Introduction

At NodeMaven FZ-LLC (“us”, “we”, “our” or the “Company”) we value your privacy and the importance of protecting your data. We also operate technical services, including proxy, API, dashboard, account-management and related infrastructure services, which require us to process certain account, billing, technical, usage, security, compliance and abuse-prevention data in order to provide, secure and protect our services. This Privacy Policy (the “Policy”) describes our privacy practices for the activities set out below. As per your rights, we inform you how we collect, store, access, and otherwise process information relating to individuals. In this Policy, personal data (“Personal Data”) refers to any information that on its own, or in combination with other available information, can identify an individual.

We are committed to protecting your privacy in accordance with the highest level of privacy regulation. As such, we follow the obligations under the below regulations:

Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and the applicable provincial legislations
Quebec Law 25
The EU’s General Data Protection Regulation (GDPR)
Brazil’s Data Protection Legislation (LGPD)
California’s Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA) and California Online Privacy Protection Act (CalOPPA)
Colorado Privacy Act (CPA)
Utah Consumer Privacy Act (UCPA)
Connecticut Data Privacy Act (CTDPA)
Virginia Consumer Data Protection Act (VCDPA)
South Africa’s Protection of Personal Information Act (POPIA)

Scope

This Policy applies to the NodeMaven FZ-LLC websites, domains, applications, dashboards, APIs, proxy services, infrastructure services, customer accounts, support channels, billing systems, compliance processes, abuse-prevention processes, and related services and products.

This Policy does not apply to third-party applications, websites, products, services or platforms that may be accessed through (non-NodeMaven FZ-LLC) links that we may provide to you. These sites are owned and operated independently from us, and they have their own separate privacy and data collection practices. Any Personal Data that you provide to these websites will be governed by the third-party’s own privacy policy. We cannot accept liability for the actions or policies of these independent sites, and we are not responsible for the content or privacy practices of such sites.

Processing Activities

This Policy applies when you interact with us by doing any of the following:

Make use of our Website, dashboard, API, proxy services, infrastructure services, customer account, support channels or related services as an authorized user;
Visit any of our websites that link to this Privacy Policy;
Create an account, purchase a subscription, use a free trial or promotional code, make or request a payment or refund, contact support, report abuse, submit documents, complete verification, or otherwise communicate with us;
Use, access, configure, route traffic through, integrate with, resell where authorized, or manage any NodeMaven service.

Personal Data We Collect

What Personal Data We Collect

When you make a purchase, or attempt to make a purchase, we collect the following types of Personal Data. This includes:

Account Information such as your name, email address, and password
Payment Information such as your billing address, phone number, credit card, debit card or other payment method

When you use our products and/or features, we collect the following types of Personal Data:

Account Information such as your name, email address, and password
Payment Information such as your billing address, phone number, credit card, debit card or other payment method

Verification and Compliance Information, such as business name, registered address, tax information, company registration information, beneficial ownership information, identity documents, proof of authority, intended use case, target websites or platforms, sanctions screening results, source-of-funds information, wallet ownership information, payment verification information, fraud-prevention information and other information requested for KYC/KYB, AML/CTF, sanctions, payment, fraud, cybersecurity, abuse-prevention or legal compliance purposes.

Technical and Usage Information, such as IP addresses used to log in to your account, authentication logs, API keys, API requests, dashboard activity, assigned proxy endpoints, session timestamps, bandwidth usage, protocol information, connection status, error logs, device identifiers, browser type, operating system, approximate location, account activity, service configuration, and other technical information generated when you use the Services.

Proxy Service Metadata, such as session metadata, assigned endpoint information, traffic volumes, connection timestamps, target host or domain metadata where reasonably necessary for service delivery, billing, troubleshooting, abuse prevention, security, fraud detection, sanctions compliance, legal compliance, or protection of our services and third parties.

Abuse, Security and Risk Information, such as abuse reports, threat intelligence, suspicious activity indicators, fraud indicators, chargeback indicators, refund-abuse indicators, wallet-risk indicators, blocked or restricted domains, platform complaints, infrastructure-provider complaints, law-enforcement requests, regulator requests, security alerts, investigation records and actions taken in response to such information.

