Privacy Notice

Last updated October 07, 2022

This privacy notice for NorthNode LLC ("Company," "we," "us," or "our"), describes how and why we might collect, store, use, and/or share ("process") your information when you use our services ("Services"), such as when you:

  • Visit our website at https://northnodeapp.com, or any website of ours that links to this privacy notice
  • Download and use our mobile application (NorthNode), or any other application of ours that links to this privacy notice
  • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@northnodeapp.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with NorthNode LLC and the Services, the choices you make, and the products and features you use. Click here to learn more

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Click here to learn more.

How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Click here to learn more.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what NorthNode LLC does with any information we collect? Click here to review the notice in full.

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  6. HOW LONG DO WE KEEP YOUR INFORMATION?
  7. HOW DO WE KEEP YOUR INFORMATION SAFE?
  8. DO WE COLLECT INFORMATION FROM MINORS?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. CONTROLS FOR DO-NOT-TRACK FEATURES
  11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  12. DO WE MAKE UPDATES TO THIS NOTICE?
  13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • names
  • phone numbers
  • email addresses
  • usernames
  • passwords
  • contact preferences
  • contact or authentication data
  • debit/credit card numbers

Sensitive Information. We do not process sensitive information.

Payment Data. We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument. All payment data is stored by PayPal. You may find their privacy notice link(s) here: 1. Overview PayPal has developed this Privacy Statement to explain how PayPal, as a Data Controller, may collect, retain, process, share and transfer your Personal Data when you visit our Sites or use our Services. This Privacy Statement applies to your Personal Data when you visit Sites or use Services, and does not apply to online websites or services that we do not own or control, including websites or services of other PayPal Users. As a European bank registered in Luxembourg, we comply with data protection and financial regulatory requirements. For the avoidance of doubt, this Privacy Statement does not constitute a “framework contract” for the purpose of the EU Payment Services Directive (2007/64/EC) or any implementation of that Directive in the European Economic Area. This Privacy Statement is designed to help you obtain information about our privacy practices and to help you understand your privacy choices when you use our Sites and Services. Please note that our Service offerings may vary by region. This Privacy Statement may be supplemented with additional notices depending on the Sites and Services concerned. Supplementary information can be found in the Statement on Cookies and Tracking Technologies and the Banking Regulations Notice. We have defined some terms that we use throughout the Privacy Statement. You can find the meaning of a capitalised term in the Definitions section. Please contact us if you have questions about our privacy practices that are not addressed in this Privacy Statement. 2. Contact You may contact us if you have general questions or concerns about this Privacy Statement and supplemental notices or the way in which we handle your Personal Data. We want to make sure your questions go to the right place: Click here to contact us about your PayPal account or transaction, or a card payment made to a merchant. Click here to contact us about your Xoom account Our Data Protection Officer can be contacted Online or at PayPal (Europe) S.à.r.l. et Cie, S.C.A., 22-24 Boulevard Royal L-2449, Luxembourg.Further, you have the right to lodge a complaint with the Supervisory Authority for data protection in your country. 3. What Personal Data Do We Collect? We collect Personal Data about you when you visit our Sites or use our Services, including the following: Registration and use information – When you register to use our Services by establishing an Account, we will collect Personal Data as necessary to offer and fulfil the Services you request. Depending on the Services you choose, we may require you to provide us with your name, postal address, telephone number, email address and identification information to establish an Account. We may require you to provide us with additional Personal Data as you use our Services. Transaction and experience information – When you use our Services or access our Sites, for example, to make purchases from merchants, to receive money, to process payments, or to send money to friends and family, we collect information about the transaction, as well as other information associated with the transaction such as amount sent or requested, amount paid for products or services, merchant information, including information about any funding instruments used to complete the transaction, Device Information, Technical Usage Data, and Geolocation Information. Participant Personal Data – When you use our Services or access our Sites, we collect Personal Data you provide us about the other participants associated with the transaction. Send or request money: When you send or request money through the Services, we collect Personal Data such as name, postal address, telephone number, and financial account information about the participant who is receiving money from you or sending money to you. The extent of Personal Data required about a participant may vary depending on the Services you are using to send or request money. Pay or request