Noticies and Policies

Terms &
Conditions

General Terms of Use of The Website

1 October 2025

Welcome to https://naka.com/, a website operated by NAKA CH Sagl, a company registered in Switzerland under company registration number CHE-327.549.674 (“NAKA”). If you wish to pay us a visit, we are located at the address Crocicchio di Cortogna 6, 6900 Lugano, Switzerland.

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 the Swiss legislation and are binding for any visitor of this website. Getting acquainted with the General Terms is important for you in order 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

The services described or presented on this website (the "Services") may be provided by NAKA directly, or through its affiliated companies, contractual partners, or other third parties. Specifically, payment services are provided by NAKA's contractual partners, while card issuing services are provided by its affiliate, NAKA SLV, S.A. de C.V. (a regulated entity operating under the laws of El Salvador).

Your use of the Services is governed by separate business agreements between you and the specific service provider for each Service. For more information, please contact the relevant service provider directly.

Copyright And Other Intellectual Property Rights

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 (i) a private and/or (ii) a commercial use of the website in accordance with these General Terms. Private use entails the use of the website for non-commercial purposes, e.g., getting informed on the services provided by NAKA and its affiliates. 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, unless where explicitly indicated otherwise. In certain cases, trademarks and service marks on this website are shown for demonstrative purposes solely (to indicate type of services and similar).

You are strictly forbidden from using any of NAKA’s brands (including trademarks and other product and services brand names) for purposes other than allowed under these General Terms before obtaining a prior written authorization by NAKA. Even if you have obtained a prior written authorization by NAKA for any type of use, you are required to include a proprietary notice (e.g., copyright notice) and other referrals to NAKA or other rightful proprietor of the brand or a part thereof. In this case as well, you are granted a personal, temporary, non-exclusive, and non-transferable right to use. Any unauthorized or unreferred use shall be interpreted as a violation of intellectual property or other laws.

If you link any of the materials from this website or a part thereof onto your own website, you are required to include a notice that such link does not constitute an endorsement of your content by NAKA. In any case we reserve (i) the right to revoke any such license in cases we deem reasonable (for instance when the content of your webpage is not aligned with our values) under the conditions included in our notification on revoking the license and (ii) other rights granted under the applicable law.

THIRD-PARTY MATERIALS: This website may contain links to third-party websites or other types of intellectual property rights (e.g., trademarks, logos, brand names, designs), including advertisement links (“Materials”). All such Materials are provided solely for your convenience or easier reference and do not represent an endorsement by NAKA of the content contained in or provided at such third-party websites. All Materials are the property of their respective owners and NAKA, as a rule, does not exercise any kind of control over such third-party Materials. Therefore, you are accessing such third-party Materials at your own risk and liability. It is recommended to read and understand terms and conditions provided by the respective third parties.

All third-party Materials on this website are shown for indicative and/or demonstrative purposes only. Such third-party Materials are used to indicate the type of companies, products or services, as applicable. All third-party Materials (including without limitation all trademarks, logos and brand names) are the property of their respective owners. In no way does the display of such third-party Materials constitute reference to actual companies, products or services or endorsement of any kind by such third parties, unless otherwise explicitly indicated otherwise.

Use Of Technology and Security Of Services

The technologies used to deliver the Services, including but not limited to payment infrastructure and digital platforms, are licensed from third-party providers or affiliated companies, including NAKA's parent company, NAKA GLOBAL d.o.o. (NAKA GLOBAL Ltd.), based in Slovenia. These technology partners retain ownership of the underlying systems and are responsible for maintaining the security, reliability, and compliance of their solutions.

NAKA is committed to providing secure, dependable, and uninterrupted services through a robust and reliable framework. We place a strong emphasis on the security of all information technology solutions used to deliver these Services. Therefore, NAKA requires all its contractual partners—whether they are outsourcing parties or direct service providers to NAKA's clients—to adhere to the highest security standards applicable in their respective industries, including the FinTech industry.

For example, NAKA GLOBAL Ltd. implements extensive information security controls and measures. These comply with international standards: ISO 9001:2015 (Quality Management Systems), ISO 27001:2022 (Information Security Management Systems), and ISO 22301:2019 (Business Continuity Management Systems), for which NAKA GLOBAL Ltd. holds official certifications from the respective issuing authorities.

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.

- Because 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 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 act 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 be revealed 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 Switzerland shall apply to the highest extent allowed under the mandatory conflict of laws rules. 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 with subject matter jurisdiction, unless specifically required otherwise under the mandatory rules.

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 1 October 2025.

NAKA CH Sagl

Cookie
Policy

Cookies

1 October 2025

As a controller of your personal data, NAKA CH Sagl, registered in Switzerland under company registration number CHE-327.549.674 and with a business address at Crocicchio di Cortogna 6, 6900 Lugano, Switzerland (“NAKA”), uses cookies on this website.

What are Cookies?

Cookies are small text files that are downloaded to your device when you visit a website and usually contain the name of the server from which the cookie was sent, the cookie’s expiration time and its value (a randomly generated unique number).

The cookie itself does not contain or collect information. However, if read by a server together with a web browser, the cookie can help the website to provide more user-friendly services, e.g., to remember your username and password for future registration. Cookies are not harmful and are always time limited.

The Purpose of Cookies

The purpose of cookies is primarily to improve website functioning and the user experience in website viewing. Cookies make the interaction between you and a website faster and easier. This saves time and makes website viewing more efficient.