Supplier, Network and Compliance Information, where applicable, such as information received from or relating to suppliers, partners, infrastructure providers, network providers, carriers or other third parties involved in providing or supporting the Services, including compliance confirmations, consent-related information, audit records, abuse reports, network integrity information, supplier risk assessments, security reviews and records necessary to verify that relevant proxy resources are lawfully sourced and operated.

How We Collect Your Personal Data

We collect Personal Data from the following sources:

From You. You may give us your Account Information, Payment Information, Financial Information, Demographic Data, Purchase Information, Content, Feedback, Product Information, by filling in forms, using our products or services, entering information online or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide, for example, when you:

Create an account or purchase products on our website;
Use our products or services;
Access or use our proxy infrastructure, APIs, dashboards, account-management tools, support channels or related services;
Generate traffic, sessions, API calls, account activity, payment activity, refund requests, verification requests, abuse reports, support tickets, technical logs, security events or compliance events through the Services;
Provide KYC/KYB, AML/CTF, sanctions, payment, wallet, source-of-funds, beneficial ownership, business, use-case or verification information;
Create content through our products or services;
Express interest in our products or services;
Download software and/or our mobile application;
Subscribe to our newsletter;
Complete a voluntary market research survey;
Contact us with an inquiry or to report a problem (by phone, email, social media, or messaging service);
Log in to our website via social media.

Automated technologies or interactions. As you interact with our website, we may automatically collect the following types of data (all as described above): Device Data about your equipment, Usage Data about your browsing actions and patterns, and Contact Data where tasks carried out via our website remain uncompleted, such as incomplete orders or abandoned baskets. We collect this data by using cookies, server logs and other similar technologies. Please see our Cookie section (below) for further details.

Third parties. We may receive Personal Data or risk-related information about you from various third parties, including:

Account Information and Payment Information from another individual when they purchase a gift for you on our website;
Device and Usage Data from third parties, including analytics providers such as Google;
Account Information and Payment Data from social media platforms when you log in to our website using such social media platforms;
Content from communication services, including email providers and social networks, when you give us permission to access your data on such third-party services or networks;
Account Information and Payment Data from third parties, including organizations (such as law enforcement agencies), associations and groups, who share data for the purposes of fraud prevention and detection and credit risk reduction;
Account Information, Payment Data, and Financial Data from providers of technical, payment and delivery services; and
payment processors, cryptocurrency payment providers, wallet-screening providers, fraud-prevention providers, KYC/KYB providers, sanctions-screening providers, cybersecurity vendors, threat-intelligence providers, hosting providers, infrastructure providers, network providers, affected platforms, rights holders, complainants, regulators, courts, law-enforcement agencies and other parties who provide information for service delivery, billing, security, fraud prevention, abuse detection, legal compliance, sanctions compliance, dispute resolution or protection of our rights and services.

If you provide us, or our service providers, with any Personal Data relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Policy. If you believe that your Personal Data has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Data, please contact us by using the information set out in the “Contact Us” section below.

Device and Usage Data

When you visit a NodeMaven FZ-LLC website, we automatically collect and store information about your visit using browser cookies (files which are sent by us to your computer), or similar technology. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. The Help Feature on most browsers will provide information on how to accept cookies, disable cookies or to notify you when receiving a new cookie. If you do not accept cookies, you may not be able to use some features of our Service and we recommend that you leave them turned on.

Data We Collect From Third Parties

We may receive your Personal Data from third parties such as companies subscribing to NodeMaven FZ-LLC services, partners and other sources. This Personal Data is not collected by us but by a third party and is subject to the relevant third party’s own separate privacy and data collection policies. We do not have any control or input on how your Personal Data is handled by third parties. As always, you have the right to review and rectify this information. If you have any questions you should first contact the relevant third party for further information about your Personal Data. Where that third party is unresponsive to your rights, you may contact the Data Protection Officer at NodeMaven FZ-LLC (contact details below).

Our websites and services may contain links to other websites, applications and services maintained by third parties. The information practices of such other services, or of social media networks that host our branded social media pages, are governed by third parties’ privacy statements, which you should review to better understand those third parties’ privacy practices.

