Terms &
Conditions
General Terms of Use of The Website
Welcome to https://naka.com/, a website operated by NAKA GLOBAL Ltd., a company registered in Slovenia under company registration number 9244557000 (“NAKA”). If you wish to pay us a visit, we are located at the address Letaliska cesta 33F, 1000 Ljubljana, Slovenia, EU.
These are the General Terms of Use of this website (“General Terms”). Their aim is to present the basic rights and obligations between you as a visitor and us as operators of this website. The General Terms are drawn up in accordance with Slovenian and EU legislation and are binding for any visitor of this website. Getting acquainted with the General Terms is important for you not to use this website for any unlawful, illegal, unethical, or inconsistent purpose (whether intentionally or unintentionally).
If you do not fully understand any provision of these General Terms, we advise you to consult us before starting to use this website. We will be very happy to answer all your questions and clarify any possible ambiguities. We are available at the e-mail address support@naka.com. We recommend that you occasionally review the General Terms and the Personal Data Protection Notification because the two documents together form the agreement between you and us regarding the use of this website.
Acceptance of the General Terms of Use
From the moment you start using this website independently, it is considered that you accept the content of these General Terms. These General Terms apply exclusively to the use of this website and do not regulate any other legal relations between you and us or between you and our contractual partners or third parties respectively.
Payment Services and Other Services
All information governing the use of NAKA Service or other services is covered by business agreements between the user and the provider of such services. The provider of these services can be NAKA, its contractual partners or third parties. Contact the relevant service provider for such information.
Copyright
This website is the intellectual property of NAKA or its contractual partners and as such subject to copyright or other forms of intellectual property protection. In addition to the text and data on the website, the entire visual identity with all the visual elements is also considered legally protected property. NAKA or its contractual partners are the copyright holder in connection with this website; as a user, you are granted a personal, temporary, non-exclusive, and non-transferable right to commercial use of the website in accordance with these General Terms. Commercial use allows the use of the documents on the website including copying, transcribing, reproduction, modification, or any kind of dissemination of the information, but only for internal use within your business, in which the documents must preserve all the notices regarding copyrights or other rights that are stated therein. Any attempt to tamper with, damage or cause permanent or temporary unavailability of the data on this website is punishable.
The trademarks and service marks published on this website are our registered trademarks or we possess exclusive rights to their use.
Limitation of Liability
Our fundamental principle is to try to the best of our ability and with due diligence to make the information on this website as accurate and current as possible; nevertheless, please note that all the texts and data are for informational purposes only.
The website with all its applications is accessible continuously (24 hours a day, 365 days a year) except in case of events beyond our control or for technical reasons (e.g., website maintenance), when short periods of disrupted access or functioning of the website can occur. Notifications on planned longer interruptions will be published on the website or through other communication channels ahead of time.
Please note that you use this website at your own risk. Neither we nor any other legal or natural person who has participated in the creation of this website is responsible for the damages and / or loss of profit that could be incurred:
- Due to using inaccurate or incomplete information.
- As a consequence of an event beyond our control or an event that cannot be avoided, stopped or averted.
- Due to occasional non-functioning of the website.
- Due to the data acquired through online links that are published on our website but are not our property.
We recommend you to ensure suitable software protection measures for uninterrupted and safe data access (e.g. protection against hacking, viruses and other malware).
Changes to General Terms
Due to constant development and improvements, certain changes of and / or amendments to these General Terms are occasionally required. In such cases, we reserve the right to change the provisions of these General Terms without prior notification. You will be suitably notified of any substantial changes in due course, e.g., by e-mail or through a website notification. If you find the provisions of the changed General Terms unsuitable for you, we advise you to no longer use the website from that point onwards.
Violation of General Terms
It is in our interest for this website to provide you with as pleasant user experience as possible as well as with ample useful information, which can be achieved by using the website in accordance with these General Terms. However, in the event of a violation of these General Terms and / or unauthorized use of this website, we reserve the right to take action in a manner considered appropriate, e.g., by reporting the suspected illegal actions to the competent law enforcement authorities, control authorities or other authorized entities.
If so necessary or required by the applicable legislation, the aforementioned authorities will reveal all the necessary information, e.g. names, e-mail addresses, IP addresses, search history, etc., in accordance with the Personal Data Protection Notification.
Applicable Legislation
For any questions regarding the implementation and interpretation of these General Terms, the law of the Republic of Slovenia shall apply. Any disputes arising from the violation of these General Terms are settled by NAKA in an amicable manner. If that is not possible, the competent court is the Court of Ljubljana.
Contact
If you have any questions or comments in connection with these General Terms, we are available at support@naka.com.
These General Terms enter into force on 18 September 2023.
NAKA GLOBAL Ltd.
Privacy
Policy
Personal Data Protection Notification
At NAKA GLOBAL Ltd., we strive for continuous development and improvement of our services as we want to adapt them to your requirements as much as possible. In order to achieve this, we need to collect and process certain personal data in some cases.
