1. INTRODUCTION
This Privacy Notice ("Notice") describes how NUVA (BVI) SPC Ltd., a British Virgin Islands segregated portfolio company ("NUVA SPC") and NUVA Foundation, an exempted limited guarantee foundation company incorporated in the Cayman Islands with limited liability (the "NUVA Foundation", and together with NUVA SPC, "NUVA," "we," "us," or "our"), collects, uses, discloses, processes, and protects information in connection with our website located at nuva.finance (the "Site") and the related services, tools, features, and functionalities we provide (collectively, the "Services").
NUVA is committed to processing personal data in accordance with Applicable Law, including but not limited to, in the case of NUVA Foundation, the Data Protection Act (Revised) of the Cayman Islands, as amended from time to time and includes any regulations, codes of practice or orders promulgated pursuant thereto (the Cayman DPA).
For purposes of applicable data protection laws, each of NUVA Foundation and NUVA SPC is the data controller and data processor with respect to the personal information we collect.
Please read this Notice carefully. By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Notice. If you do not agree with this Notice, you must not access or use of the Services.
This Notice is incorporated into and forms part of our Terms of Service. capitalized terms not defined in this Notice have the meanings given to them in our Terms of Service.
Interpretation: For the purpose of this Notice, "you" or "your" shall mean, you, the user or prospective user of the Services and shall also include any individual connected to you which could include: any person owning or controlling you or having a beneficial interest in you, any person for whom you are acting as agent or nominee, any trustee, settlor or protector of a trust, any person acting as guarantor or third party security provider on behalf of you, or any other persons or entities with whom you have a relationship that is relevant to your relationship with us, and the directors, managers, members, officers and employees of all such persons Any phrase introduced by the terms "including", "include" or any similar expression shall be construed as illustrative and shall not limit the sense of the words proceeding those terms.
2. IMPORTANT INFORMATION ABOUT OUR SERVICES
2.1 Blockchain Transparency
All transactions on the Provenance Blockchain and other blockchains are publicly visible and permanent. Information recorded on blockchains, including wallet addresses and transaction details, is accessible to anyone and cannot be deleted or modified.
2.2 Limited Information Collection
Because of the non-custodial nature of our Services, we collect minimal personal information. We do not require account registration for most Services. We may collect Know Your Customer (KYC) information to the extent specifically required by Applicable Law.
3. INFORMATION WE COLLECT
We collect information in several ways depending on how you interact with our Services.
3.1 Information You Provide Directly
We collect the following information directly from you when you use our Services that you provide to us:
Contact Information
Name
Email address
Company name (if applicable)
Communication preferences
Inquiry and Support Information
Messages, questions, or comments you send to us
Information you provide when requesting support or assistance
Feedback, survey responses, or testimonials
Professional Information (for business partnerships or employment inquiries)
Resume or CV
Professional background and qualifications
References and employment history
Event and Marketing Information
Information you provide when registering for events, webinars, or newsletters
Preferences for receiving communications
3.2 Information We Collect Automatically
When you access or use our Services, we and our third-party service providers may automatically collect certain information, including:
Device and Browser Information
Device type, model, and operating system
Browser type and version
Screen resolution
Device identifiers (such as mobile advertising IDs)
Usage Information
Pages visited on the Site
Features and content accessed
Links clicked
Time spent on pages
Referring website or source
Date and time of access
Search queries entered
Location Information
IP address
General geographic location (city and country) derived from IP address
Technical Information
Log files and server logs
Error reports and diagnostic information
Performance metrics
3.3 Cookies and Similar Technologies
We use cookies, web beacons, pixels, local storage, and similar tracking technologies ("Cookies") to collect information automatically. Cookies are small data files stored on your device that help us:
Remember your preferences and settings
Understand how you use our Services
Analyze traffic and usage patterns
Improve the functionality and performance of our Services
Detect and prevent fraud and security issues
You can control Cookies through your browser settings. However, if you disable Cookies, some features of our Services may not function properly. For more information, see Section 9 (Your Rights and Choices).