someone else to pay a bill: If you use our Services to pay a bill for the benefit of someone else, or if you request a User to pay a bill for you, we collect Personal Data from you about the account holder such as name, postal address, telephone number, email address, and account number of the bill that you intend to pay or request to be paid. Add value to your accounts: If you use our Services to add value to your Account or any other account you may have, or if you ask a User to add value to any of these accounts, we may collect Personal Data from you about the other party, or from the other party about you to facilitate the request. For example, if you use our Services to reload a mobile phone, or to request value be added to your mobile account, we may collect Personal Data and other information including mobile account number from the other participant. Information about your public profile and your friends and contacts – It may be easier for us to help you transact with your friends and contacts if you choose to connect your contact list information with your Account or if your Account profile is publicly available. If you establish an account connection between your device or a social media platform and your Account, we will use your contact list information (such as name, address, email address) to improve your experience when you use the Services. When your Account profile is public, other users can find your profile to send you money by searching for you by name, username, email, or mobile number on PayPal and confirm it’s you by viewing your photo. You can make your Account profile private anytime in your PayPal.me settings. Personal data that you choose to provide us to obtain additional Services or specific online Services – If you request or participate in an optional Site feature, or request enhanced Services or other elective functionality, we may collect additional information from you. We will provide you with a separate notice at the time of collection, if the use of that Personal Data differs from the uses disclosed in this Privacy Statement. Personal Data about you if you use unbranded Services – certain Services are available without being required to log in to or establish an Account. We will collect Personal Data when you are interacting with and making payments to merchants using our card payment services that do not carry the PayPal brand and when you checkout with PayPal without logging into an account. For our unbranded payment services, your interaction is with the merchant, on their platform. If you are an Account holder, or create an Account at a later date, we may collect information about unbranded transactions and associate them with your Account to improve your customer experience as an Account holder and for compliance and analytics purposes. If you are not an Account holder, we will collect and store all information you provide and use such information in accordance with this Privacy Statement. Personal Data about you from third-party sources – We obtain information from third-party sources such as merchants, data providers, and credit bureaus, where permitted by law. Other information we collect related to your use of our Sites or Services – We may collect additional information from or about you when you communicate with us, contact our customer support teams or respond to a survey. Non-Account holders If you use our Services without creating or logging into an account, we’ll still collect personal data, which may include your payment information, device information, and location. When you use our Services without creating or logging into an account, we will use this information to process transactions, prevent fraud and comply with the law. We may connect this information with your account, if you have one or if you create an account at a later date. 4. Why Do We Retain Personal Data? We retain Personal Data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes. We may retain Personal Data for longer periods than required by law if it is in our legitimate business interests and not prohibited by law. If your Account is closed, we may take steps to mask Personal Data and other information, but we reserve our ability to retain and access the data for so long as required to comply with applicable laws. We will continue to use and disclose such Personal data in accordance with this Privacy Statement. The cookies we use have defined expiration times; unless you visit our Sites or use our Services within that time, the cookies are automatically disabled and retained data is deleted. Please consult our Statement on Cookies and Tracking Technologies for more information. 5. How Will We Use Your Personal Data? We may Process your Personal Data when we have a valid legal basis to do so. Depending on the circumstances, we may rely on your consent or the fact that processing is necessary to fulfill a contract with you, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations. The provision of Services necessary for the performance of our agreement with You, including to: To operate the Sites and provide the Services, including to: Perform any pre-contractual obligation initiate a payment, send or request money, add value to an account, or pay a bill authenticate your access to an Account communicate with you about your Account, the Sites, the Services, or PayPal create an account connection between your Account and a third-party account or platform perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes, keep your Account and financial information up to date. To manage our business needs, such as monitoring, analysing, and improving the Services and the Sites’ performance and functionality. For example, we analyse User behaviour and perform research about the way you use our Services. To manage