Effective as of 1 September 2022

General Principles

We are committed to transparent and secure data processing. As a company incorporated in the European Union, we are committed to process any personal data in line with EU privacy standards and laws. In this privacy notice we provide you with information about what personal data we process and for what purposes, what are your rights and where you can contact us in case you have any questions or concerns about your personal data processing. We only process personal data where we have your consent or where we are entitled to do so based on other legitimate reasons, in particular where (a) processing is necessary for the performance of the Service and to enable us to contract with you in connection with provision of the Service, (b) processing is necessary for compliance with a legal obligation to which we are subject; (c) processing is necessary for the purposes of the legitimate interests pursued by us as the data controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of you as the data subject and which require protection of personal data, in particular where the data subject is a child.

We do not process any special categories of personal data, i.e. we do not process any personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

If you are not at least 16 years old, please seek advice of your parents, or other adult person who is the holder of parental responsibility before you start using the MyWallet App or any of the Services.

What information do we process about you and how is it collected?

We process identification personal data that you provide to us when you create an account and fill in forms during the registration process. To register into the MyWallet, you are required to create your username by providing us with your email which allows us to identify the registered User. You also need to create a password which protects your data inside the app. After login, you can update your personal information and add name, surname. Providing the name and surname sex is voluntary and you can use an alias as your name and surname.

Where you wish to obtain a Premium feature of our App, the payment service providers will collect information necessary in order to process the payment for our Services. We do not process information about your credit or debit card, as the payment is processed via the respective App Store. We identify you in our system via your respective App Store ID, which is a digital code. We do not obtain your identity information that you provided to the respective App Store.

When you use the MyWallet we collect details as how you use our MyWallet, in order to provide you with the Service those data are collected by analytical tools – Mixpanel, Fabric or Google Analytics.

When you use the MyWallet and you will grant us a permission for that, we can:

– View Wi-Fi connection – which allows us to switch from offline to online mode to synchronize your content

The above permissions are opt-in and you can always change your setting in your mobile device in Settings – Apps – Permissions section.

When you use an App to track your finances, your transaction data are stored on our servers including income, expenses, categories, amounts, currency, labels, account type, date, time and other details provided by the User.

What we use your personal data for

Your data may be used for providing services you request in relation to your use of Wallet or other Services provided by NC Solutions. Sending communications or contacting you with relevant information regarding our services or with Offers. We use your data for statistical and marketing analysis, system testing, maintenance and development or in order to deal with your request or claim through our customer service channel.

If you use an App provided by NC Solutions, we may from time to time send a push notification or in-app message directly to your MyWallet, or an email. You may turn-off such communication by unsubscribing from this service following instructions at the end of each of such email communication.

We do not share these aggregate data with any third party.

Recipients of your personal data

We may be required by law to grant access to personal data about you that we process for the purpose of investigating criminal activities and violations of the law, to judicial or other government agencies in particular law enforcement authorities subject to warrants, subpoenas or other governmental orders.

To provide you some Services such as Bank connection, we share your personal data with trusted 3rd parties or banks. Subject to your request and explicit consent with sharing of data, we may also share your data with an operator of a third party App.

Bank Connection Users specific information

This section applies whenever you as a user request that NC Solutions provide you with account information service (AIS) as defined in respective payment regulations, in particular, but not limited to, the PSD2 and all laws or regulations in force from time to time in NC Solution’s jurisdiction giving effect to PSD2, regardless of via what App you have requested NC Solutions to provide you with the AIS, i.e. MyWallet. Please note that other provisions of this Privacy Policy also apply, only, however, to the feasible extent.

If you request NC Solutions to provide you with the account information services, you agree to be bound by our Terms of Services and any Third party applicable licence or service terms (as the case may be and as will be notified to you). All your Personal Information provided in connection with or accessed during your participation in the Bank Connection feature will be processed only in order to provide you with the account information service. Your Account Information and all other personal data accessed through the Bank Connection feature is transmitted through secured protocols in an encrypted mode and is temporarily stored on our servers. This information is temporarily cached in a way that it is not readable by NC Solutions.

The AIS is provided by NC Solutions based on your consent. Your consent will expire in 90 days and then you will be requested to re-create it in the same way that you originally gave consent.

You can withdraw such consent anytime by the following actions:

– You can cancel the provision of NC Solutions AIS at any time by disconnecting your bank account (within your respective bank account settings).

– You can notify NC Solutions that you withdraw the AIS consent by at the email address stated below.

– You can delete your profile by sending your request NC Solutions at the email address stated below.

Please note that the withdrawal or expiration of your AIS consent does not affect the actions of NC Solutions prior to the withdrawal or expiration.

Data Retention

We will maintain the personal information as long as you actively use your account in the MyWallet. We will inactivate any account and delete any and all information entered by you into our system, if you have not logged into the MyWallet for longer than 24 months. We will also delete any data you provided us while using the MyWallet if you request us to do so (for details see below Right to erasure). For technological reasons your account will be deleted from our servers within 1 month following your request. In the case of the company termination or discontinuation of service, your data will be permanently deleted.