3.4 Blockchain Information
Because our Services relate to blockchain-based protocols, we may collect or observe the following publicly available blockchain information:
Wallet Information
Blockchain wallet addresses you use to interact with the Protocol
Wallet provider (e.g., Keplr, Cosmostation)
Public keys associated with wallet addresses
Transaction Information
Transaction hashes and identifiers
Blockchain wallet and IP addresses involved in transactions (including originator and recipient/beneficiary information, where applicable)
Transaction amounts and timestamps
Asset types transferred
Gas fees paid
Block numbers, unique transaction reference numbers and confirmation status
Protocol Interaction Data
Interactions with nuAsset Vaults
Staking activities with $NUVA
veNUVA holdings and governance participation
nuAssetToken balances and transactions
Smart contract function calls
Asset Holdings
Balances of $NUVA, veNUVA, and nuAssetTokens
Historical balance changes
Asset transfers and movements
IMPORTANT: This blockchain information is publicly available on the Provenance Blockchain and other blockchains. We do not control this information and cannot delete or modify it. Anyone can view this information using blockchain explorers or similar tools.
3.5 Information from Third-Party Sources
We may receive information about you from third-party sources, including:
Analytics Providers
Usage data and analytics
Demographic information
Interest and behavior data
Social Media Platforms
Profile information (if you interact with us on social media)
User ID and username
Demographic information (subject to platform settings)
Business Partners and Service Providers
Information from event organizers
Data from marketing platforms
Information from professional networking sites
Publicly Available Sources
Information from blockchain explorers
Publicly available professional information
Industry news and publications
Third-Party Data Providers
Fraud prevention and security data
Compliance screening data
Enhanced due diligence information (when required by law)
We may combine information from these third-party sources with information we collect directly from you or automatically.
3.6 Third-Party Wallet Connections
To interact with the Protocol, you may connect a third-party digital wallet (such as Keplr, Cosmostation, MetaMask, or similar wallets) to our Services. When you connect a wallet:
We may receive your wallet address and public key
We do NOT receive or have access to your private keys or seed phrases
Your use of the wallet is governed by the wallet provider's privacy policy
We are not responsible for the privacy practices of wallet providers
We strongly recommend that you review the privacy policies of any third-party wallets you use.
3.7 Information We Do NOT Collect
To be clear, NUVA SPC does NOT collect or have access to:
Private keys or seed phrases
Passwords for wallets or accounts
Biometric information
Financial account information (bank accounts, credit cards, etc.)
Government-issued identification documents (unless specifically required by Applicable Law)
Social security numbers or national identification numbers (unless specifically required by Applicable Law)
Precise geolocation information (GPS coordinates)
Health information
Information about children under 18 years of age
4. HOW AND WHY WE USE INFORMATION
By virtue of your use of the Services, NUVA and its affiliates and delegates (each an Authorized Entity and together, the Authorized Entities) may collect, record, store, transfer and otherwise process personal data by which individuals may be directly or indirectly identified. We may combine personal data that you provide to us with personal data that we collect from or about you. This may include personal data collected in an online or offline context including from available public databases or data sources, such as news outlets, websites and other media sources and international sanctions lists. It may also include data which, when aggregated with other data, enables an individual to be identified, such as an IP address and geolocation data.
Your personal data will be processed fairly and for lawful purposes, including for:
4.1 Providing and Maintaining Services
To provide access to the Site and Services
To facilitate your use of and interaction with the Services
To satisfy our contractual duties and obligations to you pursuant to any agreements or other relevant contractual agreements between you and us
To process and respond to your inquiries and requests
To provide customer support and technical assistance
To send transactional messages, notifications, and updates
To troubleshoot technical issues and errors
To maintain, monitor, and improve the Services
To ensure the Services function properly
4.2 Safety and Security
To detect, prevent, and respond to fraud, illegal activity, and security incidents
To protect against malicious, deceptive, or illegal activity
To verify the legitimacy of transactions and interactions
To screen against Prohibited Persons and Restricted Territories
To enforce our Terms of Service and other policies
To protect our rights, property, and safety, and the rights, property, and safety of our users and others
To comply with sanctions and export control regulations
To conduct security audits and assessments
4.3 Analytics and Improvement
To analyze how users access and use the Services
To understand user preferences, trends, and behavior
To monitor and analyze usage patterns and statistics
To improve the design, functionality, and performance of the Services
To develop new features, products, and services
To conduct research and data analysis
To test and optimize our Services
To create aggregated and de-identified data for analysis
4.4 Communications and Marketing
To send you informational content about the Protocol and Services
To provide updates about nuAsset Vaults and new features
To send newsletters, announcements, and educational materials
To invite you to events, webinars, or community activities
To notify you about changes to our Services or policies
To send promotional materials (with your consent where required)
To respond to your communications and feedback
You may opt out of marketing communications at any time (see Section 9).
