PRIVACY POLICY

Last Updated: September 16, 2024

NTCN Global are committed to respecting your privacy and protecting your personal information, whether you are a customer, potential customer, or other user of our services (collectively, “you”). This Privacy Policy (this “Policy”) describes how NS Exchange collects, uses, and discloses personal information, and your choices regarding this information.

This Policy applies to our services, which include the services we provide on https://www.ntcnglobal.com/ or any other websites, pages, features, or content we own or operate (collectively, the “Sites”) or when you use our mobile app NS Exchange, any NTCN Global API or third-party applications relying on such an API, and related services (collectively, the “Services”).

Please read this Policy carefully and contact us with any questions at data_ns@pnsoftware.org. By using or accessing the Sites or Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we may collect, use, and disclose your personal information as set forth below.

Applicability Of This Policy

This Policy applies to NTCN Globals processing of any information or data that could potentially identify a specific individual (“Personal Information”) when using our Sites or Services.

If you do not agree with the terms of this Policy, do not access or use the Services, Sites, or any other aspect of our business.

When and How We Collect Information

We may collect the following information or data, which may be considered Personal Information, from you when:

Data you provide	Data we collect
You create an account with us You make a purchase or otherwise use our Sites or Services You contact us for customer service or other purposes, including via live chat You respond to one of our surveys, or participate in another feature of our Sites or Services You provide us with user content, ideas, information, user reviews, comments, feedback, or other submissions You identify yourself by completing our KYC form	You visit and interact with our app or website You create an account with us You view our newsletters or other email communications You interact with NTCN Global social media You click through a marketing promotion

Data you provide

Data we collect

You create an account with us
You make a purchase or otherwise use our Sites or Services
You contact us for customer service or other purposes, including via live chat
You respond to one of our surveys, or participate in another feature of our Sites or Services
You provide us with user content, ideas, information, user reviews, comments, feedback, or other submissions
You identify yourself by completing our KYC form

You visit and interact with our app or website
You create an account with us
You view our newsletters or other email communications
You interact with NTCN Global social media
You click through a marketing promotion

What Information We Collect

We collect the following categories of personal information:

Data you provide	Data we collect
Contact and Demographic Information: such as your full name, date of birth, gender, nationality, residential address, email address, and phone number. Identification Information: such as your driver’s license, federal/state ID card, Social Security Number, Tax ID number, photograph(s), or other government-issued ID information. Enhanced Due Diligence Information: including proof of address documents (e.g., bank, brokerage, and/or credit card statements, utility bills, mortgage statements, and/or property tax statements); employment or professional information (e.g., employer, job title/position, office location); and source of wealth (e.g., W2s, pay stubs). Financial Information: such as your bank account number, payment card information, transaction history, trading data, tax identification number (TIN), and/or source of wealth. Correspondence: such as your feedback, quiz, questionnaire, and other survey responses, and information you provide to our support teams, including via our live or any AI-supported chatbot(s). Stored Content: such as photos from your mobile phone gallery or contacts stored in your mobile device or email accounts. We only collect this information when you grant us permission in your device settings. You may withdraw this permission at any time. Audio, Electronic, or Visual information: such as photographs and video recordings. Biometric Data: such as facial recognition and facial geometry data derived from photographs or videos you submit to us during the onboarding process. We only use biometric data to verify your identity for security and compliance purposes. You can learn more about our biometric data practices in our Biometric Data Privacy Policy.	Transaction Information: including information about the transactions you make using our Services, such as the names of the recipient, transaction amount, and timestamp. Website Metadata and Analytics: including Internet Protocol (IP) addresses and location data, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages. Cookies and Other Tracking Technologies: We, and third parties we authorize, may use cookies, web beacons, and similar technologies (collectively, “cookies”) to record your preferences, track the use of our Sites, and collect information about the use of the Sites or Services, as well as about our interactions with you. This information may include IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages and operating system, date/time stamp, and clickstream data, and information about your interactions with the communications we send to you. We may combine this automatically collected log information with other information we collect about you. Learn more about our cookie use below, or see NS Exchange's Cookie Policy for additional details on how we handle cookies. Blockchain Data: We may analyze public blockchain data, including wallet addresses, transaction IDs, timestamps of transactions or events, transaction amounts, and digital signatures. Additional Information from Third-Party Sources: such as information about you from other sources as required or permitted by applicable law, including third parties such as credit bureaus, identity verification services, and public databases. We may combine the information collected from these sources with the information we get from our Sites or Services in order to verify your identity, comply with our legal obligations, and ensure our Sites and Services are not used fraudulently or for other illicit activities.