Purpose and Legal Basis for the Processing of Personal Data

We collect and use your Personal Data where we have a lawful basis to do so, including where processing is necessary to perform our contract with you, comply with legal obligations, protect our legitimate interests, protect the rights and safety of third parties, establish, exercise or defend legal claims, prevent fraud or abuse, comply with sanctions or payment obligations, or where you have provided consent where consent is required by applicable law.

These purposes include:

To deliver your product or service;
To assess, verify, monitor and document the legality, security, integrity, consent status and compliance posture of suppliers, partners, infrastructure providers, network providers, carriers, proxy resources and other third-party resources used to provide or support the Services;
To fulfill orders including electronic and non-electronic shipment;
Providing, developing, and improving our products and services;
Delivering, maintaining, debugging and improving our products and services;
Enabling you to access NodeMaven FZ-LLC services and set up accounts;
Providing you with technical and customer support;
Communicating with you about the products and services;
To operate, deliver, secure, maintain, troubleshoot, debug, monitor, improve and protect the Website and Services;
To authenticate users, manage accounts, process payments, verify refunds, verify wallet ownership, prevent chargebacks, prevent refund abuse and manage subscriptions;
To conduct KYC/KYB, AML/CTF, sanctions, export-control, fraud-prevention, abuse-prevention, payment, cybersecurity, legal and regulatory checks;
To detect, prevent, investigate and respond to misuse of the Services, including malware, botnet activity, spam, phishing, credential attacks, unauthorized access, DDoS, fraud, platform abuse, unlawful scraping, sanctions evasion and other prohibited activities;
To process abuse reports, platform complaints, infrastructure-provider complaints, payment processor requests, regulator requests, court orders, law-enforcement requests and legal notices;
To enforce our Terms of Service, Acceptable Use Policy, payment terms, refund policy and other contractual rights;
To protect NodeMaven, its affiliates, suppliers, infrastructure providers, payment providers, customers, users, partners, affected third parties and the public;
To establish, exercise or defend legal claims, preserve evidence, cooperate with competent authorities and comply with applicable laws and regulations.

Where we process your Personal Data to provide a product or service, we do so because it is necessary to perform contractual obligations. All of the above processing is necessary in our legitimate interests to provide products and services and to maintain our relationship with you and to protect our business for example against fraud. Where consent is required by applicable law, we will request your consent and you may withdraw it as described in this Policy. However, certain processing is necessary for contract performance, legal compliance, security, fraud prevention, abuse prevention, sanctions compliance, payment processing, service delivery, dispute resolution and the establishment, exercise or defense of legal claims. If you do not provide information required for these purposes, we may be unable to provide the Services, process payments or refunds, maintain your account, or continue our relationship with you.

Third Party Tools

We may use third-party service providers to store, process, secure, verify, analyze or manage information, including payment processors, cryptocurrency payment providers, hosting providers, cloud providers, analytics providers, email providers, support tools, KYC/KYB providers, fraud-prevention providers, sanctions-screening providers, wallet-screening providers, cybersecurity vendors, threat-intelligence providers and infrastructure providers. These may include Stripe and other providers used by us from time to time.

International Data Transfer and Storage

Where possible, we store and process data on servers within the general geographical region where you reside (note: this may not be within the country in which you reside). Your Personal Data may also be transferred to, and maintained on, servers residing outside of your state, province, country or other governmental jurisdiction where the data laws may differ from those in your jurisdiction. We will take appropriate steps to ensure that your Personal Data is treated securely and in accordance with this Policy as well as applicable data protection law.

Sharing and Disclosure

We will share your Personal Data with third parties only in the ways set out in this Policy or set out at the point when the Personal Data is collected.

We may share Personal Data, technical data, usage data, security data, payment data, wallet data, verification data, abuse-prevention data and related information with our affiliates, service providers, payment processors, banks, cryptocurrency payment providers, wallet-screening providers, KYC/KYB providers, sanctions-screening providers, fraud-prevention providers, cybersecurity vendors, infrastructure providers, hosting providers, network providers, analytics providers, legal advisers, auditors, insurers, regulators, courts, law-enforcement agencies, affected platforms, rights holders, complainants and other relevant third parties where reasonably necessary for service delivery, billing, payment processing, refunds, verification, security, fraud prevention, abuse detection, sanctions compliance, legal compliance, dispute resolution, enforcement of our Terms of Service, protection of our rights, or protection of third parties.