risk and protect the Sites, the Services and you from fraud by verifying your identity. PayPal’s risk and fraud tools use Personal Data, Device Information, Technical Usage Data, and Geolocation Information from our Sites and websites that offer PayPal Services to help detect and prevent fraud and abuse of the Services. To comply with our obligations and to enforce the terms of our Sites and Services, including to comply with all applicable laws and regulations. For our legitimate interests, including to: enforce the terms of our Sites and Services; manage our everyday business needs, such as monitoring, analysing; manage risk, fraud, and abuse of PayPal Services; anonymise Personal data in order to provide aggregated statistical data to third parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services; and conduct business to business marketing; and provide personalised Services (also called interest-based marketing) offered by PayPal on third-party websites and online services. We may use your Personal Data and other information collected in accordance with this Privacy Statement to provide a targeted display, feature or offer to you on third-party websites. make it easier for you to find and connect with others. For instance, if you let us access your contacts or when your Account profile is public, we can suggest connections with people you may know and help others connect with you to send you money by letting them find your profile when they search for you by name, username, email, or mobile number on PayPal. We may also associate information that we learn about you through your and your contacts’ use of the Services, and information you and others provide, to suggest people you may know or may want to transact with through our Services. Social functionality and features designed to simplify your use of the Services with others vary by Service. With your consent, including to: To market to you about PayPal products and Services and the products and services of unaffiliated businesses. We may also Process your Personal Data to tailor the marketing content and certain Services or Site experiences to better match your interests on PayPal and other third-party websites. To use cookies and other tracking technologies to provide a targeted display, feature, Service or offer to you and/or to work with other third-parties such as merchants, advertising or analytics companies to provide these personalised services (also called interest-based marketing). To provide you with location-specific options, functionality or offers if you elect to share your Geolocation Information through the Services. We will use this information to enhance the security of the Sites and Services and provide you with location-based Services, such as advertising, search results, and other personalised (also called interest-based marketing) content. To respond to your requests, for example to contact you about a question you submitted to our customer service team. You can withdraw your consent at any time and free of charge. Please refer to the section on “Your Privacy Choices” for more information on how to do that. 6. Do We Share Personal Data? We may share your Personal Data or other information about you with others in a variety of ways as described in this section of the Privacy Statement. We may share your Personal Data or other information for the following reasons: With other members of the PayPal corporate family: We may share your Personal Data with members of the PayPal family of entities to, among other things, provide the Services you have requested or authorised; to manage risk; to help detect and prevent potentially illegal and fraudulent acts and other violations of our policies and agreements and to help us manage the availability and connectivity of PayPal products, Services, and communications. With other companies that provide services to us: We share Personal Data with third-party service providers that perform services and functions at our direction and on our behalf. These third-party service providers may, for example, provide you with Services, verify your identity, assist in processing transactions, send you advertisements for our products and services, or provide customer support. With other financial institutions: We share Personal Data with other financial institutions that we have partnered with to jointly create and offer a product. These financial institutions may only use this information to market and offer PayPal-related products, unless you have given consent for other uses. We may also share Personal Data to process transactions, provide you with benefits associated with your eligible cards, and keep your financial information up to date. With the other parties to transactions when you use the Services, such as other Users, merchants, and their service providers: We may share information about you and your Account with the other parties involved in processing your transactions. This includes other Users you are sending or receiving funds from and merchants, and their service providers. The information might include: Personal Data and Account information necessary to facilitate the transaction; Personal Data to help other participant(s) resolve disputes and detect and prevent fraud; and Anonymous data and performance analytics to help merchants better understand the uses of our Services and to help merchants enhance Users’ experiences. With other third parties for our business purposes or as permitted or required by law: We may share information about you with other parties for PayPal’s business purposes or as permitted or required by law, including: if we need to do so to comply with a law, legal process or regulations; to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to PayPal or PayPal’s corporate