Collection, Use, and Disclosure of Personal Information

In this Policy, "personal data" (a/k/a "Personal information") means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you. Personal data does not include information that is publicly available as defined by applicable privacy laws or is anonymized.

The privacy rules on the protection of personal data are an integral part of the Terms and Conditions.

We collect personal data directly from you that you voluntarily share with us through the Services, indirectly from you through technology (e.g., your activities on the Services), and from NANA Prime users and NANA Prime business partners.

As an advertising service that helps NANA Prime Platform users find NANA Prime Platform caregiver service providers, we must, of course, collect personal information (information that can be found from you). Identifiable data is collected only when you order a caregiver as a NANA Prime user or use the account creation for providing caregiver services as a NANA Prime user.

The data processed must be true and complete, as well as based on a reliable source, i.e., a source that is not outdated. The Company processes the necessary data of persons who have given consent for processing, for a clearly defined purpose, in a legally permissible manner, so that the person whose data is being processed is not specified or identifiable even after the purpose of the processing has been achieved, and in proportion to the purpose of the processing.

Regulations

Before collecting data, the Company, as the Data Controller, informs the person to whom the data relates of the following:

  • That the Data Controller of personal data, i.e., the person responsible for data collection, is the Company.
  • That the purpose of collecting and processing the data is to enable the provision of information society services, the security of NANA Prime Platform users, and to enable the creation and posting of content under the law.
  • That the collected data is used in a way that allows the identification of the person, the user, and by good business practices, the preservation of business secrets, and the law.
  • That the persons who use the data are persons engaged in the Company, who have the authority to use the data, and persons with whom the user enters into an obligatory relationship to the extent necessary to achieve that relationship, as well as all state bodies that, based on law and/or court decisions, exercise the right to use the data.
  • That the provision of personal data is voluntary and that no one who does not want to be a registered user is obligated to provide any data, but that the provision of data is mandatory in the sense of the Law on Obligations and the Law on Electronic Commerce, to exercise the rights from the mentioned laws.
  • That a person who has given consent for the collection and processing of data can, at any time and without justification, withdraw their consent, which as a legal consequence results in the cessation of the possibility of using the service, the maturity of all outstanding obligations arising during the use of the service, as well as the cessation of any further data collection from persons who have withdrawn consent.
  • That in the case of unauthorized data processing, individuals have the right to personal data protection, as well as other rights that belong to them by law.

Data We Collect and Process

  • Full name
  • Contact details (email address, phone number)
  • User account information (country of birth, languages, date of birth, biography)
  • Passport or ID card number (if you are a NANA Prime user who wants to advertise on the NANA Prime Platform and have been selected for a background check)
  • Passport or ID card photo (if you are a NANA Prime user who wants to advertise on the NANA Prime Platform and have been selected for a background check)
  • Criminal record certificate (if you are a NANA Prime user who wants to advertise on the NANA Prime Platform and have been selected for a background check)
  • Customer data
  • Device identifier
  • Customer geolocation, to retrieve the order location

Purpose of the Process

We collect and process personal data for the purpose of advertising NANA Prime Platform users to NANA Prime Platform users to help them manage their businesses more effectively.

We display selected geolocation data of NANA Prime customer addresses to NANA Prime service providers to enable service providers to efficiently reach the location. Geolocation data is collected only when the NANA Prime Platform requests an address. The collection of geolocation data stops after the NANA Prime Platform is closed.

We may use geolocation data to resolve quality issues related to addressing.

We use contact details to notify users about NANA Prime Platform updates.

Your name, phone number, and email will be used to communicate with you.

Customer support data is collected on a case-by-case basis and stored to resolve disputes and service quality issues.

For payment purposes, we use the services of a third party, Stripe LTD. The security of data during payment for a reservation is ensured by Stripe LTD, and the entire payment process takes place through the Stripe LTD SDK service. Payment card data is at no point collected or stored in NANA Prime services.

Stripe is a certified PCI Level 1 service provider. This is the strictest level of certification available in the payment industry. To achieve this, Stripe uses best-in-class security tools and practices to maintain a high level of security.

All card numbers are encrypted at rest using AES-256. Decryption keys are stored on separate machines. None of Stripe's internal servers and daemons can obtain card numbers in plaintext but can request that cards be sent to a service provider on a static whitelist. Stripe's infrastructure for storing, decrypting, and transmitting card numbers operates in a separate hosting environment and does not share any credentials with Stripe's primary services, including our API and website.