4.5 Legal and Regulatory Compliance
To comply with Applicable Laws, or any other legal, tax or other regulatory obligations to which NUVA or you are subject
To respond to legal process, including subpoenas, court orders, and law enforcement requests
To comply with anti-money laundering (AML), counter-terrorist financing (CTF) and prevention of proliferation financing requirements
To conduct sanctions screening and export control compliance
To fulfill reporting and disclosure obligations
To establish, exercise, or defend legal claims
To prevent and detect fraud;
To protect against legal liability
4.6 Business Operations
To manage our business relationships and partnerships
To process employment applications and recruit personnel
To facilitate corporate transactions (e.g., mergers, acquisitions, or asset sales)
To maintain records and documentation
To conduct internal audits and quality assurance
To manage risk and ensure business continuity
4.7 Other Purposes
To fulfill any other purpose disclosed to you at the time of collection
To carry out any purpose for which you provide consent
For any other lawful business purpose
4.8 Purpose Limitation
We will only process your data for the specific purposes notified in this Notice at the time of collection or for any other purpose specifically permitted by Applicable Law. We do not envisage that any decisions will be taken about you using fully automated means, however we will notify you in writing if this position changes.
5. LEGAL BASIS FOR PROCESSING (EEA, UK, AND SWITZERLAND)
If you are located in the European Economic Area (EEA), United Kingdom (UK), Switzerland, we process your personal information based on the following legal grounds:
5.1 Contract Performance
We process your information to perform our obligations under the Terms of Service and to provide you with the Services you have requested.
5.2 Legitimate Interests
We process your information based on our legitimate business interests, including:
Operating, maintaining, and improving our Services
Understanding how users interact with our Services
Preventing fraud and enhancing security
Conducting analytics and research
Marketing our Services (where permitted)
Protecting our legal rights
We balance our legitimate interests against your rights and interests to ensure fair processing.
5.3 Legal Compliance
We process your information to comply with our legal obligations, including:
AML/CTF compliance
Sanctions screening
Tax reporting
Responding to legal process
Regulatory requirements
5.4 Consent
Where required by law, we obtain your consent to process certain information, such as for marketing communications or use of certain Cookies. You may withdraw your consent at any time by contacting us.
5.5 Vital Interests
In rare cases, we may process your information to protect vital interests, such as to prevent serious harm or danger to individuals.
As a data controller, we will only use your personal data for the purposes for which we collected it as set out in this Policy. If we need to use your personal data for an unrelated purpose, we will contact you. In certain circumstances, we may share (or be required to share) your personal data with regulatory, prosecuting, and other governmental agencies or departments, and parties to litigation (whether pending or threatened), in any country or territory in accordance with Applicable Law.
6. HOW WE SHARE AND DISCLOSE INFORMATION
We may share your information in the following circumstances:
6.1 Service Providers and Vendors
We share information with third-party service providers who perform services on our behalf, including:
Website hosting and infrastructure providers
Analytics and data analysis providers
Customer support and communication platforms
Email and messaging services
Marketing and advertising platforms
Security and fraud prevention services
Payment processors (for business services, if applicable)
Cloud storage providers
Technical maintenance and support vendors
These service providers are contractually obligated to use your information only for the purposes of providing services to us and to protect the confidentiality and security of your information.
6.2 Authorized Entities
We may share information with Authorized Entities (including sharing information between NUVA Foundation and NUVA SPC). We may use your information consistent with this Notice or their own privacy policies provided the standards at least equivalent to ours.
6.3 Business Partners
We may share information with business partners for joint initiatives, collaborations, or co-marketing activities, with your consent where required.
6.4 Legal and Regulatory Authorities
We may disclose information to government authorities, regulators, law enforcement, courts, and other public authorities when required or permitted by law, including:
In response to subpoenas, court orders, or legal process
To comply with legal or regulatory requirements
To cooperate with government investigations
To report suspicious activity as required by AML/CTF laws
To comply with sanctions screening obligations
To enforce our rights or defend against legal claims
To protect the safety and security of users and the public
6.5 Corporate Transactions
If either NUVA SPC or NUVA Foundation is involved in a merger, acquisition, reorganization, bankruptcy, sale of assets, or similar corporate transaction, your information may be disclosed, transferred, or sold as part of that transaction, subject to confidentiality obligations and Applicable Law. We will notify you of any such transaction that affects your information.
