We respect the privacy of our website visitors and our Nodle app users. Nodle is a connectivity provider for Smart devices. We have built a Bluetooth Low Energy - powered network to help companies and cities connect and collect data from devices, sensors, and tags. We also bring an innovative solution which enables any individual (“you”) and app developer to participate in the Nodle Network and in exchange to be rewarded through NODL tokens (hereinafter “NODL”).

With this Privacy Policy, we (meaning Nodle International and our subsidiaries; hereafter “Nodle,” “we,” “us,” “our”) want to inform you why and how we may process your personal information, when and why we could share your personal data, and your rights and choices to control your personal data in accordance with the applicable laws. We collect your data through our Nodle application, our Nodle SDK that could be embedded in our Nodle application or the applications of our partners, our website (hereinafter “Sites”) and our online services (collectively hereinafter referred to as our “Services”) and when you contact us, you communicate with us via our online or social media channels.

Nodle is a wireless network connecting and securing the next trillion Internet of Things using smartphones and Bluetooth Low Energy (BLE). The Nodle Network’s architecture and system design leverage, utilizing smartphones as nodes and base stations for the network. Our team has developed an innovative way to grow the network through “proof of connectivity”. Using this method, mobile application developers and individuals participate in the network by enabling their smartphones to provide resources such as wireless radio and bandwidth, and in exchange for their contribution, get rewarded with the cryptocurrency NODL.

Manufacturers or operators of electronic devices can also utilize the Nodle Network to connect their remote devices to the Internet and collect data from these devices.

We can collect “Personal Data” (or “Data”) that identifies you:

• either directly, such as your email address if you subscribe to our newsletter or;
• or indirectly, such as your public key (we don’t collect your private key), your IP address, your Mac Address, your Payload data, your Wallet ID, your location data, timestamp, a cookie identifier if you use our Nodle application or our website.

We may collect your Data and combine this Data with data provided by our partners:

1. You use our Services or the services of our partners

We can collect some Data to provide you with our Services (in particular to give you your NODL reward), to improve and personalize your online experience, understand and analyze how you use our Services and develop new services, features, and functionality, analyze trends, prevent fraud and improve the security of our Services.

When you visit our website, we may collect the following types of information:

• Contact Details: this includes information such as your email address when you subscribe to a newsletter (hereinafter your “Contact Details”).
• Technical information: your browsing data and technical Information, to access to our Services and security of our Services, such as: visited pages, identifier of your connection (IP address), dates and times, information about the browser and the operating system you use.

When you use our Nodle application, we may process the following types of information:

• Your Nodle public key (e.g. to reward NODL or settle transactions).
• Technical information: this includes Payload data, your usage data and technical Information, to access to our Services and security of our Services, such as: identifier of your device and the connection (IP address, MAC address), information concerning the operating system you use. The Payload data includes the data the data produced or captured by the Nodle SDK through the device components.
• Location data and timestamp which allow us to locate smart devices communicating with your smartphone.

We use our Nodle SDK and various types of technologies such as cookies (hereinafter ”Cookies”) to collect such Data when you use our Services (in particular when you visit the nodle.com website).

Some partners can provide us some Data. They can also set our Nodle SDK on your device when you use their software (e.g. their mobile application) . They must inform you about the use of the Nodle SDK and obtain your consent for activating our SDK and allowing the collection of your data.

We allow some of our partners to set and access their Cookies on your device. These partners' use of Cookies is subject to their own privacy policies and not this Privacy policy. To refuse Cookies or request their deletion as well as obtain the list of partners who are permitted to store and/or access these Cookies, please visit the Cookies policy or the “How do you exercise your rights?” section below.

2. You accept to receive push notification or you sign up to our newsletters, ask to be contacted by us or our partners.

Push Notifications. If you have opted-in to receive push notification on your device, we can process your data to push you some personalized notifications on your device. You can opt-out at any time by adjusting the permissions in your device or uninstalling our app.

Emails and Newsletters. We collect your email address and other contact details when you sign up to our newsletters or ask to be contacted by us or our partners. You can unsubscribe at any time by clicking on the unsubscribe link available at the end of each newsletter.

You cannot opt-out of push notifications or non-promotional emails, such as those about your account, transactions or servicing.

3. You are exposed to personalized content on our Services or those of our partners.

We may also use your Data collected to offer you personalized products, services, or content (“Personalized Content”) via our Services (e.g. to send you push notifications from the Nodle App) or those of our partners.