The purpose of this Personal Data Protection Notification (“Notification”) is to make you acquainted with what kind of personal information we collect and for what purposes, what we do with them, how we ensure their security, and what rights you can exercise in connection with the processing of your personal data. We treat the protection of your personal data with the utmost seriousness and responsibility. We fully comply with our obligations regarding lawful, fair, and transparent personal data processing. We advise you to get yourself fully acquainted with the contents of this Notification.
In order to ensure the compliance of this Notification with the regulations governing personal data protection, NAKA reserves the right to modify or amend the Notification accordingly. You will be suitably notified of any changes in due course, e.g., by e-mail or through a website notification.
Who is Responsible for Controlling your Personal Data
The controller of the personal data processed in accordance with this Notification is NAKA GLOBAL, financial technologies, Ltd. (“NAKA”), company registration number 9244557000, with a business address at Letaliska cesta 33F, 1000 Ljubljana, Slovenia. If you have any questions or requirements regarding the processing of your personal data, please contact us at support@naka.com.
In What Case do we Process your Personal Data
We only collect your personal data when this is absolutely necessary or when you have given your consent. We will not process your personal data if the purpose of or basis for their processing is not supported by the applicable regulations in the field of personal data protection (the Personal Data Protection Act, the Official Gazette of the Republic of Slovenia No. 94/07 – official consolidated version and 163/22 (“ZVOP-2”) and Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”)) and our internal policies.
1. We only collect your personal data:
- when this is absolutely necessary or when you have given your consent,
- for which we are required by applicable laws,
- which is necessary for the performance of a contract,
- for statistical purposes,
- for identifying server problems and for website editing,
- for verification procedures (“Know Your Customer” or “KYC”) required by applicable anti-money laundering legislation,
- for business analyses,
- for offer development,
- for information system security,
- for improving or adapting the services to the individual,
- for measuring the efficiency of its promotional activities and advertising,
- on the basis of other legitimate interests.
2. By visiting our website you accept and agree with the General Terms of Use of our website and enter into an agreement with NAKA and/or you entered (or you are in the process of entering) into an agreement for the use of the NAKA Service, which constitutes a contractual basis for processing your personal data. The data is coded and transferred to the server in a protected format. Such a system prevents your personal data from being intercepted.
3. During one's visit, NAKA also collects one's personal data through cookies, based on the legitimate interests for the purpose of improving the functionalities, user experience, safety, for smooth website functioning and for counting its website visitors. All further information on the use of cookies is accessible at the following link.
How Do We Collect Your Personal Data And What Kind Of Personal Data Do We Process?
We acquire personal data from various sources. In most cases, you directly provide them to us by visiting our website, during KYC procedures, by filling out online forms for customer identification and verification and/or subscribing to our newsletter. We can also use other information and data accessible through or provided by public sources (public registers, databases, internet applications, social media).
NAKA processes the following types of personal data:
1. personal and contact information
This includes all the personal data you provide when filling in online forms or communicating with us by phone, e-mail or in any other way. It also includes all the data you provide for the requirements of KYC procedures or when you fill out the form for entering into an agreement with us or other service provider on the website, subscribe to our newsletter, or report any kind of problem that arises during your visits to our website. In such cases, we collect and save data which can include your name, e-mail address, phone number, nationality, tax identification number, number of the identification document, and other provided data.
We will process your personal information to notify you of updates and upgrades until you terminate your user account. The personal data that we process to send offers and notifications on novelties is kept until your consent withdrawal or, in any case, for a maximum period of 5 years from your consent. After that period, we will again ask you for your consent.
2. server data
When you use our website, we collect various data in the server log, i.a.: the dates and times of the visits; the visited subpages; your IP address; time zone settings; the time you have spent on our website: the websites you visit immediately before or immediately after visiting our website; screenshots of clicks on our website; the information you viewed or sought; webpage response time; downloading errors; the lengths of the visits to individual webpages and data on webpage interactions.
3. device data
We collect data on the computer or mobile device which you use to access our website, including its model, the operating system and version of your software, the Internet browser used and other identifiers of your device.
4. data on contacts with us
We keep records of your contacts with us, especially of the dates (sometimes also times) of the contacts and the reasons for them. This holds for all kinds of contacts (phone, SMS, regular mail, e-mail, live).
5. geolocation data
Geolocation data or GPS coordinates (longitude, latitude) are acquired at your visit to our website so that we can help you find the most suitable end product and / or service. NAKA processes location data in a form that cannot be connected to a specific or identifiable person, or on the basis of prior user consent.