Data you provide

Data we collect

Contact and Demographic Information: such as your full name, date of birth, gender, nationality, residential address, email address, and phone number.
Identification Information: such as your driver’s license, federal/state ID card, Social Security Number, Tax ID number, photograph(s), or other government-issued ID information.
Enhanced Due Diligence Information: including proof of address documents (e.g., bank, brokerage, and/or credit card statements, utility bills, mortgage statements, and/or property tax statements); employment or professional information (e.g., employer, job title/position, office location); and source of wealth (e.g., W2s, pay stubs).
Financial Information: such as your bank account number, payment card information, transaction history, trading data, tax identification number (TIN), and/or source of wealth.
Correspondence: such as your feedback, quiz, questionnaire, and other survey responses, and information you provide to our support teams, including via our live or any AI-supported chatbot(s).
Stored Content: such as photos from your mobile phone gallery or contacts stored in your mobile device or email accounts. We only collect this information when you grant us permission in your device settings. You may withdraw this permission at any time.
Audio, Electronic, or Visual information: such as photographs and video recordings.
Biometric Data: such as facial recognition and facial geometry data derived from photographs or videos you submit to us during the onboarding process. We only use biometric data to verify your identity for security and compliance purposes. You can learn more about our biometric data practices in our Biometric Data Privacy Policy.

Transaction Information: including information about the transactions you make using our Services, such as the names of the recipient, transaction amount, and timestamp.
Website Metadata and Analytics: including Internet Protocol (IP) addresses and location data, device information, date/time of visits, new or returning visits, products viewed, page response times, URL clickstreams, how long you stay on our pages, what you do on those pages.
Cookies and Other Tracking Technologies: We, and third parties we authorize, may use cookies, web beacons, and similar technologies (collectively, “cookies”) to record your preferences, track the use of our Sites, and collect information about the use of the Sites or Services, as well as about our interactions with you. This information may include IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages and operating system, date/time stamp, and clickstream data, and information about your interactions with the communications we send to you. We may combine this automatically collected log information with other information we collect about you. Learn more about our cookie use below, or see NS Exchange's Cookie Policy for additional details on how we handle cookies.
Blockchain Data: We may analyze public blockchain data, including wallet addresses, transaction IDs, timestamps of transactions or events, transaction amounts, and digital signatures.
Additional Information from Third-Party Sources: such as information about you from other sources as required or permitted by applicable law, including third parties such as credit bureaus, identity verification services, and public databases. We may combine the information collected from these sources with the information we get from our Sites or Services in order to verify your identity, comply with our legal obligations, and ensure our Sites and Services are not used fraudulently or for other illicit activities.

How We Use Information

We use your information, including your Personal Information, in accordance with your instructions, including any applicable terms you agree to in our Terms of Use, and as required or restricted by applicable law. We may also use the information we collect for:

Providing Our Sites, Services and Features.We may use the information we collect to provide, personalize, maintain, and improve our products, Sites and Services, including as described in the Terms of Use. This includes using information to:
1. operate, maintain, customize, measure, and improve our Sites and Services, and manage our business;
2. create and update users’ accounts;
3. process transactions;
4. send information including confirmations, notices, invoices, technical notices, updates, security alerts, and support and administrative messages; and
5. to create de-identified or aggregated data.
Safety and Security. We may use your information to help maintain the safety, security, and integrity of our Sites and Services, including to:
1. protect, investigate, respond to, and deter against fraudulent, unauthorized, or illegal activity;
2. monitor and verify identity or service access;
3. protect against spam, malware, or security risks;
4. perform internal operations necessary to provide our Services, including to troubleshoot software bugs and operational issues;
5. enforce our agreements with third parties, and address violations of our Terms of Use or agreements for other services; and
6. comply with applicable laws and regulations.
Customer Support. We may use information we collect to provide customer support, including to:
1. direct questions to the appropriate customer support person;
2. communicate with you, including via social media channels;
3. investigate and address user concerns; and
4. monitor and improve our customer support responses and processes.
Research and Development. We may use the information we collect for testing, research, analysis, and product development to improve your experience, enhance the safety and security of our Sites and Services, improve our ability to prevent the use of our Sites or Services for illegal or improper purposes, develop new features and products, and facilitate payment solutions in connection with our Sites and Services.
Legal and Regulatory Compliance. Many of our Sites and Services are subject to laws and regulations requiring us to collect, use, and store your personal information in certain ways. For example, we must identify and verify customers using our Sites or Services in order to comply with anti-money laundering and anti-terrorism laws. This may include collection and storage of your photo identification. We also use third parties to verify your identity by comparing the personal information you provide against third party, authoritative sources and databases, including public records. When you attempt to link a bank account to your 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 as required under applicable law. If you do not provide information required by law, we will have to close your account. We may also use the information we collect to investigate or address claims or disputes relating to use of our Sites and Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
Direct Marketing. We may use the information we collect to market our Sites and Services to you. This may include sending you communications via emails or mobile app notifications about our Sites, Services, features, promotions, surveys, news, updates, and events; managing your participation in these promotions and events; and to deliver targeted marketing. Our marketing will be conducted according to your advertising and marketing preferences and as permitted by applicable law.