6.6 With Your Consent or Direction
We may share your information with third parties when you provide consent or direct us to do so.
6.7 Publicly Available Blockchain Information
Information recorded on public blockchains is accessible to anyone. We have no control over how others may use or access this publicly available information. This includes:
Wallet addresses
Transaction details
Asset holdings
Smart contract interactions
Protocol participation
Anyone can view this information using blockchain explorers or similar tools.
6.8 Aggregated and De-Identified Information
We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you. Such information is not subject to this Policy.
6.9 Protection of Rights and Safety
We may disclose information when we believe in good faith that disclosure is necessary to:
Protect against fraud, illegal activity, or security threats
Prevent physical harm or financial loss
Investigate violations of our Terms of Service
Protect our rights, property, and safety
Protect the rights, property, and safety of our users and others
7. DATA RETENTION
7.1 Retention Periods
We retain your information for as long as necessary to fulfill the purposes described in this Notice unless a longer retention period is required or permitted by law.
Factors we consider in determining retention periods include:
The nature and sensitivity of the information
The purposes for which we process the information
Whether we can achieve those purposes through other means
Legal, regulatory, tax, accounting, or reporting requirements
Whether the information is necessary to establish, exercise, or defend legal claims
Risk management and fraud prevention needs
Records retention requirements
7.2 Specific Retention Periods
Contact and Communication Information: We retain contact information and communications for as long as necessary to respond to inquiries and provide support, typically 5 years after the last interaction.
Usage and Analytics Data: We retain usage data and analytics for as long as necessary for analytics purposes, typically 24-36 months.
Blockchain Information: Blockchain information is permanently recorded on public blockchains and cannot be deleted. We may retain copies of blockchain information indefinitely.
Legal and Compliance Records: We retain information necessary for legal, regulatory, or compliance purposes for at least 5 years, or longer if required by law.
7.3 Deletion and Anonymization
The personal data shall not be held by NIUVA SPC for longer than necessary regarding the purposes of the data processing. When we are no longer required to retain or no longer need your information, we will:
Securely delete or destroy the information
Anonymize the information so it can no longer identify you
Retain only aggregated, anonymized information for analysis
However, we may retain information longer if required by law or to protect our legal rights.
7.4 Your Right to Request Deletion
You may request deletion of your information as described in Section 9 (Your Rights and Choices). However, we may decline deletion requests in certain circumstances permitted by law, such as where retention is necessary for legal compliance or to establish or defend legal claims.
8. INTERNATIONAL DATA TRANSFERS
8.1 Global Operations
NUVA operates globally, and your information may be transferred to, stored in, and processed in countries other than the British Virgin Islands and the Cayman Islands, as the case may be.
We may transfer your personal data outside of the British Virgin Islands or the Cayman Islands, as permitted under Applicable Law, including but not limited to, the Cayman DPA.
When we transfer information internationally, we implement appropriate safeguards to protect your information in accordance with Applicable Law.
You have the right to obtain information as to any countries or territories outside the Cayman Islands to which we, whether directly or indirectly, transfer, intend to transfer or wish to transfer your personal data, general measures we take to ensure the security of personal data and any information available to us as to the source of your personal data.
8.2 Transfers from the EEA, UK, and Switzerland
If you are located in the EEA, UK, or Switzerland, we may transfer your personal information to countries outside these regions, including to the United States, the British Virgin Islands and the Cayman Islands.
When we transfer personal information outside the EEA, UK, or Switzerland, we ensure appropriate safeguards are in place, such as:
Standard Contractual Clauses (SCCs): We use SCCs approved by the European Commission or UK Information Commissioner's Office for transfers to countries without adequacy decisions.
Adequacy Decisions: We may transfer information to countries deemed adequate by the European Commission or UK authorities.
Appropriate Safeguards: We implement technical, organizational, and contractual measures to protect transferred information.
8.3 Your Rights Regarding International Transfers
You may contact us to obtain information about the safeguards we use for international transfers and to request a copy of relevant documentation.
9. YOUR RIGHTS AND CHOICES
9.1 Access and Correction
You have the right to:
Request access to the personal information we hold about you
Request a copy of your personal information
Request correction of inaccurate or incomplete information
Update your contact information and communication preferences
To exercise these rights, contact us at legal@nuva.finance.
