Information from you when you:

  • Ask to register for an account with us;
  • Upgrade your services or make purchases; 
  • Register for contests, promotions, or games;
  • Ask to receive our newsletter or other materials;
  • Log-in using Facebook or other social media credentials; and
  • Request customer or technical support.


This Personal Information, for example, may include your:

  • Name;
  • Date of birth;
  • Postal address;
  • E-mail address; 
  • Social media account information (e.g., username and website);
  • Telephone or mobile number;
  • Geolocation (your device’s longitudinal and latitudinal information); or
  • Payment card information.

If you can’t or choose not to provide us with the Personal Information we reasonably require, we may be unable to provide you with the information or services you have requested.

Demographic Information. We may also collect certain demographic information (e.g., gender, country of residence, preferences) you provide to us, and may sometimes also combine it with your Personal Information.

Pseudo-Anonymized Information. In some situations, we may collect, use, and share usage data, analytics, and other information that no longer identifies you personally, with certain identifiers removed, for trend monitoring, market or product research, and overall technological enhancements. 

Device Information. Depending on the permissions you’ve granted and other factors, we may receive information about your location and mobile device when you download or use apps available on our Sites, including a unique identifier for your device. We may use this information to provide you with location-based services, such as advertising, certain search results, and other personalized content. We may also share this information with unaffiliated third parties for their own marketing activities. Examples of the device information we collect include: 

  • Attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers.
  • Device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals.
  • Connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address.

Most mobile devices allow you to turn off location services, and we encourage you to contact your device manufacturer for detailed instructions on how to do that.

Payment Information. If you purchase a product or service on our Site, we will collect payment card information from you, including your name, expiration date, authentication code, and billing address. We will securely transmit this information consistent with payment card industry rules to the appropriate payment facilitators. We may offer you the option to save information about the method and choice of payment on our Site. If you save this payment card information on our Site, you will be able to add, delete, or modify that information at any time using your account settings.

Do we advertise online?

Yes, we advertise in a number of ways, including online through managed social media presences, and on other unaffiliated sites and mobile applications. To understand how our advertising campaigns are performing, we may collect certain information via our Sites through our advertising service providers. We or our vendors use several common online tracking tools to collect this information, such as browser and flash cookies, web beacons and other, similar technologies. The information we collect includes IP addresses, the number of page visits, pages viewed via our Sites, search engine referrals, browsing activities over time and across other websites following your visit to one of our Sites or applications, and responses to advertisements and promotions on the websites and applications where we advertise.

We also use certain information to:

  • Present tailored ads, including banner ads and splash ads that appear as you log-in or -off of your online accounts via our Sites;
  • Identify new visitors to our Sites;
  • Recognize returning visitors;
  • Advertise on other websites and mobile applications not affiliated with us;
  • Analyze the effectiveness of our advertisements; 
  • Better understand our audience, customers, or other Site visitors; and
  • Determine whether you might be interested in new products or services.

Controlling Our Tracking Tools. Your browser may give you the ability to control cookies. How you do so, however, depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features and limit the functionality we can provide when you visit or use our Sites. If you block or delete cookies, not all of the tracking that we have described in this Policy will stop. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked. These browser features are still not uniform, so we are not currently set up to respond to those signals.

Controlling Online Interest-Based Ads. We sometimes work with online advertising vendors to provide you with relevant and useful ads. This may include ads served on or through our Sites. This may also include ads served on other companies’ websites. These ads may be based on information collected by us or third parties. For example, your postal code may be used to target an ad for people in your area. These ads may also be based on your activities on our Sites or on third party websites.

To learn more about Interest-Based Advertising or to generally opt-out of this type of advertising by those third parties that are members of the self-regulatory programs such as the Network Advertising Initiative, please visit the NAI’s website www.networkadvertising.org, which will allow you to opt out of Interest-Based Advertising by one, or all, NAI members.  For more information about our ad service provider and its cookies, including information about how to opt out of these technologies, you may visit www.aboutads.info/choices. In addition, users may prevent Google’s collection of data generated by your use of the Sites (including your IP address) by downloading and installing a Browser Plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Minors and Children Under 13. Our Sites are not intended for those under the age of 13. We do not knowingly collect any Personal Information from children under the age of 13 or knowingly track the use of our Sites by these minor users.

How do we use and share your personal information?

Whatever the purpose may be – whether we share with service providers or other external entities – we only process and share your Personal Information to the extent reasonably necessary to fulfill your requests, our legitimate business objectives, or as permitted by applicable law. We may also share your Personal Information as needed to complete any transaction or provide any service you have requested or authorized.

When we disclose Personal Information to external entities to perform support services for us, they may access your Personal Information only for the purposes of performing those support services. 

We may also use what we know about you to offer you other products and services. We may combine your online information with information collected from offline sources or information we already have. We may also use and disclose certain Personal Information to our affiliates and others for any purpose allowed by law.

