- Nalytoo

Privacy Policy

This Policy describex how NALYTOO LLC handles account data and limited technical metadata processed through the Platform. NALYTOO provides software only and does not control or settle funds.

1. Roles & Contacts

Controller (for account/admin data and website): NALYTOO LLC, PO Box 2804, Kingston, St. Vincent and the Grenadines; [email protected]

Processor (for transaction metadata): when acting on Merchant’s documented instructions to route or relay events to Merchant’s providers.

2. Data Categories

Account/ admin data of Merchant users (name. role, contact details).

Technical metadata for orchestration (timestamps, provider IDs, status codes, routing decisions, webhook logs, limited tokens/identifiers received from Merchant’s providers).

Site/app telemetry and diagnostics; cookie data per Cookie Policy.

3. Purposes & Legal Bases

Provide and secure the Platform; orchestrate connections; monitor performance; generate dashboards/reports; billing; prevent abuse; comply with legal requests. Legal bases (where GDPR applies): contract and legitimate interests; consent for optional analytics/cookies.

4. Recipients & Transfers

Hosting and infrastructure providers; logging/monitoring tools; support tools under data processing terms. International transfers rely on appropriate safeguards (e.g., SCC/IDTA) where required.

5. Retention

Account data – for the contract term. Technical logs – typically 12-24 months, with possible anonymization/aggregation thereafter.

6. Security

We implement organizational and technical measures, including encryption at rest/in transit, network and data segregation, role‑based access control and logging, vulnerability management and regular penetration testing, PCI DSS compliance (if applicable), and business continuity/disaster recovery plans.

7. Rights

Data subjects may request access, correction, deletion (where applicable), restriction, portability, and object to processing. Requests : [email protected]

8. Changes

We may update this Policy; the latest version will be posted with an effective date and, where appropriate, notice of material changes.

9. Retention

• Contract term + [5–10] years (accounting).

• Transaction logs — [3–7] years (audit, disputes, legal obligations).

• Technical logs — up to [12–24] months, then aggregated/anonimized.

• Marketing — until withdrawal of consent or opt‑out.

11. Data Subject Rights

Rights of access, rectification, erasure (where applicable), restriction, portability, objection (including to marketing), withdrawal of consent, and the right to lodge a complaint with a supervisory authority. Requests: [[email protected]] or Mailing/PO Box: 2804, Kingston, St Vincent and the Grenadines

We generally respond within one month, subject to lawful extensions.

12. Cookies and Similar Technologies

We use strictly necessary and (with consent) analytics/marketing cookies. Manage preferences via the cookie banner and browser settings. Details are provided in our separate Cookie Policy.

13. Children

We do not provide services to or enter into contracts with children under 18, nor do we knowingly collect or process their personal data. If we learn that data from a minor has been obtained, we will delete it within a reasonable time.

15. Contact

For any privacy – related questions, rights requests, or incident reports, contact: [[email protected]] or Mailing/PO Box: 2804, Kingston, St Vincent and the Grenadines

If you are in the Saint Vincent and the Grenadines and believe your rights are infringed, you may contact your local supervisory authority.

All Services are provided by NALYTOO LLC

Registration Number: 4209 LLC 2025

Registered office address: Euro, House, Richmond Hill Rd, Kingston, St Vincent and the Grenadines

Mailing/PO Box: 2804, Kingston, St Vincent and the Grenadines

Contacts: [email protected]

Website: www.nalytoo.com