Last Updated on January 24, 2019
Effective date: 25 May 2018
Nitsova (collectively Nitsova, “we” and “us”) respects your privacy.
We offer software as a service, more precisely:
1/- Personal finance web app that allows users to track and manage their expenses, income and do budgeting (this web app is referred to as "the product")
2/- Referral program built around the product and which allows members (individuals who sign up for this referral program) to build a recurring passive income through:
a- referring users
b- sponsoring other members (to sponsor means to encourage someone to sign up for the referral program)
we collect through our services (“Services”) and via our online presence,
which include our main website at nitsova.com,
as well as services and websites that we enable Internet users to access, such as Nitsova Referral Program (collectively, our “Sites”).
This policy also describes how we use Personal Data, with whom we share it, your rights and choices,
and how you can contact us about our privacy practices. This policy does not apply to third-party websites, products, or services,
even if they link to our Services or Sites, and you should consider the privacy practices of those third-parties carefully.
For purposes of the General Data Protection Regulation (known as the “GDPR”), Nitsova is the controller of any personally identifiable information (also referred to in the European Union as “personal data”) collected on the Sites.
1. Overview and Principles
Nitsova obtains Personal Data about you from various sources to provide our Services and to manage our Sites.
“You” may be a visitor to one of our websites, a user of one or more of our Services (“User” or “Nitsova User”), a member of our referral program
(“Member” or “Referral Program Member”).
- We do not collect any more personally identifiable information about you than is necessary;
- We do not keep your personally identifiable information if it is no longer needed; and
If you visit or use our Sites, we may collect Personal Data.
For example, we collect Personal Data that you submit to us via online forms and surveys, and when you contact us by email.
2. Personal Data We Collect
a. Personal Data that we collect about you.
Personal Data is any information that relates to an identified or identifiable individual.
The Personal Data that you provide directly to us through our Sites will be apparent from the context in which you provide the data.
- When you register for the Nitsova personal finance web app we collect your full name, email address, and account log-in credentials (email and password).
- When you join the Nitsova Referral Program we collect your fullname, email address, mobile phone number, postal address and login credentials (username, email and password) .
When you respond to Nitsova emails or surveys we collect your email address, name and any other information you choose to include in the body of your email or responses.
If you contact us by phone, we will collect the phone number you use to call Nitsova.
If you contact us by phone as a Nitsova Referral Program member, we may collect additional information in order to verify your identity.
If you are a Nitsova Referral Program member, you will provide your contact details,
such as name, postal address, telephone number, and email address.
As part of your business relationship with us, we may also receive financial and Personal Data about you,
such as your date of birth and government identifiers associated with you and your organization
(such as your social security number, tax number, or Employer Identification Number).
You may also choose to submit information to us via other methods, including:
(a) in response to marketing or other communications,
(b) through social media or online forums,
(c) through participation in an offer, program or promotion,
(d) in connection with an actual or potential business relationship with us, or
(e) by giving us your business card or contact details at trade shows or other events.
b. Information that we collect automatically on our Sites.
These technologies record information about your use of our Sites, including:
- Browser and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons and the language version of the Sites you are visiting;
- Usage data, such as time spent on the Sites, pages visited, links clicked, language preferences, and the pages that led or referred you to our Sites.
We use Google Analytics on our Sites to help us analyze Your use of our Sites and diagnose technical issues.
3. How We Use Personal Data
a. Our products and services.
We rely upon a number of legal grounds to ensure that our use of your Personal Data is compliant with applicable law.
We use Personal Data to facilitate the business relationships we have with our Members,
to comply with legal obligations, and to pursue our legitimate business interests.
We also use Personal Data to complete customer onboarding and to provide services to our Users and Members.
Contractual and pre-contractual business relationships.
We use Personal Data for the purpose of entering into business relationships with prospective Nitsova Members,
and to perform the contractual obligations under the contacts that we have with Nitsova Members.
Activities that we conduct in this context include:
- Creation and management of Nitsova accounts and Nitsova account credentials,
including the evaluation of applications to commence or expand the use of our Services;
- Creation and management of Nitsova Checkout accounts;
- Accounting, auditing, and billing activities; and
- Processing of payouts, communications regarding such payouts, and related customer service.
Legal and regulatory compliance.
We use Personal Data to verify the identity of our Members in order to comply with fraud monitoring, prevention and detection obligations,
laws associated with the identification and reporting of illegal and illicit activity, such as AML (Anti-Money Laundering)
and KYC (Know-Your-Customer) obligations, and financial reporting obligations.
For example, we may be required to record and verify a Members’s identity for the purpose of compliance with legislation intended
to prevent money laundering and financial crimes.
These obligations are imposed on us by the operation of law and industry standards, and may require us to report our compliance to third parties,
and to submit to third party verification audits.
Legitimate business interests.
We rely on our legitimate business interests to process Personal Data about you.
The following list sets out the business purposes that we have identified as legitimate.