In accordance with applicable law, we may also share what we know about you with affiliated and unaffiliated third parties for their own marketing activities, or for any purpose allowed by law (California residents see below). In certain instances, we may also help advertisers better reach our users by providing certain Personal Information, including user ID, device type, geographic information, language preferences, or demographic information obtained from other companies. We may run joint or co-sponsored programs or promotions with unaffiliated companies and, as part of that, collect, use, and share your Personal Information. Finally, we may share collected location and Bluetooth data for Interest-Based Advertising, allowing certain advertisers to infer interests and serve ads to our users based on activity and location over time
 

Nummo Business Activities. We may process and disclose your Personal Information to others to:

  • Respond to your questions, complaints, or reviews of our product or services;
  • Administer contests, promotions, or surveys;
  • Allow you to send and receive messages, connection requests, or other similar activities through the Site;
  • Send you communications, including ads, electronic newsletters, or other offers tailored to you;
  • Enable our advertisers to provide you with more personalized content, and track the effectiveness of certain advertising campaigns;
  • Comply with applicable law, obey judicial orders, cooperate with law enforcement authorities, or prevent any suspected illegal activities;
  • Help us run our business; or
  • For any other everyday business purposes, such as product development and Site administration.

Authorized Service Providers. We use other companies and individuals to perform certain functions on our behalf. Those companies include payment card processors, call-center support, cloud providers that analyze or host data, and other companies that help us maintain and improve our products and services.
We may disclose your Personal Information to these companies and other individuals performing services on our behalf in the United States or other locations where we conduct business.

For California residents. Under California’s “Shine the Light” law and the California Consumer Privacy Act (CCPA), California residents may opt-out of a company’s disclosure of Personal Information to third parties for their direct marketing purposes. You may choose to opt-out of our sharing your Personal Information with third parties for their marketing purposes at any time by emailing us at help@nummo.com. You may also opt-out from receiving electronic marketing communications by clicking “unsubscribe” at the bottom of that message. These requests do not, however, prohibit disclosures or communications made for other non-marketing purposes.

Sale of the Businesses. If we sell all or part of our business, Personal Information may be transferred to the purchaser in connection with that transaction. We will use commercially reasonable efforts to include contractual provisions that require the purchaser to treat your Personal Information in a manner consistent with this Privacy Policy.

Other Disclosures. We may otherwise disclose Personal Information as permitted or required by law, when we believe in good faith it is necessary for safety purposes, where required for legal reporting, or to protect our legal rights or enforce our Terms of Use or any applicable rules, or to protect the rights of others. We may also disclose Personal Information to our auditors, to our legal advisors, or to respond to a subpoena. We may also aggregate information that we gather about you, online sales, traffic patterns, and services, and provide these statistics to others in aggregate form. 

What choices do you have about the collection, use, and sharing of your personal information?

We may also share your Personal Information with unaffiliated third parties for their own marketing activities. If you signed up to receive newsletters or other marketing communications from us, you can opt-out any time by clicking the “unsubscribe” link at the bottom of the message.

Even after you opt-out of receiving marketing communications from us, we may still communicate with you for transactional or informational purposes. These include, for example, customer service issues, product-related inquiries, surveys or recalls, or any questions regarding a specific product or service. Of course, you may also deactivate your account at any time.

What kinds of security measures do we take to safeguard your personal information?

The security and confidentiality of your Personal Information matters to us. That’s why we have technical, administrative, and physical controls in place to protect your Personal Information from unauthorized access, use, and disclosure. For example, the areas of our Site that enable or require you to submit Personal Information online use encryption to protect that information. We also review our security procedures periodically to consider appropriate new technology and updated methods. Even so, despite our reasonable efforts, no security measure is ever perfect or impenetrable.

When you use some Nummo products, services, or applications, or post on a forum or social networking service, the Personal Information and content you share is visible to other users, and can be read, collected, or used by them. You are, needless to say, responsible for the Personal Information you choose to share or submit in these instances.

How can you access, update, or block your personal information?

You can update the Personal Information you voluntarily provided to us at any time by logging-in to your account, using our online account resources to access your Personal Information, or submitting any updates or corrections to your contact information. You can contact us directly any time at the address below to update your Personal Information. If you wish to de-activate your account, you may do so online or by contacting our customer support team at help@nummo.com. Once you do so, your account will then be de-activated on a going-forward basis, although certain Personal Information may still be retained to comply with applicable record retention laws, legal holds, or other business requirements.

How can you file a complaint, ask questions, or send us comments about this privacy policy?

If you have any questions, have a complaint, or wish to send us comments about this Privacy Policy, e-mail us at help@nummo.com or write to us. We will investigate your complaint, and use reasonable efforts to respond to you as soon as possible.  

Our postal address is:

nummo Ltd
Muenstergasse 21
8001 Zurich
Switzerland

How will you know if we amend this privacy policy?

We may amend this Privacy Policy at any time. If we make any material change to the way we collect, use, disclose, or otherwise process Personal Information, we will prominently post a link to the updated Privacy Policy. Any material changes to this Privacy Policy will be effective within 10 days after we post the updated Privacy Policy. If you disagree with any material changes to our Privacy Policy, you may exercise your then-available options to opt-out or simply de-activate your account.