Privacy Policy

Introduction

We – Naoma AI – are committed to protecting your privacy and handling your personal data transparently and securely. This Privacy Policy explains how we collect, use, process, and protect your personal data – our website visitors, clients, and their sales teams. We also use cookies and similar technologies to enhance your experience on our website, as detailed in our Cookie Policy.

When necessary under applicable law, by continuing to use our website you are agreeing to the processing operations we disclosed in this Privacy Policy.

The terms “personal data”, “data processing”, “data controller”, “data processor” and others have the definitions set out in data protection laws, namely the GDPR. These terms may vary depending on applicable law.

Data Controller

We – Naoma AI Inc. – are the data controller, meaning that we determine the purposes and means of the processing of your data on our website and in communications with our teams. Our contact details:

• EIN number: 33-2156052
• Address: Ste 949, 221 W 9th St, Wilmington, Delaware, United States, 19801
• Email: info@naoma.ai (this email is dedicated to inquiries about the processing of your data and the exercise of your rights)

Types of Data Collected

We process the following categories of personal data:

We do not knowingly collect, use, or disclose personal data from individuals under 18 years old, nor do we offer or target our services to them.

Purpose and Legal Basis for Processing

Your data is processed for the following purposes:

• To provide our services and communicate with you regarding your use of our services – based on a contract with us and our Terms of Service.
• To analyze website usage and performance through analytics – based on your consent with analytics cookies, which you may withdraw at any time.
• To personalize your experience with our website and teams, and improve our services – based on our legitimate interest.
• To comply with KYC, bookkeeping, and similar procedures – based on our legal obligations.

Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your browsing experience and understand how you interact with our website.

Data Recipients and International Transfers

Your personal data may be shared with the following third-party service providers who assist us in providing our services:

• Vercel Inc. (Analytics Provider): Website analytics and performance monitoring

We ensure all third parties respect the security of your personal data and comply with applicable law.

Subject to EU/EEA, UK or Swiss laws and regulations, for international transfers outside these territories to our partners located in third countries (such as to Vercel Inc. in the United States), considering that some of these countries may not provide the same level of data protection as determined by their competent authorities, we implement necessary data protection measures and follow required procedures to ensure the protection of your data and your rights as a data subject, including Standard Contractual Clauses approved by the European Commission, EU-U.S. Data Privacy Framework vendor assessment, and transfer impact assessments.

Most of our third-party service providers process data solely on our documented instructions and are contractually prohibited from using such data for their own purposes.

Data Retention

We process and retain your personal data only for as long as necessary to fulfill the purposes we collected it for, legal, accounting, and reporting requirements, and to defend or exercise legal claims in accordance with applicable limitation periods.

Cookies are stored for as long as specified in our Cookie Policy.

Your Rights

You have the right to:

• Access the information about what data we process about you, why and how, and to get a human-readable copy of it.
• Rectify or correct inaccurate or incomplete data about you.
• Erase or delete your data held by us, unless we are required to keep it by law (e.g. to deal with legal claims, or to support freedom of expression and information).
• Restrict the processing of your data if you challenge the lawfulness of the processing, data accuracy, or our legitimate interest, or if you need the data retained for legal claims.
• Request the transfer of your data to another party – if we process your data by automated means based on consent or contract, you have the right to get a copy of your data in a machine-readable format to transmit it to another data controller of your choice.
• Object (1) to the processing of your data for direct marketing purposes (if any) at any time, by opting out following the instructions in the marketing message or by sending us a request, and (2) to the processing based on legitimate interest if you believe it violates your rights.
• Not be subject to automated individual decision-making and profiling, unless you have given your consent or it is necessary for the performance of a contract with you.
• Lodge a complaint about the processing of your data with us, or with the data protection authority of your place of residency if you believe your rights have been violated.
• Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, please contact us using the details provided above.

Security of Data

We are committed to ensuring the security of your data. We have implemented appropriate technical and organizational measures, data protection principles, contractual safeguards, and conduct necessary assessments to ensure the confidentiality and security of your personal data, including from accidental loss and from unauthorized access, use, alteration, and disclosure, and to process it in compliance with applicable laws, whether by us or our partners, contractors, and vendors, including in cases of international data transfers.

Such measures include (but are not limited to) pseudonymization of personal data and encryption at rest and in transit, access management and event logging, confidentiality commitments of staff, and access control on a need-to-know basis.

We shall notify you by email immediately if any data breach occurs that may threaten your rights and privacy, as stipulated in applicable law, and provide you with guidance on how to mitigate that risk.

Changes to this Privacy Policy

We may update this policy from time to time. The latest version will always be posted on our website. We encourage you to review this Privacy Policy regularly for any changes.

When necessary under applicable law, we will inform you by any available means when the processing of your data has been significantly changed and the Privacy Policy amended accordingly.