Privacy Policy

1. INTRODUCTION

This Privacy Policy (“Privacy Policy”) describes the data protection process adopted by NATEN SAS (“nocnoc”) regarding data obtained through our Platform and communication channels with customers and users. It applies to nocnoc and its group companies, acting as data controllers.

nocnoc is an Uruguayan company that offers intermediary services between sellers from different regions of the world (“Sellers”) and marketplaces operating in Latin America. nocnoc’s services include cross-border facilitation/integration of Sellers into e-commerce and marketplaces through a platform, as well as logistics for delivering products to end consumers.

We are committed to respecting your privacy and guaranteeing the security of all our users’ information and data. This commitment is fundamental to providing services with transparency, security and peace of mind.

This Policy explains how we handle the personal information of:

• Sellers who intend to sell their products on marketplaces and who register on our platform.
• Sellers who actually contract our services and who use our Seller Center available at sc.nocnocstore.com.
• Consumers who purchase products advertised through our official stores on marketplaces and who interact with nocnoc through our customer communication channels.
• Prospects or visitors to our website nocnocstore.com.

This Privacy Policy includes information on what data we collect, what data we process, the purpose, the duration, and your rights as the data subject. In some cases, we may communicate specific additional data privacy policies for certain services, practices, or geographic regions, which will complement this Privacy Policy.

• For consumers living in Brazil and Mexico, this Policy is supplemented by specific statements:
• Privacy Notice for Brazil.
• Privacy Notice for Mexico.

Your personal information may be subject to the privacy policies of third-party websites, such as the marketplaces with which nocnoc maintains commercial relations and on which Sellers who are nocnoc clients display their products. In addition, our website may occasionally contain links to our partners’ websites.

It is important to note that we have no control over these sites, and our Privacy Policy does not apply to them. We recommend that you read the privacy policies and terms and conditions of the partner sites carefully, as they have their own privacy policies. nocnoc does not accept any responsibility or liability for these policies.

By creating an account on nocnoc for the use of our Platform or registering through any of our channels or by any means using our services, you declare that you have read, understood, and agree to this Privacy Policy.

It’s important to clarify that the decision to share your data, including the extent and duration of such sharing, will always be yours. However, if you choose not to share certain data or part of it with nocnoc, particularly when it is necessary for the provision of our services, you may opt not to use the services we offer.

If you have any questions about data protection at nocnoc, please contact us by email: [email protected].

2. PERSONAL INFORMATION WE COLLECT

2.1 INFORMATION YOU PROVIDE TO US

We collect various pieces of information that you voluntarily provide to us.

If you are a seller, this includes

• first and last name
• e-mail address
• postal address
• phone number
• professional position
• company name
• bank details

In addition, in specific situations, such as when you represent a company that enters into a contract with us, we may collect additional information such as date of birth, passport number, national identity, and other data for identification purposes and compliance with our integrity, anti-corruption, anti-money laundering, and anti-terrorist financing policies.

If you are a consumer, the data we hold about you is that which is shared by partner marketplaces through which you purchase products advertised by sellers, such as your address, phone number, and identification number. We use it to fulfill our services, including product delivery and communication with the customer to provide relevant information, such as order status and customer support when you contact us.

If you are a prospect or a visitor to our website, this includes

• device ID
• time, date, and origin of your access
• duration of use of our website.

In the above cases, if you are a Seller, consumer or visitor to our site, we may also collect the following data:

• Feedback or correspondence: all information you share when you get in touch with us, whether it’s to ask questions, provide feedback, or communicate in any other online manner.
• Usage information: pertains to how you use our website or services and interact with us. This includes information associated with any content you submit and data provided when you use interactive features on our website or services. It also covers information resulting from interactions with our customer service.
• Marketing information: these details refer to your preferences regarding receiving communications about our activities, events, and publications. It also encompasses specifics about how you engage with our communications.

In addition, we may collect other information not specifically listed here, but it will be used in accordance with this Privacy Policy or as disclosed at the time of collection.

2.2 INFORMATION OBTAINED FROM THIRD PARTIES

In addition to the information you provide to us, we may receive personal information about you from third-party sources. This may include:

Contact information and correspondence from marketplaces: If you are a consumer, we may receive your contact information from marketplaces to fulfill your orders.

Information shared by business partners: Business partners may share contact information with us if you express specific interest in our services or the types of products or services we offer.

Other third parties: We may also obtain personal information from other third parties, such as marketing partners, publicly accessible sources, and data providers.

2.3 COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS

To improve our services, we, together with our service providers and business partners, use technologies such as cookies, browser storage, web beacons and similar tools. This allows us to automatically collect information about your interactions with our website and services, including:

• Device data: Such as your device’s operating system type and version number, manufacturer and model, device identifier, browser type, screen resolution, IP address and general location information, such as city, state or geographical area.
• Online activity data: This includes information about the use of our websites, such as the pages you have viewed, the time spent on each page, the navigation paths, information about your interactions on each page, access times and duration of visits, as well as communications response data, such as the opening of emails we send and the actions you take in response to those emails.