9.2 Deletion
You may request deletion of your personal information, subject to certain exceptions, such as where we need to retain information for legal compliance, to establish or defend legal claims, or for other lawful purposes.
Important Note: We cannot delete information recorded on public blockchains, as blockchain information is permanent and immutable.
9.3 Restriction and Objection
Depending on your location, you may have the right to:
Restrict how we process your information
Object to processing based on legitimate interests
Object to direct marketing at any time
Object to processing that is likely to cause damage or distress to you or anyone else
9.4 Data Portability
In certain circumstances, you have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another controller.
9.5 Withdrawal of Consent
If we process your personal data based on your consent, you may withdraw your consent and require us to stop processing or restrict the processing, or not begin the processing of your personal data;. Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal.
9.6 Marketing Communications Opt-Out
You may opt out of receiving marketing communications from us by:
Clicking the "unsubscribe" link in marketing emails
Adjusting your communication preferences
Contacting us at legal@nuva.finance
Even if you opt out of marketing communications, we may still send you transactional or Service-related messages.
9.7 Right to be informed
You have the right to be informed that your personal data is collected and, how it is being held and the basis upon which it may be processed.
9.8 Data portability
You have the right to require the movement, copy of transfer of your personal data from one IT environment to another in a safe and secure way.
9.9 Data breaches
You have the right to be notified of a data breach (unless the breach is unlikely to be prejudicial).
9.10 Cookie Controls
You can control Cookies through your browser settings:
Browser Settings: Most browsers allow you to:
View and delete Cookies
Block Cookies from specific websites
Block third-party Cookies
Clear all Cookies when you close your browser
Configure your browser to notify you when you receive Cookies
Cookie Management Tools: You may use the following tools:
Network Advertising Initiative Opt-Out Tool: http://optout.networkadvertising.org/
Digital Advertising Alliance Opt-Out Tool: http://optout.aboutads.info/
European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/
Do Not Track: Some browsers include a "Do Not Track" (DNT) signal. Our Services do not currently respond to DNT signals because there is no industry standard for DNT implementation.
9.11 Mobile Device Settings
You can control certain data collection on mobile devices through your device settings, such as:
Limiting ad tracking
Resetting your advertising identifier
Disabling location services
Managing app permissions
9.12 Exercising Your Rights
To exercise any of these rights, contact us at legal@nuva.finance. We may need to verify your identity before responding to your request.
We will respond to your request within the time period required by Applicable Law, typically within 30 days. If we need additional time, we will inform you of the extension and the reasons for it.
9.12 Right to Lodge a Complaint
If you are located in the EEA, UK, or Switzerland, you have the right to lodge a complaint with a supervisory authority if you believe we have violated applicable data protection laws. However, we encourage you to contact us first so we can address your concerns.
EU Supervisory Authorities: https://edpb.europa.eu/about-edpb/board/members_en
UK Information Commissioner's Office: https://ico.org.uk/make-a-complaint
You the right to complain to the Office of the Ombudsman of the Cayman Islands. You can access their website here: ombudsman.ky; and
Please note that if you do not wish to provide us with requested personal data or subsequently withdraw your consent, it will affect NUVA's ability to provide our services to you.
10. DATA SECURITY
10.1 Security Measures
We implement reasonable technical, organizational, and physical security measures designed to protect your information from unauthorized access, disclosure, alteration, and destruction, including:
Technical Measures:
Encryption of data in transit and at rest
Secure network architecture and firewalls
Access controls and authentication mechanisms
Regular security assessments and vulnerability testing
Intrusion detection and prevention systems
Secure software development practices
Organizational Measures:
Employee training on data protection and security
Confidentiality agreements with employees and contractors
Access controls limiting information access to authorized personnel
Incident response and breach notification procedures
Regular security audits and reviews
Vendor management and due diligence
Physical Measures:
Secure facilities and data centers
Physical access controls
Environmental controls and monitoring
10.2 Limitations of Security
Despite our security measures, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your information.
You are responsible for:
Maintaining the security of your devices
Protecting your Wallet and private keys
Using secure internet connections
Not sharing your passwords or credentials
Reporting any security concerns to us promptly
10.3 Third-Party Security
We cannot control the security practices of third-party services, including blockchain networks, wallet providers, and other services you use in connection with the Protocol. You use such services at your own risk.