We also use Google Analytics to help us understand how our customers use the site. You can read more about how Google uses your Personal Data here: google.com/policies/privacy.

You can also opt out of Google Analytics here: tools.google.com/dlpage/gaoptout.

We may also use your Personal Data to provide you with targeted marketing via advertisements or communications (such as newsletters).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at networkadvertising.org/understanding-online-advertising/how-does-it-work.

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at optout.aboutads.info.

Legal Requirement

We may use or disclose your Personal Data in order to comply with a legal obligation, in connection with a request from a public or government authority, or in connection with court or tribunal proceedings, to prevent loss of life or injury, or to protect our rights or property. Where possible, lawful and practical to do so, we may tell you in advance of such disclosure. However, we may not provide prior notice where prohibited by law, where the request is confidential, where notice would prejudice an investigation, where there is an emergency or security risk, or where we believe notice would increase legal, fraud, cybersecurity, abuse, sanctions, regulatory, platform, payment or third-party risk.

Service Providers and Other Third Parties

We may use a third party service provider, independent contractors, agencies, or consultants to deliver and help us improve our products and services. We may share your Personal Data with marketing agencies, database service providers, backup and disaster recovery service providers, email service providers and others but only to maintain and improve our products and services. For further information on the recipients of your Personal Data, please contact us by using the information in the “Contact Us” section below.

Cookies

What Are Cookies?

A cookie is a small file with information that your browser stores on your device. Information in this file is typically shared with the owner of the site in addition to potential partners and third parties to that business. The collection of this information may be used in the function of the site and/or to improve your experience.

How We Use Cookies

To give you the best experience possible, we use the following types of cookies:

Strictly Necessary. As a web application, we require certain necessary cookies to run our service.
Preference.
- We use preference cookies to help us remember the way you like to use our service.
- Some cookies are used to personalize content and present you with a tailored experience. For example, location could be used to give you services and offers in your area.
Analytics. We collect analytics about the types of people who visit our site to improve our service and product.
Marketing. We share cookies with third party advertisers and/or partners to help provide you with a personalized marketing experience.
We also allow third party partners to put their own cookies on our website.

Retention and Deletion

We will retain Personal Data for as long as reasonably necessary for the purposes for which it was collected, including to provide the Services, manage accounts, process payments and refunds, comply with legal, tax, accounting, AML/CTF, sanctions, cybersecurity and regulatory obligations, resolve disputes, enforce our agreements, investigate abuse, prevent fraud, protect our services and establish, exercise or defend legal claims.

Different categories of data may be retained for different periods depending on the purpose of processing, legal requirements, risk level and operational needs. For example, account records, billing records, payment records, refund records, KYC/KYB records, sanctions-screening records, security logs, usage logs, proxy session metadata, abuse reports, investigation records, support records and legal records may be retained for different periods where reasonably necessary for compliance, security, fraud prevention, abuse prevention, dispute resolution and legal claims.

When we no longer need Personal Data, we will delete it, anonymize it or securely retain it in accordance with applicable legal, security, backup, archival and compliance requirements. We may retain limited information where necessary to prevent re-registration by abusive users, maintain suppression lists, comply with sanctions or legal obligations, preserve evidence, prevent fraud or abuse, or protect our rights and third parties.

Merger or Acquisition

If we are involved in a merger, acquisition or asset sale, your personal information may be transferred. We will provide notice before your personal information is transferred and becomes subject to a different Privacy Policy. Under certain circumstances, we may be required to disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

How We Keep Your Data Safe

We have appropriate organizational safeguards and security measures in place to protect your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.

The communication between your browser and our website uses a secure encrypted connection wherever your Personal Data is involved.

We require any third party who is contracted to process your Personal Data on our behalf to have security measures in place to protect your data and to treat such data in accordance with the law.

In the unfortunate event of a Personal Data breach, we will notify you and any applicable regulator when we are legally required to do so.

