How We Collect Information About You
When you use Nagaya Services, we collect information sent to us through your computer, mobile phone, or other access device. This information may include your IP address, device information including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website. Nagaya does not intentionally collect information from or about any individual who is under 13 years old.
If you create an account or use Nagaya Services, we, or our affiliates vendors acting on our behalf may collect the following types of information: Contact information - your name, address, phone, email, Skype ID, and other similar information;
If you seek permission to raise Digital Currency buy and sell limits associated with your Nagaya Account, we may require you to provide additional information which we may use in collaboration with service providers acting on our behalf to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal information. We may also obtain information about you from third parties such as credit bureaus and identity verification services.
When you use Nagaya Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect information about your computer, mobile device, or other access device for fraud prevention purposes, to monitor for possible breaches of your Nagaya Account, and to identify any malicious software or other activity that may harm Nagaya or its users.
Finally, we may collect additional information you may disclose to our customer support team.
When you access our website or content or use our application or Nagaya Services, we or the companies we work with may place small data files called cookies or pixel tags on your computer or other devices. We use these technologies to:
Recognize you as a Nagaya customer;
Customize Nagaya Services, content, and advertising;
Measure promotional effectiveness; and
Collect information about your computer or other access device to mitigate risk, help prevent fraud, and promote trust and safety.
We use both session and persistent cookies when you access our website or content. Session cookies expire and no longer have any effect when you log out of your account or close your browser. Persistent cookies remain on your browser until you erase them or they expire.
We also use Local Shared Objects, commonly referred to as "Flash cookies," to help ensure that your account security is not compromised, to spot irregularities in behavior to help prevent fraud, and to support our sites and services.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser or browser add-on permits, but doing so may interfere with your use of Nagaya Services. The help section of most browsers or browser add-ons provides instructions on blocking, deleting, or disabling cookies.
How We Protect and Store Personal Information
We store and process your personal and transactional information, including certain payment information, where Nagaya facilities or our service providers are located, including in the United States of America, and we protect it by maintaining physical, electronic, and procedural safeguards in compliance with applicable laws. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. We store our customers' personal information securely throughout the life of the customer's Nagaya Account. Nagaya will retain your personal information for a minimum of five years or as necessary to comply with our legal obligations or to resolve disputes.
You may request access or make corrections to your personal data held by Nagaya. Nagaya may charge a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
Please contact us (please see the “How to contact us” section below) for details on how you may request such access or corrections.
How We Use The Personal Information We Collect
Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information for matters such as:
Provide Nagaya Services and customer support you request;
Process transactions and send notices about your transactions;
Resolve disputes, collect fees, and troubleshoot problems;
Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
Carrying out research, planning, and statistical analysis;
Analytics for the purposes of developing or improving our products, services, security, service quality, and advertising strategies;
Managing our infrastructure and business operations and complying with internal policies and procedures;
Complying with all applicable laws, regulations, rules, directives, orders, instructions, and requests from any local or foreign authorities, including regulatory, governmental, tax, and law enforcement authorities or other authorities;
Enforcing obligations owed to us; and/or seeking professional advice, including legal advice;
Customize, measure, and improve Nagaya Services and the content and layout of our website and applications;
Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences; and
Verify your identity by comparing your personal information against third-party databases.
We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or Nagaya Services may not be available to you.
We will never sell or rent your personal information to third parties.
Any communications we send to you will either be related to your account or will be related to Nagaya services or products. In the event Nagaya sends any communication to you which is not related specifically to your account, Nagaya will provide you with an "unsubscribe" mechanism through which you may opt out of receiving other similar messages in the future.
We may use your personal data to offer you products or services, including special offers, promotions, contests, or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile, and other mobile messaging services. In doing so, we will comply with the Personal Data Protection Act of Singapore (PDPA).
In respect of sending telemarketing messages to your telephone number via short message service, telephone calls, facsimile, and other mobile messaging services, please be assured that we shall only do so if we have your clear and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry. If we have an ongoing relationship with you and you have not indicated to us that you do not wish to receive telemarketing messages sent to your telephone number, we may send you telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call).
You may at any time request that we stop contacting you for marketing purposes via selected or all modes.
To find out more about how you can change the way we use your personal data for marketing purposes, please contact us. Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.
How Personal Information is Shared With Other Nagaya Users
If you use your Nagaya Account to transfer Digital Currency in connection with the purchase or sale of goods or services, we or you may also provide the seller with your shipping address, name, and/or email to help complete your transaction with the seller. The seller is not allowed to use this information to market their services to you unless you have agreed to it. If an attempt to transfer Digital Currency to your seller fails or is later invalidated, we may also provide your seller with details of the unsuccessful transfer. To facilitate dispute resolutions, we may provide a buyer with the seller's address so that goods can be returned to the seller.
In connection with a Digital Currency transfer between you and a third party, including merchants, a third party may share information about you with us, such as your email address or mobile phone number which may be used to inform you that a transfer has been sent to or received from the third party. We may use this information in connection with such transfers to confirm that you are a Nagaya customer, that Digital Currency transfers are enabled, and/or to notify you that you have received Digital Currency. If you request that we validate your status as a Nagaya customer with a third party, we will do so. You may also choose to send Digital Currency to or request Digital Currency from an email address. In such cases, your user name will be displayed in an email message notifying the user of the designated email address of your action. Please note that merchants you interact with may have their privacy policies, and Nagaya is not responsible for their operations, including, but not limited to, their information practices.
If you authorize one or more third-party applications to access your Nagaya account, then the information you have provided to Nagaya may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions using Nagaya services.
How We Share Personal Information With Other Parties
We may share your personal information with parties such as the following:
Third-party identity verification services in order to prevent fraud. This allows Nagaya to confirm your identity by comparing the information you provide us to public records and other third-party databases. These service providers may create derivative data based on your personal information that can be used solely in connection with the provision of identity verification and fraud prevention services;
Service providers under contract who help with parts of our business operations such as bill collection, marketing, and technology services. Our contracts require these service providers to only use your information in connection with the services they perform for us, and prohibit them from selling your information to anyone else;
Financial institutions with which we partner;
Law enforcement, government officials, or other third parties such as when: (i) We are compelled to do so by a subpoena, court order, or similar legal procedure; or (ii) We believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement; and
Other third parties
Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.
If you establish a Nagaya account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a Nagaya website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.
In general, we will notify you of material changes to this policy by updating the last updated date at the top of this page, and we will provide you with explicit notice of material changes as required by law. We recommend that you visit this page frequently to check for changes.
Specific Consent by Users in The European Economic Area
If you are located in, or a resident of, the European Economic Area ("EEA"), you specifically and voluntarily consent to the transfer of your personal information to our related entity and service providers in Singapore, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.
You may revoke your consent to this section at any time by emailing email@example.com with the subject line "Revoke EEA data consent". How you can access or change your personal information.
How You Can Contact Us About Privacy Questions
If you have questions or concerns regarding this policy, or if you have a complaint, you should contact us on our support page, by emailing firstname.lastname@example.org.