family; if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; to protect the vital interests of a person; with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes; to investigate violations of or enforce a user agreement or other legal terms applicable to any Service; to protect our property, Services and legal rights; to facilitate a purchase or sale of all or part of PayPal’s business; in connection with shipping and related services for purchases made using a Service; to help assess and manage risk and prevent fraud against us, our Users and fraud involving our Sites or use of our Services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants; to banking partners as required by card association rules for inclusion on their list of terminated merchants; to credit reporting and collection agencies; to companies that we plan to merge with or be acquired by; and to support our audit, compliance, and corporate governance functions. With your consent: We also will share your Personal Data and other information with your consent or direction, including if you authorise an account connection with a third-party account or platform. In addition, PayPal may provide aggregated statistical data to third-parties, including other businesses and members of the public, about how, when, and why Users visit our Sites and use our Services. This data will not personally identify you or provide information about your use of the Sites or Services. We do not share your Personal Data with third parties for their marketing purposes without your consent. 7. How Do We Work with Other Services and Platforms? A significant benefit and innovation of PayPal’s Services is that you can connect your Account with a third-party account or platform. For the purposes of this Privacy Statement, an “account connection” with such a third-party is a connection you authorise or enable between your Account and a non-PayPal account, payment instrument, or platform that you lawfully control or own. When you authorise such a connection, PayPal and the third-party will exchange your Personal Data and other information directly. Examples of account connections include: linking your Account to a social media account or social messaging service; connecting your Account to a third-party data aggregation or financial services company, if you provide such company with your Account log-in credentials; or using your Account to make payments to a merchant or allowing a merchant to charge your Account. If you choose to create an account connection, we may receive information from the third-party about you and your use of the third-party’s service. For example, if you connect your Account to a social media account, we will receive Personal Data from the social media provider via the account connection. If you connect your Account to other financial accounts, directly or through a third-party service provider, we may have access to your account balance and transactional information, such as purchases and funds transfers. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Privacy Statement. Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorising an account connection, you should review the privacy notice of any third-party that you authorised to have an account connection that will gain access to your Personal Data as part of the account connection. For example, Personal Data that PayPal shares with a third-party account or platform such as a social media account may in turn be shared with certain other parties, including the general public, depending on the account’s or platform’s privacy practices. 8. International transfers Our operations are supported by a network of computers, cloud-based servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. The parties mentioned above may be established in jurisdictions other than your own and outside the European Economic Area, Switzerland, and the United Kingdom (the “UK”). These countries do not always afford an equivalent level of privacy protection. We have taken specific steps, in accordance with EEA data protection law, to protect your Personal Data. In particular, for transfers of your Personal Data within PayPal related companies, we rely on Binding Corporate Rules approved by competent Supervisory Authorities (available here). Other transfers may be based on contractual protections. Please contact us for more information about this. If you make transactions with parties outside the EEA, Switzerland, the UK or connect our Service with platforms, such as social media, outside the EEA, Switzerland, or the UK, we are required to transfer your Personal Data with those parties in order to provide the requested Service to you. 9. How Do We Use Cookies and Tracking Technologies? When you visit our Sites, use our Services, or visit a third-party website for which we provide online services, we and our business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”) to recognise you as a User and to customise your online experiences, the Services you use, and other online content and advertising; measure the effectiveness of promotions and perform analytics; and to mitigate risk, prevent potential fraud, and promote trust and safety across our Sites and Services. Certain aspects and features of our Services and Sites are only available through the use of Cookies, so if you choose to disable or decline Cookies, your use of the Sites and Services may be limited or not possible. Do Not Track (DNT) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. We do not respond to DNT signals. Please review our Statement on Cookies and Tracking Technologies to learn more about how we use Cookies. 