Your Rights for Your Personal Data

Depending on your geographical location and citizenship, your rights are subject to local data privacy regulations. These rights may include:

Right to Access (PIPEDA, GDPR Article 15, CCPA/CPRA, CPA, VCDPA, CTDPA, UCPA, LGPD, POPIA) — You have the right to learn whether we are processing your Personal Data and to request a copy of the Personal Data we are processing about you.
Right to Rectification (PIPEDA, GDPR Article 16, CPRA, CPA, VCDPA, CTDPA, LGPD, POPIA) — You have the right to have incomplete or inaccurate Personal Data that we process about you rectified.
Right to be Forgotten (right to erasure) (GDPR Article 17, CCPA/CPRA, CPA, VCDPA, CTDPA, UCPA, LGPD, POPIA) — You have the right to request that we delete Personal Data that we process about you, unless we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
Right to Restriction of Processing (GDPR Article 18, LGPD) — You have the right to restrict our processing of your Personal Data under certain circumstances. In this case, we will not process your Data for any purpose other than storing it.
Right to Portability (PIPEDA, GDPR Article 20, LGPD) — You have the right to obtain Personal Data we hold about you, in a structured, electronic format, and to transmit such Personal Data to another data controller, where this is (a) Personal Data which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you or the third party that subscribes to NodeMaven FZ-LLC services.
Right to Opt Out (CPRA, CPA, VCDPA, CTDPA, UCPA) — You have the right to opt out of the processing of your Personal Data for purposes of: (1) targeted advertising; (2) the sale of Personal Data; and/or (3) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Under CPRA, you have the right to opt out of the sharing of your Personal Data to third parties and our use and disclosure of your Sensitive Personal Data to uses necessary to provide the products and services reasonably expected by you.
Right to Objection (GDPR Article 21, LGPD, POPIA) — Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for processing which override your interests and rights, or if we need to continue to process the Personal Data for the establishment, exercise or defense of a legal claim.
Nondiscrimination and Nonretaliation (CCPA/CPRA, CPA, VCDPA, CTDPA, UCPA) — You have the right not to be denied service or have an altered experience for exercising your rights.
File an Appeal (CPA, VCDPA, CTDPA) — You have the right to file an appeal based on our response to you exercising any of these rights. In the event you disagree with how we resolved the appeal, you have the right to contact the attorney general:
- If you are based in Colorado, please visit this website to file a complaint.
- If you are based in Virginia, please visit this website to file a complaint.
- If you are based in Connecticut, please visit this website to file a complaint.
File a Complaint (GDPR Article 77, LGPD, POPIA) — You have the right to bring a claim before the competent data protection authority. If you are based in the EEA, please visit edpb.europa.eu/about-edpb/about-edpb/members_en for a list of local data protection authorities.

Your rights may be limited where permitted by applicable law, including where processing or retention is necessary for legal compliance, security, fraud prevention, abuse prevention, sanctions compliance, payment processing, dispute resolution, establishment, exercise or defense of legal claims, protection of third-party rights, preservation of evidence, or compliance with court, regulator or law-enforcement requests.

We may refuse, limit or delay a request where we are unable to verify your identity, where the request is manifestly unfounded or excessive, where disclosure would adversely affect the rights and freedoms of others, where disclosure would compromise security or abuse-prevention measures, or where applicable law permits or requires us to do so.

Withdrawing Consent

If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge, such as where you wish to opt out from marketing messages that you receive from us. If you wish to withdraw your consent, please contact us using the information found at the bottom of this page.

How to Exercise Your Rights

You can make a request to exercise any of these rights in relation to your Personal Data by sending the request to our privacy team using the form below.

For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.

Changes

We may modify this Policy at any time. If we make changes to this Policy then we will post an updated version of this Policy at this website. When using our services, you will be asked to review and accept our Privacy Policy. In this manner, we may record your acceptance and notify you of any future changes to this Policy.

Contact Us

To request a copy of your information, unsubscribe from our email list, request for your data to be deleted, or ask a question about your data privacy, we’ve made the process simple.

To contact us regarding privacy matters, please email [email protected].

To report abuse, misuse, security concerns, unlawful activity, suspected botnet activity, malware, phishing, credential attacks, spam, platform abuse, non-consensual proxy use, infringement, or third-party rights concerns involving the Services, please contact us at [email protected] or any dedicated abuse-reporting address made available by us from time to time. Please include sufficient supporting information to allow us to assess the report, such as timestamps, IP addresses, domains, URLs, logs, screenshots, headers, transaction identifiers, wallet addresses, account details or any other relevant evidence.