We respect and value your privacy as well as the integrity of the information you have provided and/or permitted Us to collect. Thus, We endeavour to follow industry standards to ensure the security and confidentiality of your Personal Information when you use, access, or participate Our Website.
2. Personal Information that We collect
3. How We collect Personal Information
4. How We use Personal Information
5. How We protect Personal Information
6. How long We retain Personal Information
8. Sharing your Personal Information
9. Third-Party Collection of Personal Information
10. Your Legal Rights
11. Cross-Border Transfer of Personal Information
14. How to contact NEW NORDIC GROUP
The personal information that we collect depends on the context of your interactions with us, the choices you make and features you use. The personal information we collect may include the following:
2.1 Personal Information Provided by You
We collect names; mobile phone numbers; email addresses; and information required to verify your eligibility for access to Our Website.
All personal information that you provide to us must be true, complete, up-to-date and accurate, and you must notify us of any changes to such personal information.
2.2 Information automatically collected
We automatically collect certain information when you visit, use or navigate Our Website. This information does not reveal your specific identity (for example your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use Our Website and other technical information. This information is primarily needed to maintain the security and operation of Our Website, and for our internal analytics and reporting purposes.
2.3 The information we collect includes:
• Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in Our Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
• Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access Our Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access Our Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.
We will collect and process Personal Information automatically provided by you under the following situations.
3.1.1 when you voluntarily complete any user survey or provide feedback to Us via emails or any other electronic channels including on our social media accounts;
3.1.2 when you use browser cookies or any other relevant software upon visiting the Website;
3.2 Information collected by the third-party
We will collect your Personal Information from third parties as required or permitted to the extent of applicable laws. Information from the third-party sources will include, but will not limited to, public databases, ID verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.
3.3 Anonymized and Aggregated Data
We use and process your Personal Information for the following purposes or in the following ways:
4.1 To provide Our Services
We respect data protection principles and process personal data only for specified, explicit, and legitimate purposes for which such personal data were provided. We primarily use your Personal Information, either collected or delivered, to enable your use of the Website, to improve the efficiency of our day-to-day Website, to provide you with a personalised experience, and to verify your identity.
4.2 To protect users
We use the information collected to protect Our Website, your information, and archives. We also use IP addresses and cookies to detect suspicious activities and to protect against automated abuse such as spam, phishing and Distributed Denial of Service (“DDoS”) attacks, and other security risks.
4.3 To comply with regulations and compliance
For Our legitimate interests, We will use the information in compliance with our legal obligations, global and local industry standards, and Our AML/KYC/CTF procedures. In the case where it is strictly necessary (i.e., to protect the vital interests of the users or other natural persons, to prevent or mitigate fraud, to fulfil the purpose of public interest, or to pursue Our reasonable interests), We may use and process your Personal Information without obtaining your consent. You hereby expressly authorise NEW NORDIC GROUP to disclose any information relating to you in NEW NORDIC GROUP’s possession to any law enforcement or government officials upon the only request by a subpoena or a valid court order.
4.4 For measurement, research and development purposes
We actively measure and analyse your information to understand the way you use and interact with Our Website, and to provide you with a unique and personalized experience. For example, We keep track of your preferences such as display name, time zone, and so on. This review is continuously conducted by Our operation teams to continuously improve Our Websites’ performance and to resolve issues with user experience.
In addition, We use such information to monitor trends and improve the production and functionality of funding schemes designed on Our Website. Our administration, the content and layout of Our Website, and to develop new services and products for you. We may also share such information with interested qualifying third parties from any research centres, universities, and scientific bodies to change consumer, production, and environmental trends.
4.5 For communication purposes
4.6 To enforce Our Terms of Service
Personal Information is also used to enforce Our Terms of Service continuously and actively among, and other agreements or documents published on the website relating to the product. Activities in this regard include, but are not limited to, reviewing, investigating, mitigating and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. In light of this matter, NEW NORDIC GROUP shall be entitled to freeze/close/delete accounts or any of your activity on Our Website as necessary as to any user found to be engaged in any activities that violate Our Terms of Service, and other agreements (if any).
4.7 For marketing and advertising
We will share your Personal Information with Our marketing partners to target, model, and/or identifying analytics as well as marketing and advertising. We may send you marketing communications to alert you about new strains, products, technological equipment for the plantation, yet you can opt-out of Our marketing activities at any time.
4.8 For other purposes
We also implement certain reasonable security measures to protect your Personal Information from unauthorized access, and such security measures comply with the security practices and procedures as prescribed under the applicable laws.
However, you agree and acknowledge that it is impossible to fully guarantee the security of your Personal Information by implementing the above-mentioned safeguard and measures. It is not absolute protection to your Personal Information and by accessing the services on Our Website.
You agree that We will not hold any responsibility for the acts committed by those who gain unauthorized access to your account or abuse your information and services. In addition, We will not hold any responsibility for any act committed by the third-party service providers who are contractually engaged with Us to maintain an appropriate security measure for protecting your Personal Information. Thus, you are recommended to understand this responsibility and to independently take safety precautions to protect your Personal Information, particularly your credential information such as your username and password. You hereby agree that We will not be liable for any information leakage and other damage or loss not caused by Our intention or gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures.
In addition, We may be required by applicable laws and regulatory requirements to retain certain information, including your Personal Information, your identification verification materials, information relevant to AML/KYC/CTF procedures, information related to your loan transactions, your financial history, and other agreements between Us and third-parties, account statements, and other records after you stop accessing or participating in Our Website.
A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are beneficial and may be used for various purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Our Website will use the following types of cookies:
7.1 Strictly Necessary Cookies
These cookies are essential to enable you to log in, navigate a website, and use its features or to provide a service requested by you. We will not need to obtain your consent to use these cookies.