NAKA's Cookies

NAKA uses both essential and non-essential cookies. While non-essential cookies are not necessary for the provision of our service (e.g., browsing our website), but merely serve to enhance your user experience or help us gain insight into the functionalities of our service, without the essential cookies our service, which you accessed to, cannot function properly. As a result, you can choose not to allow the non-essential cookies to be stored onto your device, while opting-out of essential cookies is not possible. Non-essential cookies include: (i) marketing cookies, (ii) analytics cookies and (iii) preference cookies.

Some cookies we use are temporary (also known as session cookies), but some are saved on your device for a certain time also after you have left our website. We use temporary cookies to measure the number of our website visitors, which helps us check the efficiency of our content display and enables continuous website improvement. Persistent cookies, however, enable us to save your contact information for subsequent website visits, so that you don’t need to sign in any longer or that the website content display adjusts to your device. We also use saved cookies originating from other sites like Facebook, X, Google, etc.

In addition to these, we also use cookies to determine how you navigate our webpages, what content you are interested in and how long your visits last. Based on this, we can shape the content of our webpages and adjust it to your requirements.

The data collected through cookies is processed exclusively for statistical purposes and for collecting demographic data and visitor interests (but only in such a way that your identity cannot be revealed), for identifying server problems and for webpage editing.

Privacy is important to us, so you have the option of disabling all or some of the non-essential cookies, that is, those that may not be necessary for the basic functioning of the website.

You have an option not to allow any of the below stated category of non-essential cookies not to be stored on your device (the choice can be made in the cookie banner, by clicking to “Cookies preferences” button):

Styled 4-Column Table
Analytics Cookies Uses Type Expiration
_ga Registers a unique ID that is used to generate statistical data on how the visitor uses the website – to distinguish the users. External Per session
_ga_ Used to persist session state (in relation to the _ga). External Per session
_hjSession Used to determine the behaviour during a single browsing session to help website owners analyse interactions (e.g., navigation patterns, form abandonment). External Per session
_hjSessionUser The cookie is set when the customer first lands on a page with the Hotjar script. It is used to persist the Hotjar User ID, unique to that site on the browser. This ensures that behaviour in subsequent visits to the same site will be attributed to the same user ID. External 365 days
fs-cc Technical cookie is used to for the site to function properly. Internal 180 days
fs-cc-updates Technical cookie is used to for the site to function properly. Internal 180 days

Analytics cookies help NAKA understand how its website performs, how visitors interact with the site, and whether there may be technical issues.

Styled 4-Column Table
Marketing Cookies Uses Type Expiration
_gcl_au Google Ads, Google AdSense Cookie is used to store and track conversions. Used for conversion tracking (measuring the effectiveness of ads). It helps advertisers attribute conversions (e.g. purchases, sign-ups) to specific clicks on an ad. Part of Google's Conversion Linker system, which provides accurate conversion data. Does not store personal data - just a random unique attribution ID. External Per session
fs-cc Technical cookie is used to for the site to function properly. Internal 180 days
fs-cc-updates Technical cookie is used to for the site to function properly. Internal 180 days

Marketing cookies are used to deliver advertising that is more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns.

Styled 4-Column Table
Preference Cookies Uses Type Expiration
fs-cc Technical cookie is used to for the site to function properly. Internal 180 days
fs-cc-updates Technical cookie is used to for the site to function properly. Internal 180 days

Preference cookies allow the website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. For example, a website may provide you with local weather reports or traffic news by storing data about your current location.

Styled 4-Column Table
Essential Cookies Uses Type Expiration
fs-cc Technical cookie is used to for the site to function properly. Internal 180 days
Alert Cookie is used to store user preferences related to the site's alerts and notifications, providing a more personalised browsing experience. Internal Single session
_ga_ Used to persist session state (in relation to the _ga). External Per session

Essential cookies are required to enable basic website functionality and are always active.

Google Analytics

We also use the Google Analytics web service by Google Inc. (“Google”). Google Analytics is a web analysis service providing information on your behaviour on our web page, thus helping us to create a better user experience. Data related to your use of our web page (e.g., your IP address, browser type, language settings, operating system, etc.) collected by the Google Company will be transferred to Google’s server in the United States of America, where this data will be stored and analysed. The relevant data in anonymized form will then be sent to us. Pursuant to the “Model Contractual Clauses” approved by the European Commission, obliging them to protect your personal data, the Google Company ensures the adequate levels of data protection regarding Google’s processing of personal data.

You may withdraw your consent to the use of web analysis at any time by downloading Google Analytics Opt-out Browser Add-on. More information on the Google Analytics service is available in the terms and conditions for the use of the Google Analytics service, in security and privacy principles of the Google service and in the privacy policy of the Google Company.

Contact

If you have any questions or comments in connection with the cookies, we are available at support@naka.com.  

This notification enters into force on 1 October 2025.

NAKA CH Sagl

Privacy
Policy

Personal Data Protection Notification

1 October 2025

At NAKA CH Sagl, we strive for continuous development and improvement of our services as we want to adapt them to your requirements as much as possible. 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.

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 CH Sagl (“NAKA”), company registration number CHE-327.549.674, with a business address at Crocicchio di Cortogna 6, 6900 Lugano, Switzerland. If you have any questions or requirements regarding the processing of your personal data, please contact us at

support@naka.com.

In What Cases can we Process your Personal Data

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. 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,
  • because 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 system prevents your personal data to be 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 a 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.e.: 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 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 our efforts, we can not guarantee for 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 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 use 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 several different ways, for instance:

i.) The country to which we send your personal data was approved by the European Commission.

ii.) 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?

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 minimalization 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 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 based on 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.

Do You Need To Know Anything Else?

This Notification is published on our website and enters into force on 1 October 2025.

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.

NAKA CH Sagl