For more information on cookies, see item number 9.

3. HOW WE USE YOUR PERSONAL INFORMATION

We utilize your personal information for various purposes, which include:

• Order Fulfillment and Addressing Concerns: We process your data to fulfill orders placed by consumers through marketplaces and to resolve any concerns you may have.
• Platform and Service Operations: Our platform and services’ operation, maintenance, security, and improvement are reliant on your data.
• Information Provision: We provide information about our services and events using your personal data.
• Communication: We use your data for communication, including announcements, updates, security alerts, and support and administrative messages.
• Event-Related Communication: Keeping you informed about events you participate in.
• Understanding Needs and Personalization: We analyze your data to understand your needs and interests, customizing your experience on our platform, services, and communications.
• Response to Requests: Your data helps us respond to your requests, questions, and feedback effectively.
• Research and Development: We utilize your information for research and development purposes, aiming to enhance our platform and services and create new products.
• Marketing and Promotions: Engaging in marketing activities, which may include sending marketing communications or facilitating the advertising of our products and services. You can choose to opt-out of such marketing efforts.
• Legal Compliance: Ensuring compliance with applicable laws, lawful requests, and legal processes, such as responding to subpoenas or government authority requests.
• Compliance, Fraud Prevention, and Safety: Protecting our rights, privacy, safety, and property, enforcing our terms and conditions, and investigating and deterring fraudulent, harmful, unauthorized, unethical, or illegal activities.
• Consent: When required by law, we may specifically seek your consent to collect, use, or share your personal data.
• Anonymous Data Creation: We may create anonymous data by removing personally identifiable information, which we use for lawful business purposes, including analysis and service improvement.

4. RECRUITMENT PROCESS

When you explore career opportunities on our platform, we gather information as part of your job application process. This data includes both business and personal contact details, professional qualifications and competencies, educational and professional background, and other details commonly found in a resume.

We utilize this information to facilitate our recruitment procedures, handle employment applications, such as assessing candidates for job roles, and track recruitment metrics.

Additionally, we may use this information for the efficient management of our platform and for other essential purposes, including but not limited to:

Ensuring compliance with applicable laws and responding to legal requests, such as subpoenas or warrants served on nocnoc.

Safeguarding and upholding the rights or assets of nocnoc and other parties.

Participating in legal investigations when required.

Investigating or aiding in the prevention of any actual or potential law violations, breaches of this Privacy Policy, or infringements of nocnoc’s Terms of Use.

5. HOW WE SHARE YOUR PERSONAL INFORMATION

In order to carry out our activities correctly and guarantee excellence in the provision of services, we may share certain Personal Data in some situations, always seeking to preserve your privacy and, where possible, in an anonymized form. We describe here the situations in which we may share Personal Data:

Suppliers and partners: we share Personal Data to enable our operation and the provision of our products and services, such as companies that operate payment systems, logistics companies, companies that provide fraud prevention services, companies that license the right to use digital platforms, companies that support our operations, that provide data hosting services, professional advisors, such as lawyers, bankers, auditors and insurers, where necessary in the course of the professional services that they render to us, among others.

Public Authorities: We may share any personal data we believe is necessary to comply with legal obligations or to protect our rights and those of our collaborators. Additionally, we may be compelled to share some of your personal data with public entities to fulfill legal or regulatory obligations or comply with orders from competent authorities.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

nocnoc Group Companies: In some cases we use our affiliates to provide some of the services so we can use our resources in a more efficient way. We may share data to our affiliates to perform the activities indicated in sections 4 above.

Business Transactions: In certain instances, we may engage in business transactions such as mergers, acquisitions, or asset transfers. If such events occur, your personal data may be transferred, subject to reasonable efforts to ensure your data’s continued protection and accordance with this Privacy Policy.

Others: nocnoc may share your information other than as described in this Privacy Policy if we notify you and you expressly agree to this.

6. HOW LONG WE STORE YOUR DATA

We will retain your data:

(i) until we fulfil the reason why we collected it, including providing the Services, legal, accounting and reporting obligations, etc.

(ii) for as long as you consented to it.

Your data will be deleted if you request so or if your account is inactive for 8 years. However, we may be obliged to certain legal retention periods which shall be complied by us.

Should that be the case, even if you request the deletion of your data, we may still need to store some of it due to legal requirements.

In addition, we will continue to store your data if necessary to comply with applicable local laws.

7. INTERNATIONAL DATA TRANSFERS

nocnoc is committed to consistently using and protecting your data in accordance with this Privacy Policy and applicable legislation.

nocnoc is based in Uruguay, however, due to the global nature of our platform and services, your data may be transferred internationally to countries where our users, collaborators or third parties, as mentioned in section 4 above, are located.

nocnoc has some services allocated to AWS, which are located in the United States, so nocnoc transfers your personal data internationally to this organization for the purpose of hosting our website and storing data. Among the specific safeguards we have established are contractual clauses on data protection and audits on the supplier.