4. You contact us via our customer support or social media.

If you contact us via our customer support, we collect Data such as your first name, your last name, your username, your email address, your date of birth, your postal address, depending on your questions or requests. We will record the content of our correspondence with you (such as feedback and questions to customer support). This data could be used to monitor service quality and compliance, prevent fraud, or provide training for our staff and customer service teams.

If you contact us via social media, we collect some of the Data included on your profile.

5. You take part in a survey

We could organize surveys within our application or our community (discord channels, telegram channels), and collect Data for administering the survey, analytics, statistics and marketing purposes (e.g. sending you promotional offers).

6. You do not comply with our terms and conditions.

When you use our Services, we ask that you comply with our terms and conditions which are intended to protect our users, employees, and our rights.

If you do not abide by these rules, you may be blocked your account including in the event of inappropriate conduct. We will keep your Data for the time needed to apply these exclusions. This Data may include for example your username, your IP address, and the identifier of your device.

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Unless the law specifies a different retention period (e.g. for complying with legal, accounting, tax requirements and for managing your rights and/or our rights), we will only keep your Data for the time strictly necessary to carry out the operations for which said Data has been collected. At the end of this data retention period, your personal data will be erased or anonymized.

Due to the nature of blockchain, the retention period of the personal data embedded to manage the NODL tokens reward and other transactions (e.g. your crypto-wallet public address) is aligned with the duration of the blockchain.

We may share your Data with:

• The competent Administrative or judicial authorities or any other authorized third party, in compliance with applicable laws. We always verify the legitimacy of the request. We may share Data to establish, exercise or defend our and/or your legal rights (this includes providing Data to our professional advisors).
• We share information with our related entities, including our parent, sister, and subsidiaries for business purposes such as customer support, marketing, product development, technical operations and administering the Services.
• Subsidiaries and Affiliates: In connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets, including in the unlikely event of a bankruptcy, we may transfer your Data to service providers, advisors, potential transactional partners, or other third parties. If the transfer or sale goes ahead, the companies receiving your Data can use your Data in the same way as us. The use of your Data following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.
• Our partners who use your Data to offer you their products and services accessible from our Services. In certain jurisdictions only, you may be offered the opportunity to purchase the NODL token via our partner Swipelux. Their services may not be available in all languages and may not be appropriate or available for use in any particular location. Eligibility for use of the Swipelux services will be determined by Swipelux in their sole discretion. In addition, we reserve the right to block access, suspend, remove, or cancel its services through our Services for any reason and without prior notice. The use of Swipelux services will be subject to transaction fees and/or other fees charged by Swipelux. The terms and conditions which will apply to the use of Swipelux services can be found here. Where you choose to purchase the Nodle token using payment by Swipelux we will be sharing some personal data (e.g. your Publick Key) with Swipelux that may request or require access to your personal data. Nodle has no responsibility for their use of your personal data. The processing of such data will be handled in accordance with the Swipelux privacy policy that is available here. It’s your responsibility to review and understand their terms and conditions and their privacy policy before using its services. We are not responsible for the access, content, accuracy, security, availability, any performance, or failure to perform of their services or any issue in relation with the use of their services. To the extent you choose to use their services, you are solely responsible for compliance with any applicable laws in relation to such use.

We can work with some partners who use your usage data to help us make our services better via Cookies: to consult the list of these partners, please visit the Cookies page. These third-parties (except our subsidiaries) have their own privacy policies which you may refer to for information about how they process your information and how to exercise your data subjects' rights as provided under applicable laws. We do not accept any responsibility or liability for the policies of other organizations.

Your Nodle public key and information related to your Nodle transaction (such as the amount of the transaction and the public key of the recipient) are shared across all participants in the Nodle blockchain, and because of the nature of the blockchain, it is publicly available and cannot be altered or deleted.

We may process or transfer some Data with partners who have servers or who are based outside EEA. In such cases, the EuropeanData may be transferred to countries located outside the European Union who provide an equivalent level of protection. In the event of transfer to other countries, the protection of this Data is specially ensured by the signature of standard contractual clauses approved by the European Commission or equivalent legal mechanisms (such as those defined in chapter V of the Regulation (UE) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (hereinafter ”GDPR”).

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Due to the nature of blockchain, your privacy rights (e.g. rectification, object and erasure rights) are not extended to the data embedded in the blockchain. This personal data stored on the blockchain is limited to transactions with your public keys.