6. data from social networks
In our marketing campaigns, we also use social media (e.g. Facebook) and, although we do not keep the data published on your profile, we use it for targeted marketing activities, but only if you consent to this during your use of the aforementioned media. In the scope of third-party cookies, we also offer user service improvements, content dissemination through various social media, and personalization of our offer according to your wishes and requirements which are evident from your previous web browsing. Despite all of our efforts, we can not guarantee the security of the content of the connected external websites or check such content. You, therefore, click external links at your own risk. We are not liable for any damages or implications resulting from visiting any aforementioned external link. If you follow a link to another website, you thereby leave our website and this Personal Data Protection Notification does not apply to your use of other websites or your activities on them.
Who Can Use The Personal Data That You Provide For Us?
Your personal data will only be revealed to those third parties that will process your personal data on our behalf. The third parties are our parent and/or subsidiary entities and our contract partners performing user analysis, e-mailing, consulting, direct marketing as well as data collecting and storing services on our behalf. Your personal data constitutes a business secret of NAKA. NAKA’s employees process your personal data in accordance with their authorizations and our internal policies. The contracted data processors are obliged to protect confidential data and respect the rights of individuals in the same manner as NAKA’s employees, therefore, your data is safe.
Where we transfer your personal data outside the European Economic Area, we will ensure that it is protected and transferred in a manner consistent with the legal requirements applicable to personal data. This can be done in a number of different ways, for instance:
1. The country to which we send your personal data was approved by the European Commission;
2. The recipient of your personal data signed a contract based on “Model Contractual Clauses” approved by the European Commission, obliging them to protect your personal data.
In all other circumstances, the law may permit us to otherwise transfer your personal data outside the European Economic Area. In all cases, however, any transfer of your personal data will be compliant with the applicable data protection legislation.
In the scope of our legal obligations, we may communicate your personal data to the regulatory authorities for the purposes of discovery and prevention of money laundering and terrorist financing as well as for prevention and investigation of abuse or fraud in connection with the use of the NAKA Service.
How Will Your Personal Data Be Protected?
In order to protect personal data, NAKA will use all the organizational, technical and other suitable procedures and measures necessary to prevent unauthorized data destruction, modification, loss or any unauthorized processing. Among others, these measures can include internal rules on personal data protection, additional employee training, internal controls of processing activities, etc. Other possible measures can include minimization of personal data collection, pseudonymization, transparency, enabling individuals to monitor the processing, as well as continuous safety measure upgrades.
How Long Do We Keep Your Personal Data?
The period of keeping your personal data depends on the basis and purposes of processing an individual personal data category. Personal data is only kept for as long as this is legally required or allowed and absolutely necessary to achieve the purpose for which the data has been collected or processed. After achieving the purpose, we will only keep the personal data we are legally obliged to keep, or we might need for evidence or defense purposes in case of a possibility of legal claims. The rest of the data is erased, blocked, or anonymized unless otherwise legally required for certain types of data.
The personal data that we process to send offers and notifications on novelties is kept until your consent withdrawal or, in any case, for a maximum period of five years from your consent. After that period, we will again ask you for your consent.
Applicable Legislation
You can always request to view or access your personal data, or request its correction or erasure, or restrict or object to its processing. We will notify you if your request affects the possibility of further operation of the website or our business collaboration. In certain cases, you also have the right to data portability of your personal data to a different controller. This depends on the technical capacities and internal policies of individual controllers.
Your consent to the processing of personal data for the purpose of sending offers and novelty notifications may be withdrawn at any time; however, the withdrawal of your consent does not affect the lawfulness of the processing of your personal data on the basis of your consent for the period prior to the withdrawal.
NAKA does not take responsibility for the credibility, accuracy, and promptness of the personal data you provide. You as a user are yourself obliged to ensure the accuracy and promptness of all the data you provide.
In the event of a violation of protection of your personal data, we will notify you in accordance with the conditions laid down by the applicable legislation.
Your requests will be fulfilled without undue delay, but in any case, within one month of the receipt of your request unless otherwise provided by the applicable legislation. In the event of complexity and a large number of requests, this time limit may be extended by up to two months. We will notify you of any such extension within one month of receiving your request, together with the reasons for the delay.
If you believe that we do not process your personal data in accordance with the applicable legislation, you can file a complaint with the Slovenian Information Commissioner at the e-mail address gp.ip@ip-rs.si or by regular mail to Information Commissioner of the Republic of Slovenia, Dunajska cesta 22, 1000 Ljubljana, Slovenia. Nevertheless, we will greatly appreciate it if you communicate your misgivings, comments, or suggestions to us prior to contacting the Information Commissioner.
Do You Need To Know Anything Else?
This Notification is published on our website and enters into force on 18 September 2023.
In addition to this Notification, we also advise you to read the General Terms of Use of our website, which are published on our website and together with this Notification form a binding agreement between you and NAKA.
This notification may be changed at any time if this is necessary due to a change of personal data processing or due to a new interpretation, decision or opinion in connection with the personal data processing legislation. Any notification changes will be communicated to you in advance.
This Notification enters into force on 18 September 2023.
NAKA GLOBAL Ltd.