In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals
whose Personal Data we process. We:
- Monitor, prevent and detect fraud and unauthorized actions taken on our Sites;
- Mitigate financial loss, claims, liabilities or other harm to Members and Nitsova;
- Respond to inquiries, send service notices and provide customer support;
- Analyze, modify and improve our products, systems, and tools, and develop new products and services;
- Manage, operate and improve the performance of our Sites and Services by understanding their effectiveness and optimizing our digital assets;
- Analyze and advertise our products and services;
- Conduct aggregate analysis and develop business intelligence that enable us to operate, protect, make informed decisions,
and report on the performance of, our business;
- Ensure network and information security throughout Nitsova and our Services; and
- Transmit Personal Data within our company for internal administrative purposes.
If we need to use your Personal Data in other ways, we will provide specific notice at the time of collection and obtain your consent where required by applicable law.
b. Marketing and events-related communications.
We may send you email marketing communications about Nitsova products and services,
invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes,
provided that we do so in accordance with the consent requirements that are imposed by applicable law.
When we collect your business contact details through our participation at trade shows or other events,
we may use the information to follow-up with you regarding an event, send you information that you have requested
on our products and services and, with your permission, include you on our marketing information campaigns.
c. Interest-based advertising.
When you visit our Sites or online services, both we and certain third parties collect information about
your online activities over time and across different sites to provide you with advertising about products and services
tailored to your individual interests (this type of advertising is called “interest-based advertising”).
These third parties may place or recognize a unique cookie or other technology on your browser (including the use of pixel tags).
Where required by applicable law, we will obtain your consent prior to processing of your information for the purpose of
You may see our ads on other websites or mobile apps because we participate in advertising networks.
Ad networks allow us to target our messaging to users based on a range of factors,
including demographic data, users’ inferred interests and browsing context
(for example, the time and date of your visit to our Sites, the pages that you viewed, and the links that you clicked on).
This technology also helps us track the effectiveness of our marketing efforts and understand if you have seen
one of our advertisements.
We work with Google AdWords and other advertising networks.
To learn how to opt out of behavioral advertising delivered by Network Advertising Initiative member companies,
please visit the Network Advertising Initative
and Digital Advertising Alliance.
You may download the AppChoices app to opt out in mobile apps.
If you opt out from interest-based advertising, you may see advertising that is not relevant to you.
At present, there is no industry standard for recognizing Do Not Track browser signals, so we do not respond to them.
4. How We Disclose Personal Data.
Nitsova does not sell or rent Personal Data to marketers or unaffiliated third parties.
We share your Personal Data with trusted entities, as outlined below.
a. Your sponsor & your team. When you sign up for our referral program, your fullname, email address and mobile phone number are visible to:
- your sponsor (the member who referred you).
- your team (the members you'd refer).
b. Service providers. We use the website hosting service of a third-party company but we don't share any Personal Data with them.
c. Business partners. We don't have any business partner with whom we share Personal Data.
d. Corporate transactions. In the event that we enter into, or intend to enter into,
a transaction that alters the structure of our business, such as a reorganization, merger, sale, joint venture, assignment,
transfer, change of control, or other disposition of all or any portion of our business, assets or stock,
we may share Personal Data with third parties for the purpose of facilitating and completing the transaction.
e. Compliance and harm prevention. We share Personal Data as we believe necessary:
(i) to comply with applicable law;
(ii) to enforce our contractual rights;
(iii) to protect the rights, privacy, safety and property of Nitsova, you or others; and
(iv) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public
and government authorities, which may include authorities outside your country of residence.
5. Your Rights and Choices.
You have choices regarding our use and disclosure of your Personal Data:
a. Opting out of receiving electronic communications from us.
By default this option (receiving marketing related electronic communications) is deactivated.
at any time, if you no longer want to receive marketing-related emails from us, you may do it by unchecking the box again,
( you'll find it under My Profile when you log into the Referral Program platform).
Moreover you may opt-out via the unsubscribe link included in such emails.
We will try to comply with your request(s) as soon as reasonably practicable.
Please note that if you opt-out of receiving marketing-related emails from us,
we may still send you important administrative messages that are required to provide you with our Services.
b. How you can see or change your account Personal Data.
If You would like to review, correct, or update Personal Data that You have previously disclosed to us,
You may do so by signing in to your Nitsova account or by contacting us.
c. Your data protection rights.
Depending on your location and subject to applicable law, you may have the following rights
with regard to the Personal Data we control about you:
- The right to request confirmation of whether Nitsova processes Personal Data relating to you,
and if so, to request a copy of that Personal Data;
- The right to request that Nitsova rectifies or updates your Personal Data that is inaccurate, incomplete or outdated;
- The right to request that Nitsova erase your Personal Data in certain circumstances provided by law;
- The right to request that Nitsova restrict the use of your Personal Data in certain circumstances,
such as while Nitsova considers another request that you have submitted
(including a request that Nitsova make an update to your Personal Data); and
- The right to request that we export to another company, where technically feasible,
your Personal Data that we hold in order to provide Services to you.