• Obtain a copy of your Data - “Right of access and data portability”: You have a right to see the personal data we hold about you and you can request a copy of this data. You also have the right to request a copy, in an interoperable format (right to your data “portability”), of the personal data that you have provided to us for the performance of a contract with us or under your consent. You may also use it yourself or transfer it to another service provider. If you have been excluded in relation to our Services, we will not be able to give you access to the Data regarding your sanction to maintain our ability to detect or act against such behavior.
• Correct your Data - “Right to rectification”: If you believe we hold inaccurate or missing information, please let us know and we will correct it.
• Object to our use of your personal data (Right to object): We will consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it or delete it. At any time, you can unsubscribe of the reception of newsletters (please use the unsubscribe link available in our newsletters). You can also opt-out at any time of the marketing Push Notifications on your device by adjusting the permissions in your device or uninstalling our app.
• Give and withdraw your consent (Right to consent): At any time, you may withdraw your consent or object to:
  • The personalization of advertisements, the sharing of your Data with some partners and the use of some categories of Cookies (please visit our Cookies Policy).
  • Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no industry consensus as to what site and app operators should do with regard to these signals. Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit http://www.allaboutdnt.com.
  • The personalization of advertisements on your mobile (please use the privacy settings on your telephone or your tablet and activate “Limit Ad Tracking” on Apple smartphones, or “Opt-out of Ads Personalization” on Android smartphones).
  • Location Sharing: Nodle uses Bluetooth Low Energy (BLE) to securely locate and anonymously connect smart devices in exchange for NODL. Users of the Nodle App earn NODL each time their device receives data from nearby IoT devices or sensors for which the owner of the device had created a “smart mission” to reward network contributors interacting with the smart device. The Nodle App needs permission to capture device location, along with Bluetooth IoT data, at regular intervals. You earn NODL based on this data. You may change the frequency of the data or location capture using the scan modes in the Options menu of the Nodle App. You may choose to only send IoT Data to Nodle when your device is connected to a WiFi network. You can stop collection of precise location data from the Nodle App or a third party app with the Nodle SDK by withdrawing your consent through your device settings. You can also stop all collection of information via any app by uninstalling it.
• Right to erasure (Right to be forgotten): You can request the deletion of your data when:
  • We no longer need to keep your personal data.
  • You have successfully made a general objection.
  • You have withdrawn your consent to us using your personal data (where we have relied on consent as the lawful basis for doing so).
  • We have unlawfully processed your personal data.

If you have been sanctioned in relation to our Services, we cannot delete the Data regarding your sanction as to allow us to maintain your sanction.

PLEASE REMINDER, DUE TO THE INHERENT TECHNOLOGY OF BLOCKCHAIN (I.E., ITS IMMUTABLE NATURE), YOUR PRIVACY RIGHTS TO BE FORGOTTEN ARE NOT APPLICABLE TO ANYTHING THAT IS PUBLISHED ON THE BLOCKCHAIN.

• Limit the use of your data (Right to restriction of processing): you can restrict our use of your personal data (if you do not want us to delete it), if you have successfully made a general objection, you are challenging the accuracy of the personal data we hold, or we have used your personal data unlawfully.

If you object to the processing or withdraw your consent or ask for the deletion of your personal data by us, we will stop processing your personal data or erase it from our IT systems, except where we have legitimate and compelling grounds for processing, or for the purpose of ascertaining, exercising, or defending its legal rights in accordance with the applicable laws and regulations.

To exercise your rights, you can also contact us. But before we can facilitate these rights, we will first need to be able to identify you based on the information that we have about you.

We will retain and use information about you as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

We'd like the chance to resolve any complaints you have. However, if you feel that your rights have not been respected after having contacted us, you have the right to make a complaint to the regulatory authority in your country.

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To ensure the security and confidentiality of your Data, we implement appropriate physical, electronic and organizational procedures to safeguard and secure Data throughout our Services, in particularly, to prevent your Data from being distorted, damaged or communicated to unauthorized third parties, by ensuring an appropriate level of security with regards to the risks associated with the processing and the nature of Data to be protected.

Where you use a password for registering with our Services, you are responsible for keeping this password confidential. We ask you not to share your username and/or password and/or your private key with anyone. To protect your NODLE account, you should not share your private key with anyone.

We cannot guarantee the security of Data that you transfer over the internet or a telecommunication network to us; however, we do take appropriate technical and organizational measures to safeguard your personal data.