10. What Privacy Choices Are Available To You? You have choices when it comes to the privacy practices and communications described in this Privacy Statement. Many of your choices may be explained at the time you sign up for or use a Service or in the context of your use of a Site. You may be provided with instructions and prompts within the experiences as you navigate the Services. Choices Relating to the Personal Data We Collect Personal Data. You may decline to provide Personal Data when it is requested by PayPal, but certain Services or all of the Services may be unavailable to you. Location and other device-level information. The device you use to access the Sites or Services may collect information about you, including Geolocation Information and User usage data that PayPal may then collect and use. For information about your ability to restrict the collection and use of such information, please use the settings available in the device. Choices Relating to Our Use of Your Personal Data Finding and connecting with others. If available, you may manage your preferences for finding and connecting with others from your account of the Service you use. Choices Relating to Account Connections If you authorise an account connection to a third-party account or platform, such as a social media account, you may be able to manage your connection preferences from your Account or the third-party account or platform. Please refer to the privacy notice that governs the third-party platform for more information on the choices you may have. Choices Relating to Cookies Online Tracking and Interest-Based Marketing. We work with partners and third-party service providers to serve you advertising using ad-related cookies and web beacons. You can opt-out of third-party advertising-related cookies and web beacons, in which case our advertising should not be targeted to you. You will continue to see our advertising on third party websites. For more information on third-party advertising-related cookies and interest-based marketing, and to learn how to opt-out of these practices with companies participating in industry self-regulation, please visit Your Online Choices. You may have options available to manage your browser preferences. For example, your browser or internet device may allow you delete, disable, or block certain cookies and other tracking technologies. You can learn more by visiting AboutCookies.org. You may choose to enable these options, but doing so may prevent you from using many of the core features and functions available on a Service or Site. You may have an option regarding the use of cookies and other tracking technologies when you use a Service or visit parts of a Site. For example, you may be asked if you want the Service or Site to “remember” certain things about you, and we will use cookies and other tracking technologies to the extent that you permit them. You can learn more about our cookies and tracking technologies by visiting the Statement on Cookies and Tracking Technologies page. Choices Relating to Your Registration and Account Information If you have an Account, you may review and edit Personal Data by logging in and updating the information directly or by contacting us. contact us if you do not have an Account or if you have questions about your Account information or other Personal Data. Choices Relating to Communication Promotional Marketing: We may send you marketing content about our Sites, Services, products, products we jointly offer with financial institutions, as well as the products and services of unaffiliated third parties and members of the PayPal corporate family through various communication channels, for example, email, text, pop-ups, push notifications, and messaging applications. You may opt out of these marketing communications we send by following the instructions in the communications you receive. If you have an Account with us, you may also adjust your communication preferences in your Account settings. For messages sent via push notifications, you may manage your preferences in your device. Informational and Other: We will send communications to you that are required or necessary to send to Users of our Services, notifications that contain important information and other communications that you request from us. You may not opt out of receiving these communications. However, you may be able to adjust the media and format through which you receive these notices. 11. What Are Your Rights? Subject to limitations set out in EEA data protection laws, you have certain rights in respect of your Personal Data. In particular, you have a right of access, rectification, restriction, erasure and data portability. Please contact us if you wish to exercise these rights. Further, subject to specific requirements, you have the right to object to processing of your personal data based on legitimate interests or a public interest or an official authority vested in us. If you have an Account with any of our Services, you generally can review and edit Personal Data in the Account by logging in and updating the information directly. We may use automated decision-making for decisions concerning credit with your consent or where necessary for the entry into or performance of a contract or authorised by Union or Member state law. Please contact us if you require more information on automated-decision making. Please contact us if you require more information on automated-decision making. 12. How Do We Protect Your Personal Data? We maintain technical, physical, and administrative security measures designed to provide reasonable protection for your Personal Data against loss, misuse, unauthorised access, disclosure, and alteration. The security measures include firewalls, data encryption, physical access controls to our data centres, and information access authorisation controls. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current. We are not responsible for protecting any Personal Data that we share with a third-party based on an account connection that you have authorised. 13. Can Children Use Our Services? The Sites and Services are not directed to children under the age of 16. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use our Sites and Services. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 16, we will promptly delete it, unless we are legally obligated to retain such data. contact us if you believe that we have mistakenly or unintentionally collected information from a child under the age of 16. 14. What Else Should You Know? Changes to this Privacy Statement. We may revise this Privacy Statement from time to time to reflect changes to our business, the Sites or Services, or applicable laws. The revised Privacy Statement will be effective as of the published effective date. If the revised version includes a substantial change, we will provide you with 30 days prior notice by posting notice of the change on the “Policy Update” page of our website. We also may notify Users of the change using email or other means. 15. Definitions Account means a PayPal or Xoom member account. Data Controller means that PayPal determines the purposes and means of the processing of Personal Data. Device Information means data that can be automatically collected from any device used to access the Site or Services. Such information may include, but is not limited to, your device type; your device’s network connections; your device’s name; your device IP address; information about your device’s web browser and internet connection you use to access the Site or Services; Geolocation Information; information about apps downloaded to your device; and biometric data. Geolocation Information means information that identifies, with reasonable specificity, your location by using, for instance, longitude and latitude coordinates obtained through GPS or Wi-Fi or cell site triangulation. PayPal means PayPal (Europe) S.a.r.l. et Cie, S.C.A. and subsidiaries, group companies or affiliates. In this Privacy Statement, PayPal is sometimes referred to as “we,” “us,” or “our,” depending on the context. Personal Data means information that can be associated with an identified or directly or indirectly identifiable natural person. “Personal Data” can include, but is not limited to, name, postal address (including billing and shipping addresses), telephone number, email address, payment card number, other financial account information, account number, date of birth, and government-issued credentials (e.g., driver’s license number, national ID, passport number). Process means any method or way that we handle Personal Data or sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, and consultation, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction of Personal Data. Services means any products, services, content, features, technologies, or functions, and all related websites, applications and services offered to you by PayPal or Xoom. Sites means the websites, mobile apps, official social media platforms, or other online properties through which PayPal offers the Services and which has posted or linked to this Privacy Statement. Technical Usage Data means information we collect from your phone, computer or other device that you use to access the Sites or Services. Technical Usage Data tells us how you use the Sites and Services, such as what you have searched for and viewed on the Sites and the way you use our Services, including your IP address, statistics regarding how pages are loaded or viewed, the websites you visited before coming to the Sites and other usage and browsing information collected through Cookies. User means an individual who uses the Services or accesses the Sites. 16. Additional Information The information provided in this section may be specific to customers depending on your region or how you use the Services. This information is provided to PayPal from third parties whom you may interact when using the Services. Banking Regulations Notice for Customers in the EEA Google ReCaptcha Banking Regulations Notice for Customers in the EEA In general, the Luxembourg laws to which PayPal’s handling of user data is subject (data protection and bank secrecy) require a higher degree of transparency than most other EU laws. This is why, unlike the vast majority of providers of internet-based services or financial services in the EU, PayPal has listed in this Privacy Statement the third party service providers and business partners to whom we may disclose your data, together with the purpose of disclosure and type of information disclosed. You will find a link to those third parties here. By accepting this Privacy Statement and maintaining an account with PayPal, you expressly consent to the transfer of your data to those third parties for the purposes listed. PayPal may update the list of third parties referred to above on the first business day of every quarter (January, April, July and October). PayPal will only start transferring any data to any of the new entities or for the new purposes or data types indicated in each update after 30 days from the date when that list is made public through this Privacy Statement. You should review the list each quarter on the PayPal website on the dates stated above. If you do not object to the new data disclosure, within 30 days after the publication of the updated list of third parties, you are deemed to have accepted the changes to the list and to this Privacy Statement. If you do not agree with the changes, you may close your account and stop using our services. In order to provide the PayPal Services, certain of the information we collect (as set out in this Privacy Statement) may be required to be transferred to other PayPal related companies or