Where the processing of your Personal Data is based on your previously given consent,
you have the right to withdraw your consent at any time.
You may also have the right to object to the processing of your Personal Data on grounds relating to your particular situation.
d. Process for exercising data protection rights.
In order to exercise your data protection rights, you may contact Nitsova.
We take each request seriously. We will comply with your request to the extent required by applicable law.
We will not be able to respond to a request if we no longer hold your Personal Data.
If you feel that you have not received a satisfactory response from us, you may consult with the data protection authority
in your country.
For your protection, we may need to verify your identity before responding to your request,
such as verifying that the email address from which you send the request matches your email address that we have on file.
If we no longer need to process Personal Data about you in order to provide our Services or our Sites,
we will not maintain, acquire or process additional information in order to identify you for the purpose of
responding to your request.
6. Security and Retention.
We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of Personal Data.
We maintain organizational, technical and administrative measures designed to protect Personal Data within our organization
against unauthorized access, destruction, loss, alteration or misuse.
Your Personal Data is only accessible to a limited number of personnel who need access to the information to perform their duties.
Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.
If you have reason to believe that your interaction with us is no longer secure
(for example, if you feel that the security of your account has been compromised),
please contact us immediately.
If you are a Nitsova Referral Program Member, we retain your Personal Data as long as we are providing the Services to you.
We retain Personal Data after we cease providing Services to you, even if you deactivate your Nitsova account,
to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring,
detection and prevention. We also retain Personal Data to comply with our tax, accounting, and financial reporting obligations.
Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are
imposed by applicable law.
7. International Data Transfers.
We are a global business. Personal Data may be stored and processed in any country where we have operations
or where we engage service providers. We may transfer Personal Data that we maintain about you to recipients in countries
other than the country in which the Personal Data was originally collected, including to the United States.
Those countries may have data protection rules that are different from those of your country.
However, we will take measures to ensure that any such transfers comply with applicable data protection laws
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those
other countries may be entitled to access your Personal Data.
If you are located in the European Economic Area (“EEA”) or Switzerland,
we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to the US.
Where applicable law requires us to ensure that an international data transfer is governed by a data transfer mechanism,
we use one or more of the following mechanisms: EU Standard Contractual Clauses with a data recipient outside the EEA,
verification that the recipient has implemented Binding Corporate Rules, or verification that the recipient adheres to
the EU-US and Swiss-US Privacy Shield Framework.
8. Use by Minors.
The Services are not directed to individuals under the age of heighteen (18),
and we request that they do not provide Personal Data through the Services.
changes in our Personal Data practices or relevant laws.
by posting them on our website and, if you are a Member, by contacting you through your Referral Program Dashboard,
email address and/or the physical address listed in your Nitsova account.
10. Links To Other Websites.
The Services may provide the ability to connect to other websites.
These websites may operate independently from us and may have their own privacy notices or policies,
which we strongly suggest you review. If any linked website is not owned or controlled by us, we are not
responsible for its content, any use of the website or the privacy practices of the operator of the website.
Attention: Nitsova Legal
Cookies and Similar Technologies
Cookies are small text files that are stored in a computer’s web browser memory.
They help website providers with things like understanding how people use a website, remembering a User’s login details,
that our Services function properly, prevent fraud and other harm, and analyze and improve the Services in accordance
Cookies play an important role in helping us provide personal, effective and safe Services.
a. To Operate Our Services. Some cookies are essential to the operation of our website and Services.
We use those cookies in a number of different ways, including:
through our site and Your dashboard.
- Fraud Prevention and Detection. Cookies and similar technologies that we deploy through websites and
the Services help us learn things about computers and web browsers used to access the Services.
This information helps us monitor for and detect potentially harmful or illegal use of our Services.
to each sale and distribute the right commissions to each referral and sponsor .
b. To Analyze and Improve Our Services. Cookies help us understand how to make our website and Services
work better for You. Cookies tell us how people reach our website and our Users’ websites and they give us insights
into improvements or enhancements we need to make to our website and Services.
c. For Better Advertising. Cookies can help us provide more effective advertising on our website.
For example, we might use a cookie to help prevent You from seeing the same advertisement multiple times or to measure
how many times an advertisement is viewed or clicked on.
2. How We Use Other Technologies
a. Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used in connection with
some Services to, among other things, track the actions of Users (such as email recipients), measure the success of
our marketing campaigns and compile statistics about usage of the Services and response rates.
to collect and analyze information about use of the Services and report on activities and trends.
This service may also collect information regarding the use of other websites, apps and online resources.
You can learn about Google’s practices on the Google website.
c. Flash Cookies. We may use Adobe Flash and other technologies to, among other things,
collect and store information about Your use of the Services. If You want to block or control flash cookies,
You can adjust Your settings.
3. How To Manage Cookies
Your web browser may allow You to change Your cookie preferences, including to delete and disable Nitsova cookies.
Please consult the help section of Your web browser or follow the links below to understand Your options,
but please note that if You choose to disable the cookies, some features of our website or Services may not operate as intended.