Link to the AWS Privacy Policy: https://aws.amazon.com/privacy/

8. YOUR RIGHTS

nocnoc respects your privacy and strives to provide the necessary channels for you to exercise your rights and obtain clear and transparent information about the use and processing of your personal data, including the possibility of exercising the following rights:

To confirm the processing of your data by nocnoc, as well as to know the details of the data we hold about you, how we process it and with whom we share it.

Receive information on the possibility of not providing consent and the consequences of refusal, when nocnoc requests your consent for the processing of personal data in a specific situation, as well as the right to revoke consent, where applicable.

Inform nocnoc if you disagree with the processing of your personal data, explaining the reason for your objection, so that we can analyze the situation.

Request corrections if you identify inaccuracies in your stored data.

Request the deletion of your data or the interruption of its use, if we have processed the data in violation of applicable laws.

To request the correction of incomplete, inaccurate or outdated data, or the deletion of data provided to nocnoc, send a message to [email protected].

We will analyze your request and deal with it, unless this results in the interruption of the services provided by nocnoc or falls under any of the data retention hypotheses specified above.

If you are a nocnoc customer and your request results in the services being discontinued, your relationship with nocnoc will be terminated. However, the obligations arising from the provision of such services, such as the payment of amounts owed to nocnoc and/or its business partners, will remain valid. In this case, your personal information and data will continue to be processed by us and/or authorized third parties until the needs or purposes set out in this Policy cease.

nocnoc will anonymize, block or delete any personal data that becomes unnecessary or excessive and will not process such data in breach of the laws applicable in the jurisdictions in which we operate.

9. CHILDREN

Our services and our site are not directed to children, as we are very concerned about protecting the privacy of children. Therefore, we do not want to collect any personally identifiable information from children.

If a child has provided us with personally identifiable information, his or her parents and/or guardians should contact us through the contact information below. If we become aware that data of a minor (under the age of 18) has been provided to nocnoc, we will delete such information as soon as possible.

10. COOKIES

Cookies are small files that collect information about your browser or device. They allow us to better understand how our website is accessed, how many people visit it, and how we can personalize your experience. Cookies play an important role on our platform, and we use different types of them:

Session cookies: These help us recognize you and the information you provided when using our Platform. Session cookies will be deleted from your device when you close your web browser.

Permanent cookies: We use permanent cookies to enable our Platform to recognize you when you visit it. Permanent cookies will remain stored on your device until you delete them, or until they reach a specified expiry date.

You can manage cookies on your device, including viewing, deleting, or restricting their use, through your browser settings. However, please note that blocking cookies may affect the functionality of some parts of our platform, and certain features may not operate correctly.

11. OTHER SITES AND SERVICES

Our website may contain links to third-party websites or services. We do not control these sites and recommend that you read their privacy policies.

12. SECURITY OF YOUR PERSONAL DATA

We have a responsibility to safeguard your Personal Data and use it for the purposes described in this Policy. To this end, we have implemented appropriate security practices for our activities, such as the use of encryption techniques, record management, access controls, and other available security measures to prevent information security incidents and preserve the privacy and protection of your Personal Data. The measures adopted include access controls, strong encryption, SSL implementation, firewalls, change log registration, among other mechanisms and protocols.

Please be aware that the transmission of data over the internet is not entirely secure. While we take measures to protect your personal information, we cannot guarantee the security of data transmitted to us electronically.

Therefore, we recommend avoiding the inclusion of confidential, sensitive, or compromising information in communications sent over the internet, including emails. Additionally, it is your responsibility to maintain the confidentiality of your password and user details. In the event that we are obligated to notify you of a data-related incident, we may do so via email or telephone, in accordance with applicable legal requirements.

13. CHANGES TO THIS POLICY

We retain the right to amend this Privacy Policy as needed. In the event of significant alterations to this Privacy Policy, we will inform you by revising the Privacy Policy’s date and publishing it on our website.

Additionally, we may choose to notify you of these changes through alternative methods that we believe will reasonably reach you, such as through email (if you have an account where we possess your contact details) or another suitable method through our website or services.

The adjustments to this Privacy Policy will take effect upon posting the updated terms or upon the implementation of the changes on our website (or as otherwise indicated during posting). In any scenario, your ongoing use of the website or services following the posting of any revised Privacy Policy terms signifies your agreement to the modified Privacy Policy’s terms.

Nothing in this Privacy Policy creates or adds to any right or claim (whether legal, equitable or otherwise) that any individual or person may have at law or otherwise against nocnoc, any third party, or their respective directors, officers, delegates, employees, agents or representatives. In addition, the existence of this Privacy Policy or its enforcement does not impose or add any obligations or liabilities on nocnoc or the parties mentioned that they do not already have otherwise under applicable law.

14. HOW TO CONTACT US

For questions or comments about this Policy or our privacy practices, please contact us at [email protected]

Last Updated: November 7th, 2023