10.4 Breach Notification
In the event of a data breach that affects your information, we will notify you and relevant authorities as required by Applicable Law.
11. CHILDREN'S PRIVACY
11.1 Age Restrictions
Our Services are not intended for, and may not be used by, individuals under 18 years of age (or the age of legal majority in your jurisdiction). We do not knowingly collect personal information from children under 18.
11.2 Parental Notice
If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at legal@nuva.finance. We will promptly delete such information.
11.3 Age Verification
If we discover that we have collected information from a child under 18 without appropriate consent, we will delete that information as quickly as possible.
12. THIRD-PARTY SERVICES AND LINKS
12.1 Third-Party Services
Our Services may integrate with or provide access to third-party services, including:
Wallet providers (e.g., Keplr, Cosmostation, MetaMask)
Blockchain explorers
Democratized Prime and Figure Markets Holdings, Inc.
Analytics providers (e.g., Google Analytics)
Social media platforms
Other DeFi protocols and applications
These third-party services have their own privacy policies. We are not responsible for their privacy practices.
12.2 Third-Party Links
Our Site may contain links to third-party websites or resources. We do not control these third-party sites and are not responsible for their content, privacy policies, or practices. We encourage you to review the privacy policies of any third-party sites you visit.
12.3 Social Media
We may maintain profiles on social media platforms. When you interact with us on social media, the platform's privacy policy governs the information you share. We may collect information you make publicly available on social media platforms.
12.4 Disclaimer
We expressly disclaim any responsibility or liability for:
The privacy practices of third-party services
The security of third-party services
Any loss or damage resulting from your use of third-party services
The accuracy or availability of third-party content
13 REGION-SPECIFIC DISCLOSURES
13.1 European Economic Area, United Kingdom, and Switzerland
Data Controller: NUVA SPC is the data controller for personal information collected through the Services.
Legal Bases: See Section 5 for information about the legal bases for processing.
Data Subject Rights: See Section 9 for information about your rights under the GDPR and UK GDPR.
International Transfers: See Section 8 for information about international data transfers.
Supervisory Authority: You have the right to lodge a complaint with a supervisory authority.
Data Protection Officer: For questions about data protection, contact us at legal@nuva.finance.
13.2 United States
State-Specific Rights: If you are a resident of California, Virginia, Colorado, Connecticut, Utah, or other states with consumer privacy laws, you may have additional rights, including:
Right to know what personal information we collect, use, and disclose
Right to delete personal information
Right to correct inaccurate personal information
Right to opt out of the sale or sharing of personal information
Right to opt out of targeted advertising
Right to opt out of automated decision-making
Right to non-discrimination for exercising your rights
No Sale of Personal Information: We do not sell personal information as defined by state privacy laws.
Sensitive Personal Information: We do not collect or process sensitive personal information except as necessary to provide the Services and as permitted by law.
Automated Decision-Making: We do not engage in automated decision-making that produces legal or similarly significant effects.
Appeals: If we deny your request, you may appeal by contacting us at legal@nuva.finance.
13.4 Other Jurisdictions
If you are located in a jurisdiction with specific privacy laws, you may have additional rights. Contact us to learn more about your rights.
14. CHANGES TO THIS PRIVACY POLICY
We will continue to review the effectiveness of this Notice to ensure it is achieving its stated objectives. For this reason, this Notice may be amended at any time.
14.1 Updates
We may update this Notice from time to time to reflect changes in our practices, Services, legal requirements, or for other reasons. When we make changes, we will update the "Last Updated" date at the top of this Policy.
14.2 Notice of Material Changes
If we make material changes to this Policy, we will provide notice by:
Posting a prominent notice on our Site
Sending an email notification (if we have your email address)
Other reasonable means
14.3 Your Continued Use
Your continued use of the Services after the effective date of any changes constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop using the Services.
14.4 Review
We encourage you to review this Policy periodically to stay informed about how we protect your information and to ensure that you are always aware of how personal data is collected, used, stored and disclosed.
15. CONTACT US
If you have any questions, concerns, or requests regarding this Notice or our privacy practices, please
Email: legal@nuva.finance and legal@nuva.foundation
We will respond to your inquiry as promptly as possible, typically within 30 days unless a shorter time is required by Applicable Law.
END OF PRIVACY POLICY
Version: 1.0
Effective Date: November 17, 2025
Last Updated: November 19, 2025