Legal Basis

Personal data is processed to provide the service agreed upon with the users. We collect and process personal data submitted by clients during the installation and use of the NANA Prime Platform. A prerequisite for using the NANA Prime Platform is the user's consent to the processing of identification data.

Personal data may also be processed based on legitimate interest, for example, in the investigation and detection of fraudulent payments.

Recipients

Personal data of NANA Prime Platform users is disclosed only to the NANA Prime Platform service provider who has activated the NANA Prime Platform and has been selected by the customer; in that case, the service provider will see the name, order address data, and order details.

A part of the personal data of the NANA Prime Platform service provider is disclosed to all NANA Prime Platform users during the creation of an order. Users will see the name, country of birth, languages spoken, profile picture, biography, and city of business.

After providing a home assistance service, the name of the NANA Prime Platform user will remain visible to the NANA Prime Platform service provider. This is necessary for service providers and clients to resolve any issues related to the provision of services.

Feedback provided by NANA Prime Platform users regarding the quality of NANA Prime Platform service providers is anonymous, and NANA Prime Platform service providers do not receive the names of users who have provided a rating and feedback.

Depending on the client's location, personal data may be disclosed to NANA Prime group companies and partners (local subsidiaries, representatives, branches, agents, etc.). The processing of personal data by NANA Prime group companies and partners will take place under the same conditions as set out in this privacy notice.

Where Is Your Information Stored?

Your data is stored in a PostgreSQL-based database, hosted via the Railway.com service. Access to the database is protected and restricted—only the responsible person in charge of application maintenance has technical access, and all data is stored under applicable data protection regulations. We do not share, sell, or otherwise transfer your data to third parties. All reasonable technical and organizational measures have been taken to ensure the security, confidentiality, and integrity of your data, where data is stored in the admin database. In addition to our market software, your data may be stored on Google Drive and Google Apps for business.

All personal data collected during the provision of services is transmitted and stored in the data centers of Google Firebase Storage, located in the territory of the member states of the European Union. Only authorized employees of NANA Prime and partners have access to personal data and can access the data only to resolve issues related to the use of services (including disputes related to the services of the NANA Prime Platform service provider). For research and scientific purposes, data is used in a non-identified form (anonymized).

How Long Is It Stored?

Your personal data will be stored until you explicitly request that the data be deleted.

Financial data on services provided to customers will be stored for 3 years after the last order.

Data required for accounting purposes will be stored for 7 years [after the last order].

In case of suspicion of a criminal offense, fraud, or providing false data, the data will be stored for 10 years.

In case of payment disputes, the data will be stored until the claims are settled or until such claims expire.

Order history data will be stored for 3 years, after which the data will be anonymized.

Please note that uninstalling the NANA Prime Platform or NANA Prime on your device does not cause your personal data to be deleted.

If the NANA Prime Platform or NANA Prime has not been used for 3 years, we will notify you and ask you to confirm whether the account is still active. If no response is received, the account will be closed and personal data will be deleted unless such data is required to be stored for accounting, dispute resolution, or fraud prevention purposes.

Accessing Your Data

You can access and update your personal data yourself through the NANA Prime Platform (for customers) or the NANA Prime Platform (for service providers).

Otherwise, if you wish to access any of your data, send us an email with such a request to support@nanaprime.com stating the scope of information you wish to receive, the desired format (e.g., .csv, .odf, etc.), and the email address to which the information should be sent.

Deleting Your Data

You can delete your personal data yourself through the NANA Prime Platform.

Also, your personal information can always be deleted at your request, except in cases where we are required to store such information for accounting purposes, or to know your client's regulations related to financial transactions. If you ask us to delete information that we are legally required to store for a certain period, such information will be deleted as soon as we are legally able to do so.

To request the deletion of your data, send us an email with such a request to support@nanaprime.com. All your personal information will be replaced with either hashed or meaningless data (e.g., instead of your real name, the record will be replaced with DELETED_CUSTOMER, your email address with customer_12345@example.com).

You should also note that any request to delete your personal data is only possible if we delete your account. As a result, you will not be able to use the NANA Platform account that has been deleted.

We respond to every request for the deletion of personal data submitted via email within one month and will specify the data deletion period.

Direct Marketing

We will use your email address and/or phone number to send direct marketing messages only if you have permitted us to do so through the NANA Prime Platform. We may personalize direct marketing messages using information about how you use NANA Prime services (frequency of use, orders).

If you no longer wish to receive direct marketing messages, click the "Unsubscribe" link in the footer of our emails or the profile section of the NANA Prime Platform.

Dispute Resolution

Disputes related to the processing of personal data are resolved through customer support at support@nanaprime.com or by calling +381604424338.