other entities, including those referred to in this section in their capacity as payment providers, payment processors or account holders (or similar capacities). You acknowledge that according to their local legislation, such entities may be subject to laws, regulations, inquiries, investigations, or orders which may require the disclosure of information to the relevant authorities of the relevant country. Your use of the PayPal Services constitutes your consent to our transfer of such information to provide you the PayPal Services. Specifically, you agree to and direct PayPal to do any and all of the following with your information: Disclose necessary information to: the police and other law enforcement agencies; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies, departments, regulatory authorities, self-regulatory authorities or organisations (including, without limitation, the Agencies referenced in the “Agencies” section of the Third Party Provider List here) and other third parties, including PayPal Group companies, that (i) we are legally compelled and permitted to comply with, including but without limitation the Luxembourg laws of 24 July 2015 on the US Foreign Account Tax Compliance Act (“FATCA Law”) and 18 December 2015 on the OECD common reporting standard (“CRS Law”); (ii) we have reason to believe it is appropriate for us to cooperate with in investigations of fraud or other illegal activity or potential illegal activity, or (iii) to conduct investigations of violations of our User Agreement (including without limitation, your funding source or credit or debit card provider). If you are covered by the FATCA or CRS Law, we are required to give you notice of the information about you that we may transfer to various authorities. Please read more about PayPal's obligations under the FATCA and CRS Law and how they could affect you as well as take note of the information we may disclose as result. We and other organisations, including parties that accept PayPal, may also share, access and use (including from other countries) necessary information (including, without limitation the information recorded by fraud prevention agencies) to help us and them assess and to manage risk (including, without limitation, to prevent fraud, money laundering and terrorist financing). Please contact us if you want to receive further details of the relevant fraud prevention agencies. For more information on these Agencies, fraud prevention agencies and other third parties, click here. Disclose Account Information to intellectual property right owners if under the applicable national law of an EU member state they have a claim against PayPal for an out-of-court information disclosure due to an infringement of their intellectual property rights for which PayPal Services have been used (for example, but without limitation, Sec. 19, para 2, sub-section 3 of the German Trademark Act or Sec. 101, para 2, sub-section 3 of the German Copyright Act). Disclose necessary information in response to the requirements of the credit card associations or a civil or criminal legal process. Disclose your name and PayPal link in the PayPal user directory. Your details will be confirmed to other PayPal users in response to a user searching using your name, email address or telephone number, or part of these details. This is to ensure people make payments to the correct user. This feature can be turned off in the PayPal profile settings. If you as a merchant use a third party to access or integrate PayPal, we may disclose to any such partner necessary information for the purpose of facilitating and maintaining such an arrangement (including, without limitation, the status of your PayPal integration, whether you have an active PayPal account and whether you may already be working with a different PayPal integration partner). Disclose necessary information to the payment processors, auditors, customer services providers, credit reference and fraud agencies, financial products providers, commercial partners, marketing and public relations companies, operational services providers, group companies, agencies, marketplaces and other third parties listed here. The purpose of this disclosure is to allow us to provide PayPal Services to you. We also set out in the list of third parties, under each " Category", non-exclusive examples of the actual third parties (which may include their assigns and successors) to whom we currently disclose your Account Information or to whom we may consider disclosing your Account Information, together with the purpose of doing so, and the actual information we disclose (except as explicitly stated, these third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information was shared). Disclose necessary information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you). Disclose aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in Manchester. However, this aggregated information is not tied to personal information. Share necessary Account Information with unaffiliated third parties (listed here) for their use for the following purposes: Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk. Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional). Shipping: in connection with shipping and related services for purchases made using PayPal. Legal Compliance: to help them comply with anti-money laundering and counter-terrorist financing verification requirements. Service Providers: to enable service providers under contract with us to support our business operations, such as fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit. Google ReCaptcha PayPal uses ReCaptcha on the Sites and Services. Your use of ReCaptcha is subject to the Google Privacy Policy and Terms of Use. ReCaptcha is only used to fight spam and abuse..