How and Why We Disclose Information

We may disclose your information, including your Personal Information, in the following circumstances:

With Your Consent. You may permit us to disclose your personal information with others for any other purposes disclosed to you with your consent.
With Our Affiliates. Where appropriate, we may disclose your information with NTCN Global, and its wholly-owned subsidiaries and/or affiliates in the course of conducting business and offering our Services to you. For more information, please refer to our Law Enforcement Guide.
To Comply With Our Legal Obligations. We may disclose your information with courts, law enforcement authorities, regulators, attorneys or other parties: (A) to comply with laws and legal obligations; (B) for the establishment, exercise, or defense of a legal or equitable claim; (C) to respond to law enforcement and regulatory requests, including (1) when we are compelled to do so by a subpoena, court order, search or seizure warrant, or similar legal procedure, or (2) for international law enforcement requests, pursuant to a mutual legal assistance treaty or letter rogatory; (D) to comply with one or more forms of “travel rules” that require our transmitting of your information to another financial institution; (E) when we believe in good faith that the disclosure of personal information is necessary to protect the rights, property or safety of our customers, us, or others, including to prevent imminent physical harm or material financial loss; (F) to investigate violations of our Terms of Use or other applicable policies; or (G) to report suspected illegal activity or to assist law enforcement in the investigation of suspected illegal or wrongful activity.
With Third-Party Identity Verification Services. We may disclose your information with third party identity verification service providers for the purposes of identity verification, fraud prevention, and denial of service to persons presenting an unacceptable level of money-laundering or terrorism-financing risks. These service providers confirm your identity by comparing the information you provide us to public records and other authoritative third-party databases (e.g., credit bureaus). These providers may create derivative data based on your personal information that they can use in connection with provision of identity verification and fraud prevention services. We do not control these providers’ privacy policies and we contractually require these service providers to only use your information in accordance with our legal agreements.
With Service Providers. We may disclose your information on a confidential basis with service providers who help facilitate business operations such as payment processing, marketing, security, or information technology services. Our legal agreements require these service providers to only use your information according to our instructions.
With Financial Institutions. We may disclose your information with financial institutions to process payments you have authorized.
With Our Professional Advisors. We may disclose your information with our professional advisors such as accountants, auditors, lawyers, insurers, bankers, and blockchain forensic services in order to complete third party audits and/or to comply with our legal and regulatory obligations.
With Other NS Exchange Users. We may disclose your information with other users when use our Pay feature to send, request, or receive cryptocurrency.
During A Change To Our Business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your information may be disclosed or transferred.
Aggregated or De-identified Data. We may create de-identified or anonymous data from Personal Information by removing certain data components (such as your name or email address) that makes the data personally identifiable to you, or through obfuscation. We may disclose aggregated and/or anonymized data with third parties for their own uses.