Consent

If you granted us your consent to process your personal data, you can withdraw your consent any time without affecting the lawfulness of processing based on consent before its withdrawal by removing your consent inside Wallet – Settings – Personal data & privacy section or by unsubscribing from this service following instructions at the end of each of such email communication.

Cookies

What are cookies used for? Cookies help identify application users and web site re-occurring visitors, they remember users’ custom preferences, help user complete tasks without having to re‑enter information when browsing from one page to another or when visiting the site later. Cookies can also be used to track user preferences when web browsing for online behavioral target advertising and to show adverts relevant to something that the user searched for in the past.

What type of cookies do we use?

In order to provide you with a better service, we use cookies when you visit our website www.ncsolutions.gror when you use our MyWallet. We use different set of cookies. We use the term “cookies” to refer to pieces of information that are sent to your browser and stored on your computer or device to store and sometimes track information about your preferences in order to deliver behavioral advertising. System cookies enable us to provide you with services you have specifically asked for and are essential in order to enable you to move around the Website and application and use their features, such as cookies used to identify user once he or she has logged in.Without these cookies some services you have asked for cannot be provided to you. Apart from those we use cookies and third-party cookies that help us track your browsing history in order to serve you with behavioral advertising. We will only use these cookies if you grant us explicit consent on our website www.ncsolutions.gr. You can disable or refuse some or all cookies, or delete the already set up cookies in the web browser you use. The cookies we use can be divided into the following:

• session cookie which is erased when you close the browser, it exists only in temporary memory of your device while you navigate the website;

• persistent cookie which remains on the user’s computer/device for a pre-defined period of time, these remain in operation, even when you have closed the browser, they remember your login details and password so you don’t have to type them in every time you use the site; and

• third-party cookies these are installed by third parties with the aim of collecting certain information to carry out various research into behavior, demographics etc.

Persistent cookies and third-party cookies are deleted automatically if you are in-active and do not visit our web-site or use our application for more than 6 months. Also you can delete these cookies if you change your preferences.

Web beacons are images (single-pixel gifs) embedded in a web page or email for the purpose of measuring and analyzing site usage and activity. Web beacons or similar technologies help us better manage content on our Services by informing us what content is effective, count users of the Services, monitor how users navigate the Services, count how many e-mails that we send were actually opened or count how many particular articles or links were actually viewed. We do not tie the information gathered by web beacons to our users’ Personal Information.

You can learn more about cookies at www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers. Please note, however, that blocking or deleting cookies used on the Website or the application may affect the availability and functionality of the Website and provision of service to you via our application.

Security policy

We follow strict security procedures in the storage and disclosure of your personal data.

Where we store your data?

We may process your personal data on third party servers, with whom we concluded data processing agreement according to the standards of the EU laws, securing your data privacy and safety. We do not process personal data of EU Users, outside the EU, i.e. we do not transfer personal data for the purposes of their data processing outside the EU. You may obtain the information about which data processors we use and where we store personal data by contacting our customer support at support@ncsolutions.gr

Communications

All private data exchanged with Provider is always transmitted over SSL. We are not transferring your data outside EU.

Contact

You can contact Provider at the email address: support@ncsolutions.gr you request any information regarding personal data protection.

Data Deletion Policy

You have the right to request that your Personal Information be deleted from our primary production servers. You own your data. Anytime you want your data removed from our system, you can request us to delete your account from our production servers. As a result, your data will be excised permanently from our production servers and further access to your account will be impossible. Additionally, any connection we had established to your Account Information will be disconnected. However, for purposes of ensuring continued ability to serve you in case of malfunction or damage to our production servers, we retain backups of portions of your data derived from your Account Information on our production servers. Your aggregated data is stored in these servers indefinitely. We reserve the right to use any aggregated or anonymous data derived from or incorporating your Personal Information.

You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information provided as part of account registration. If your Personal Information changes, or if you no longer want to use our Services, you may correct or delete inaccuracies, or amend information by making the change at any time via the Service. However, in some instances we cannot delete all information we hold about you.

Right to data portability

You have right to receive the personal data concerning you, which were provided to us, while registering into our system or while using our application, in a structured, commonly used and machine-readable format and you have the right to transmit those data to another service provider without hindrance, where: (a) the processing is based on your consent pursuant or on a contract; and (b) the processing is carried out by automated means. We will provide you these data in .csv, .xls or .pdf format by e-mail, which we use when using our system. You can request that we transmit the data directly to the other service provider, where it is technically feasible. Your exercise of the data portability right does not mean that you cancel using our services or that you withdraw your consent that we further process your personal data. This shall not affect the services we have been providing you prior to such request. We may reject your request for data portability if it shall adversely affect the rights and freedoms of others.