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register in this way, we will collect the information described in the section called "HOW DO WE HANDLE YOUR SOCIAL LOGINS?" below.

    Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:
  • Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

  • To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  • To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  • To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
  • To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
  • To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see "WHAT ARE YOUR PRIVACY RIGHTS?" below.
  • To post testimonials. We post testimonials on our Services that may contain personal information.
  • To administer prize draws and competitions. We may process your information to administer prize draws and competitions.
  • To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.
  • To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
  • To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
  • To comply with our legal obligations. We may process your information to comply with our legal obligations, respond to legal requests, and exercise, establish, or defend our legal rights.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:

  • Nonprofit Partners

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
  • Other Users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.
  • Offer Wall. Our application(s) may display a third-party hosted "offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@northnodeapp.com.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

  • Log in to your account settings and update your user account.
  • Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

    Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

    If you have questions or comments about your privacy rights, you may email us at info@northnodeapp.com.

    10. CONTROLS FOR DO-NOT-TRACK FEATURES

    Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

    11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

    In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

    California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

    If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

    CCPA Privacy Notice

    The California Code of Regulations defines a "resident" as:

  • (1) every individual who is in the State of California for other than a temporary or transitory purpose and
  • (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
  • All other individuals are defined as "non-residents."

    If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

    What categories of personal information do we collect?

    We have collected the following categories of personal information in the past twelve (12) months:

    Category
    Examples
    Collected

    A. Identifiers

    Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name

    NO

    B. Personal information categories listed in the California Customer Records statute

    Name, contact information, education, employment, employment history, and financial information

    NO

    C. Protected classification characteristics under California or federal law

    Gender and date of birth

    NO

    D. Commercial information

    Transaction information, purchase history, financial details, and payment information

    NO

    E. Biometric information

    Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements

    NO

    G. Geolocation data

    Images and audio, video or call recordings created in connection with our business activities

    NO

    I. Professional or employment-related information

    Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us

    NO

    J. Education Information

    Student records and directory information

    NO

    K. Inferences drawn from other personal information

    Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

    NO

    We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

  • Receiving help through our customer support channels;
  • Participation in customer surveys or contests; and
  • Facilitation in the delivery of our Services and to respond to your inquiries.
  • How do we use and share your personal information?

    More information about our data collection and sharing practices can be found in this privacy notice.

    You may contact us by email at info@northnodeapp.com, or by referring to the contact details at the bottom of this document.

    If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

    Will your information be shared with anyone else?

    We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

    We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

    NorthNode LLC has not sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. NorthNode LLC has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

    The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?".

    Your rights with respect to your personal data

    Right to request deletion of the data — Request to delete

    You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.

    Right to be informed — Request to know

    Depending on the circumstances, you have a right to know:

  • whether we collect and use your personal information;
  • the categories of personal information that we collect;
  • the purposes for which the collected personal information is used;
  • whether we sell your personal information to third parties;
  • the categories of personal information that we sold or disclosed for a business purpose;
  • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
  • the business or commercial purpose for collecting or selling personal information.
  • In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

    Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

    We will not discriminate against you if you exercise your privacy rights.

    Verification process

    Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

    We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

    Other privacy rights

  • You may object to the processing of your personal information.
  • You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
  • You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
  • You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
  • To exercise these rights, you can contact us by email at info@northnodeapp.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

    12. DO WE MAKE UPDATES TO THIS NOTICE?

    In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

    We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

    13. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

    If you have questions or comments about this notice, you may email us at info@northnodeapp.com or by post to:

    NorthNode LLC
    3469 Fort Independence St
    Riverdale, NY 10463
    United States

    14. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

    You have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please submit a request form by clicking here.