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The lawfulnesses of the data processings are:

• A contract between you and us to provide you with Services (including participating to the NODL token and receiving rewards).
• A legitimate interest: offering you the best possible user experience (including understanding our product – strengths, weaknesses, opportunities and threats, testing and developing new products and services as well as improve existing ones, understanding and keeping abreast of current, new and emerging trends in our industry), administering and protecting our Services (maintaining the integrity of our IT services and network security, troubleshooting, system maintenance, support, reporting and hosting of data), responding to your requests and questions or sending you our newsletters, keeping our records up to date.
• Your consent: offering you personalized advertisements depending on your data via Cookies. You may withdraw your consent for us to process your Data at any time.
• Complying with a legal obligation: responding to complaints and queries from competent administrative or judicial authorities or any other authorized third party, in compliance with applicable laws

Our Services are not intended for use by or directed towards children. Accordingly, we do not knowingly collect and maintain the information of anyone under the age of 18. Where we discover that the user is a child, we will promptly delete the associated user account and any personal data linked to this account, except where that data is part of the Nodle Chain, in which case it is immutable and cannot be deleted.

Please note that we may update or change this privacy policy. If we update our privacy policy, we will post those changes to other appropriate places. You are deemed to have accepted the new terms of the privacy policy when you first use the Services.

To let you know when we make changes to this Privacy Notice, we will amend the revision date at the top of this page. The new modified or amended Privacy Notice will apply from that revision date. Please check back periodically to see changes and additions.

If you have any questions about this privacy policy, please contact our Data Protection Officer by using this contact form or by mail: Data Protection Officer, Nodle Technology Inc, 2443 Fillmore Street #287, San Francisco, CA 94115

If you have a disability and would like to access this Privacy Policy in an alternative format, please contact us by using this contact form.

This privacy notice for California Residents supplements the information contained in this Privacy Policy and applies to visitors, users, and others who reside in the State of California. Consumers residing in California have certain rights with respect to their personal information under the California Consumer Privacy Act (“CCPA”).

Notice of Collection and Use

In the preceding 12 months, we have collected the following categories of Data: identifiers, personal information categories listed in the California Customer Records statute, commercial information, internet or other similar network activity, and geolocation data. For examples of more specific information, we collect and the sources of such collection, please see Section “When do we collect your Personal Data and for what purpose?” in the Privacy Policy. We collect your Data for the business and commercial purposes described in the dedicated section.

Right to Know and Delete

If you are a California resident, you have the right to delete the personal information we have collected from you and the right to know certain information about our data practices in the preceding 12 months. In particular, you have the right to request the following from us:

• The categories of personal information we have collected about you;
• The categories of sources from which the personal information was collected;
• The categories of personal information about you we disclosed for a business purpose or sold;
• The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
• The business or commercial purpose for collecting or selling the personal information; and
• The specific pieces of personal information we have collected about you.

To exercise any of these rights, please contact us by using our contact form. In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within 10 days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete.

Right to Opt-Out

To the extent Nodle sells your personal information as the term “sell” is defined under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by using our contact form.

Authorized Agent

You can designate an authorized agent to submit requests on your behalf. However, we will require written proof of the agent’s permission to do so and will verify your identity directly.

Right to Non-Discrimination

You have the right not to receive discriminatory treatment by us for the exercise of any your rights.

Financial Incentives

Financial incentives are programs, benefits, or other offerings, including payments to consumers as compensation, for the disclosure, deletion, or sale of personal information about them.

To be rewarded with NODL token, the Nodle App and Nodle SDK require the collection and sharing of Data in exchange for financial rewards in the form of NODL tokens. The connectivity resources require Edge Node Device Information and due to the inherent nature of connectivity protocols like BLE and Wi-Fi. If you do not provide Edge Node Device Information, you will not be able to connect to the Nodle Network, provide connectivity resources to the Nodle Network, or earn any NODL token.

NODL token rewards vary based on the data packets transmitted through the Nodle network, paying for the first few nodes that show a new packet, paying more or less depending on the value of the packet. In order to guarantee that Nodle is faithful to its mining model, Nodle has inserted a validation protocol to assess and confirm the order of arrival of beacons.

More information about the terms related to NODL token can be found in our terms and conditions.

California Shine the Light Law

California Civil Code Section 1798.83 permits users of services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please submit a verifiable consumer request to us by writing to us at:

Nodle Technology Inc.
2443 Fillmore Street #287
San Francisco, CA 94115

We may still retain your information to resolve disputes, enforce our user agreement, or comply with legal requirements.

California Do Not Track Disclosures: “Do Not Track” is an internet browser setting regarding tracking and your browser may allow you to set a DNT signal indicating that you do not wish your online activity to be tracked. As there are currently no agreed upon standards for the DNT signals or how to respond to them, our system does not support and cannot act on DNT signal headers that we may receive. However, the choices that we provide you concerning collection and use of your personal information will continue to operate as described in this Privacy Policy.