Privacy Policy

1. Introduction

Welcome to Nexor's privacy policy.

Nexor respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

2. Important information and who we are

2.1. Purpose of this privacy policy

2.1.1. This privacy policy aims to give you information on how Nexor collects and processes your personal data through your use of this website, including any data you may provide through this website when you join our waitlist or sign up for our services.

2.1.2. This website is not intended for children and we do not knowingly collect data relating to children.

2.1.3. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

2.2. Controller

2.2.1. Nexor Global Inc is the controller and responsible for your personal data (collectively referred to as “Nexor”, “we”, “us” or “our” in this privacy policy).

2.2.2. Nexor Global Inc is incorporated in Ontario, Canada, with company registration number 1000952388, and is a licensed Money Services Business under registration number CI000000211. This privacy policy is issued on behalf of Nexor, so when we mention “Nexor”, “we”, “us” or “our” in this privacy policy, we are referring to the Nexor entity responsible for processing your data.

2.2.3. Our legal team is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our legal team using the details set out below.

2.3. Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our legal team at support@nexor.africa. You have the right to make a complaint at any time to the applicable data privacy regulator in your country. We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance.

2.4. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

2.5. Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

3. The data we collect about you

3.1. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

3.2. We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, email address and telephone numbers.
• Financial Data includes your payment and bank account information.
• Transaction Data includes details about settlements to and from you, and on your behalf, and other details of our services you have signed up for.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
• Profile Data includes your username and password, instructions and orders made by you, your interests, preferences and feedback.
• Usage Data includes information about how you use our website, products and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

3.3. We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. If we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3.4. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences, except where required as part of regulated compliance screening.

3.5. If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our settlement services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

4. How is your personal data collected?

We use different methods to collect data from and about you, including through:

4.1.1. Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us by phone, email or otherwise. This includes personal data you provide when you create an account with Nexor, join our waitlist, subscribe to our services, request marketing to be sent to you, or give us feedback or contact us.

4.1.2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies.

4.1.3. Third parties or publicly available sources. We may receive Technical Data from analytics providers and search information providers; Contact, Financial and Transaction Data from providers of technical, banking and payment services; and Identity and Contact Data from publicly available sources such as company registries and sanctions or compliance screening providers.

5. How we use your personal data

5.1. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

5.2. Generally, we do not rely on consent as a legal basis for processing your personal data, although we will get your consent before sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

6. Purposes for which we will use your personal data

We have set out below a description of the ways we plan to use your personal data and the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

7. Marketing and promotional offers from us

7.1. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

7.2. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

7.3. You may receive marketing communications from us if you have requested information from us, joined our waitlist or signed up for our services, and you have not opted out of receiving that marketing.

7.4. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

7.5. You can ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of previous transactions with us.

8. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

9. Change of purpose

9.1. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

9.2. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

9.3. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

10. Disclosures of your personal data

10.1. We may share your personal data with internal third parties (other companies in Nexor), external third parties (professional advisers, banks, settlement and payment partners, and compliance providers), and third parties to whom we may choose to sell, transfer or merge parts of our business or our assets.

10.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

11. International transfers

11.1. We share your personal data within Nexor. This may involve transferring your data outside your country of residence, subject to local data protection regulations.

11.2. Many of our external third parties are based outside Canada, the UK and the EU, so their processing of your personal data will involve an international transfer of data.

11.3. Whenever we transfer your personal data internationally, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented: we only transfer your personal data to countries that have been deemed to provide an adequate level of protection; you have consented to the transfer; or the transfer is necessary for the performance of a contract you have with us or another party.

11.4. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data internationally.

12. Data security

12.1. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

12.2. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13. Data retention

13.1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. As a licensed Money Services Business, we are required to retain certain transaction and identification records for a defined statutory period.

13.2. To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it, and the applicable legal requirements.

13.3. In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

14. Your legal rights

14.1. Under certain circumstances, you have rights under data protection laws in relation to your personal data, including to request access to, correction of, or erasure of your personal data; to object to or request restriction of processing; to request transfer of your personal data; and to withdraw consent.

14.2. If you wish to exercise any of the rights set out above, please contact us at support@nexor.africa.

14.3. No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

14.4. What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it.

14.5. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

15. Glossary

Lawful basis

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We consider and balance any potential impact on you and your rights before we process your personal data for our legitimate interests.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Third parties

Internal third parties — other companies in Nexor acting as joint controllers or processors and who provide settlement services.

External third parties — professional advisers including lawyers, bankers, auditors and insurers; and settlement partners such as banks, mobile money operators and payment aggregators who we partner with to provide our services to you.

16. Company details

Nexor Global Inc (formerly Retorna)
Ontario, Canada
Company registration number: 1000952388
Licensed Money Services Business number: CI000000211
Email: support@nexor.africa