International Transfers

Our retail Services are directed and offered only to individuals within supported regions in the India. Our institutional Services are available to companies, or companies with beneficial owners, that may be located outside of the India. All data is stored in India using Hostinger Cloud Services. As such, if you are a non Indian resident, we may transfer to, and store the data we collect about you, to countries other than the country in which the data was originally collected, including the India. Those countries may not have equivalent data protection laws as the country in which you provided the data. When we transfer your data to other countries, we will protect the data as described in this Privacy Policy and comply with applicable legal requirements providing adequate protection for the transfer of data to countries outside India. We rely on Standard Contractual Clauses (“SCCs”) for the transfer of personal data (as defined by the General Data Protection Regulation, or “GDPR”) to countries that have not received an applicable adequacy decision. By using the Site and Services you agree to the privacy practices laid out in this Policy.

For more information on cross-border transfers of your Personal Information, the appropriate safeguards in place, please contact us via Email, support@nsexchange.org.

Security

We maintain administrative, technical, and physical safeguards (“Security Controls”) designed to protect the personal information we maintain against unauthorized access or disclosure. While no system is completely secure due to real-time and emerging cyber threats and bad actors, we take reasonable steps to secure your information. When registering for our Sites or Services, choose a complex password and turn on advanced security features, such as two-factor authentication. Never share your account credentials with third-parties and submit a Customer Support ticket here if you become aware of unauthorized access to or use of your account.

You are responsible for all activity on the account that is associated with your login credentials.

Data Retention

NS Exchange retains your Personal Information for as long as is necessary for the purposes set out in this Privacy Policy and to the extent necessary to comply with our legal and regulatory obligations (i.e., if we are required to retain your data or the information you provided to us to comply with applicable laws, including anti-money-laundering, anti-terrorism, or other financial laws and regulations). In addition, we will retain and use your personal information to resolve disputes and enforce our legal agreements and policies.

To determine how long we will retain your personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and applicable legal, regulatory, tax, accounting, or other requirements.

NS Exchange will retain your Personal information for marketing purposes, where applicable, until you unsubscribe from our marketing communications. At that time, we may retain the Sites and Services’ usage data for internal analysis purposes.

Your Privacy Rights

It is NS Exchange's policy to offer certain privacy rights to all individuals, regardless of whether a statutory right exists. The rights that NS Exchange offers to all individuals include the following:

Right to Know. You have the right to request what Personal Information we collect, use, disclose, or share about you, as applicable.
Right to Access/Portability. You can request access to and/or a copy of the personal information that we maintain about you.
Right to Delete. You can ask us to delete the Personal Information that we have collected or maintain about you, subject to exceptions. Please note that we are required to retain certain Personal Information and related data to comply with our legal obligations, including compliance with recordkeeping requirements contained in anti-money laundering, anti-terrorism, or other financial laws and regulations.
Right to Correct. You can ask us to correct inaccurate personal information we maintain about you.
1. You can update certain account profile information by logging into your account.

You can exercise these rights by contacting us at support@nsexchange.org. To protect your privacy and security, we may request specific information from you to help us verify your identity before complying with your request. We are not obligated to provide or to delete any information pursuant to your request if we are unable to adequately verify your identity.

We reserve the right to lawfully refuse to act on a request, or to charge a reasonable administrative fee when a request is either manifestly unfounded or excessive because of its repetitive character.

Online Tracking

Like many companies, we use cookies, pixels, web beacons, SDKs, and other tracking technologies (“cookies”) to collect information about your browsing activities, your interactions with websites (including our Sites) and apps (including our mobile app), and to serve tailored ads.

Mobile Privacy

The NS Exchange app uses software code provided by our business partners (software development kits or SDKs) that let our software interact with the services those partners provide. Sometimes these interactions will involve that business partner collecting some information from the device on which the software is run.

Children’s Privacy

We do not allow use of our Services and Sites by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with Personal Information, please contact us at support@nsexchange.org and we will take steps to delete such information, close any such accounts, and prevent the user from continuing to use our Services.

Links to Third-Party Sites

Our Services or Sites may contain links to other websites or services. We do not exercise control over the information you provide or is collected by these third-party websites. We encourage you to read the privacy policies or statements of the other websites you visit.

Changes To This Policy

We may update this Privacy Policy from time-to-time as we update or expand our Services or Sites and to comply with applicable laws. If we make any changes, we will change the Last Updated date above. We encourage you to review this Policy to stay informed. If we make material changes, we will provide additional notice, such as via the email specified in your account or through the Services or Sites.

Contact Us

Please contact us if you have any questions about this Policy or if you are seeking to exercise any of your privacy rights. You may contact us at support@nsexchange.org.