7.2 Functionality Cookies
These cookies allow Our Website to remember choices you make (such as your username, language, or the region you reside in) and provide enhanced, more personal features. The information these cookies collect remains anonymous, and they cannot track your browsing activity on other websites.
7.3 Performance cookies
These cookies collect information about how you use a website, for example, which pages you go to most often, how much time you spend on a page, record difficulties you may experience while using Our Website such as error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of Our Website.
7.4 Targeting Cookies or Advertising Cookies
These cookies are used to deliver advertisements tailored to you and your interests specifically. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. These cookies remember that you have visited a website, and this information is shared with other organizations such as advertisers. Quite often targeting or advertising cookies will be linked to the sites’ functionality provided by the other organizations.
You may remove these cookies by following the instructions of your device preferences. However, if you choose to disable cookies, some features of Our Website may not operate properly or become inaccessible, and your online experience may be limited.
We may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:
We may disclose Personal Information to the third parties to administer or process a transaction, or services you have authorized or requested, or in the context of facilitating the execution of a loan transaction, or We may disclose Personal Information to third parties that provide supporting services, or analytical information for the Service improvement, only where we have a lawful basis to do so or under an agreement or legal requirements for the transfer of Personal Information.
We will be required to verify your identities by applicable laws and regulatory requirements and rely on third-party services to perform these verifications. Personal Information that you provide to Us during the initial signing-up and applying loan agreement process will be passed to these services at the KYC Verification process and on an ongoing basis thereafter.
We may share your information with law enforcement, and government officials when We are only compelled to do so by a subpoena, a valid court order to prevent financial loss, to report suspected illegal activity or to investigate violations of any of Our Terms of Service or any other applicable policies.
Your relationship with these third parties and their services and tools is independent of your relationship with us. These third parties may allow you to permit/restrict the information that is collected. It may be in your interest to individually restrict or enable such data collections.
We use and process your Personal Information based on a valid lawful basis of the EU General Data Protection Regulation (“GDPR”) and any equivalent regulations (collectively referred to as “Data Protection Laws”). The lawful basis for processing your Personal Information includes (i) your consent, (ii) the performance of a contract, (iii) a legitimate interest, (iv) compliance with legal obligations, (v) protection of your vital interest, and (vi) public task.
Under certain circumstances when you access Our Website, you have the rights under the Data Protection
Laws concerning your Personal Information. These rights include the following:
10.1 Right to be informed
You reserve the right to be informed about the collection, use, and process of your Personal Information.
10.2 Right of access
You reserve the right to request a copy of the Personal Information We hold about you and specific information regarding Our processing of this information.
10.3 Right to rectify
You reserve the right to request Us to update, correct, or complete your Personal Information that you believe to be outdated, inaccurate, or incomplete. You will rectify this at any time by informing Us via our contact channels.
10.4 Right to erasure (“Right to be Forgotten”)
You may request to have your Personal Information deleted from Our record where (i) your Information is no longer necessary to be used for Our Website, (ii) Information was collected concerning processing that you previously consented to, but later withdrew such consent, or (iii) you Information was collected concerning processing activities to which you object, and there are no overriding legitimate grounds for Our processing.
10.5 Right to data portability
You reserve the right to request to transfer a machine-readable copy of your Personal Information to you or the third party of your choice. We will provide you, or a third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have consented to use.
10.6 Right to restrict processing
You may request Us to restrict or suppress the processing of your Personal Information under certain circumstances as follows:
• to establish the accuracy of the Personal Information;
• when the processing is considered unlawful, but you do not wish to have your Personal Information erased;
• where We no longer need to process your Personal Information, but the information must be retained for legal reasons; and
• where you have objected to Our processing your Personal Information, but We need to determine whether Our legitimate interest overrides your objection.
10.7 Right to object
You may object to Our reliance on Our legitimate interests as the basis of Our processing of your Personal Information that impacts your rights. You may also object to Our process of your Personal Information for direct marketing purposes.
10.8 Right to withdraw consent (“Opt-out”)
You reserve the right to withdraw your consent at any time where We are relying on it to process your Personal Information. Withdrawing your consent does not affect the lawfulness of Our processing of your Personal Information before withdrawing.
If you wish to exercise these rights as aforementioned, please inform and contact Us via Our Website, including the website, and official social media accounts or send a request to admin@newnordicgroup.
Please also be noted that there are some limitations when you wish to exercise any one of these individual rights. We may limit your rights in the following situations:
• Where denial of access is required by-laws;
• When granting access would harm others’ privacy;
• To protect Our rights and properties;
• Where the request is burdensome.
Our Website contains the transmission of your Personal Information to or to be transferred to or to be processed outside of the countries where you are located, it is not suggestible if your Personal Information is restrictive.
However, if you wish to continue using the NEW NORDIC GROUP website outside your home locations, We will ensure that We will transfer your Personal Information only to a country that has the required contractual provisions for transferring Personal Information in place with third parties to which your information is transferred, or to a country where is approved by the EU authorities as providing an adequate level of data protection or enter into legal agreements ensuring an adequate level of data protection in the jurisdiction of the party receiving the information. In this manner, you hereby expressly consent to this transfer and agree that We will not be responsible for any additional Terms of Service, policies or any other guidelines implemented by any party receiving the information.
12.2 We cannot guarantee that any loss, misuse, unauthorized access, or alteration of your Personal Information will not occur. You hereby agree that you play a vital role in protecting your Personal Information, including your credentials.
Furthermore, We may provide you with the “just-in-time” disclosures or additional information about Our data collection process, purposes for processing, or other information concerning the collection of your personal information. The purpose of the just-in-time notification is to supplement or clarify Our privacy practice or provide you with additional choices about how We process your personal information.