Privacy Policy

Who we are?

We’re Nosso Limited (‘we’, ‘our’, ‘us’) and operate under the name Nosso. We’re registered with the UK data protection authority (the Information Commissioner’s Office or ICO), as a data controller, under number ZA797424.
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This notice provides you with information regarding your rights and obligations and explains how, why and when we collect and process your personal data. We take personal data seriously. Anything containing personally identifiable information is kept safe and we have put in place appropriate technical and other security measures to protect it.

Personal Data is any personally identifiable information that you provide us with in the course of our business relationship, whether that’s a completed business relationship, an ongoing business relationship or a potential business. It does not include details, such as usage of websites and/or apps, where the identifiable information has been removed and can no longer relate personally to you.
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We take Personal Data seriously. Anything containing personally identifiable information is kept safe and we have put in place appropriate technical and other security measures to protect it.

For more information, email us at contact@withnosso.com or write to us at 13-17 Margett Street, Cottenham, Cambridge, England, CB24 8QY.
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What data do we collect?

When you sign up to the Nosso app:

When you sign up and use the Nosso app we collect the following information:

We collect identity and contact information about you such as your name, date of birth, address, email address and national insurance number.
We collect information on your partner such as their name and email address if you wish to invite them to your account. We rely on your consent to collect this information and to email them and invite them to the Nosso app.
We collect identity data of your child including their name and date of birth.
We collect financial data such as your bank account number and sort code.
We collect other personal data such as the images you upload for profile pictures of you and your child, the information you provide us about your goals. We also collect information on your device, location and how you interact with our app.
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When you interact with the Nosso website:

We gather information on your device, location and how you navigate around our website. We use this information to improve our platform and service as it helps us identify the type of people that our messaging most resonates with and what parts of our site they understand. Some of these details may be shared with third party platforms including, but not limited to, Google Analytics. In all cases, these details are anonymous as they don’t not include any personal information (e.g. your name).

When you sign up for our waiting list:

We collect your email address when you sign up for our waiting list. We use this to keep you informed and updated on our progress and allow you to be part of the Nosso community. When you leave your email address, we will confirm that you have opted into our services. Any electronic marketing communications we send you will include clear instructions to follow should you wish to unsubscribe at any time.

Why we use your information?

European Data protection laws say we need to have a lawful basis for using your personal data. At least one of the following must apply: contractual or legal duty, legitimate interest, public interest, vital individual interest or consent. In this section we explain which one we rely on to use your data in a certain way.

At this stage in our product, we use your data when it’s in our ‘legitimate interest’, with your consent and to comply with our legal duties.‍
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Legitimate interest:

We need to use your data for our legitimate interests, or those of a third party. This means using data in a way that you might expect us to, for a reason which is in your and/or our (or a third party’s) interest and which doesn’t involve overriding your privacy rights. For marketing we:

Tell you about products and services through our website or other channels such as social media based on how you engage with our site and overtime how you engage with our product. We do this so we can make sure our marketing is useful. That includes instructing platforms to show or not show Nosso adverts to existing customers. We don’t share any identifying information with social media companies other than your mobile advertising ID. You can disable or reset your mobile advertising ID in your device’s operating system.
Track, analyse and improve the services we give you and other customers and how you respond to ads we show. We may ask for feedback if you’ve shown interest in a service. We do this so that we can make our products better and understand how to market them.
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Consent:

We’ll ask for your consent before we send you any marketing mail telling you about our product and service. Any electronic marketing communications we send you will include clear instructions to follow should you wish to unsubscribe at any time.
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We do not rely on consent as a legal basis for processing your personal data where we use the data to meet our contractual obligations to you and / or regulatory requirements.

Legal Duty:

As a financial services provider, we must verify your identity and the accuracy of the details you provide us with. For this purpose, we may use your Data with third party service providers to comply with our legal obligations.

Where we store or send your data

We may transfer and store the data we collect from you to organisations outside the UK and the European Economic Area (‘EEA’). When we do this, we make sure that your data is protected and that:

the European Commission says the country or organisation has adequate data protection, or
we’ve agreed to standard data protection clauses approved by the European Commission with the organisation.
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How long we store your data

We may store and process your Personal Data for the duration of your relationship with us, and some time thereafter, as necessary to comply with our legal and contractual obligations. We may also keep Personal Data related to you, such as messages, pictures, greetings, etc, that we collected from third parties for the duration of our relationship with you. There is no legal obligation to keep this data so we will delete it or transfer it to you if and when we terminate our business relationship.
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What do we do with your data

To allow us to open investment products for you such as Junior ISAs, General Investment Accounts or any other products we may offer in the future, we also share your data with WealthKernel Ltd who are the principal and custodian of your assets.

We use your Personal Data to and we share it with our partners to:

Provide you with the products and services you have subscribed to,
Comply with our legal obligations regarding identification and money laundering prevention, and
Keep you updated with products and services we believe are suited for you or in which you may be interested.

Wealthkernel Ltd, our principal and custodian of your assets; and
Other third parties such as public and private databases, credit score agencies, verification companies, etc.
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What third parties do we currently use?

Google analytics
Webflow
Zapier
Mailchimp
Onfido
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Your rights as a Data Subject

As a Data Subject, you have the rights to:

Access the Data we hold about you, within the limits of the law
Request your Data to be amended, ratified or even deleted
Withdraw your consent at any time
Request your Data to be transferred to another Controller, and
Make a complaint to the ICO
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Please note that whilst you can withdraw your consent at any time. However, we may not be able to provide certain products and services to you if you do so.
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You may ask for Data related to you to be erased, which we will endeavour to do within the scope of applicable regulations.
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You may ask for a copy of the Data we hold about you, and we reserve the right to charge a reasonable fee if the request is unfounded or repetitive.
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You have the right to complain to the ICO, in case you are not satisfied with our services.
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We may make changes to this privacy policy, so please review it every now and then. If appropriate we will notify you by email about changes. Remember, you will be bound by this notice.
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Version 1.0.2
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Terms of use

These terms apply to all users of the Nosso app and website and by using them you agree you have read and accepted these terms.
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The Nosso app and website are made available for use in connection with your use of the Nosso service. You may retrieve and display Nosso URL links and pages on a computer or mobile screen and may print individual pages and store pages for your personal, non-commercial use. Any other use of Nosso materials such as copying URL links or content onto another website or use of the pages or app for anything other than your personal, non-commercial use is prohibited without our prior written permission. The intellectual property in all design, graphics, text and other material and its arrangement in Hapi is owned by us and our respective licensors.
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Nosso provides links to other websites beyond our control. The links to other websites are there for your convenience and we are not responsible for and do not give any warranties or make any representations regarding such websites. We are not responsible for or liable in relation to the content or security of these sites (other than to the extent required by law).
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Nosso is not a financial adviser and we do not provide any type of advice including but not limited to financial, legal or tax. As such, we are not liable for any loss incurred from any services provided on our platforms. If you are unsure about any of our content, please seek specialist and qualified advice.
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Nosso makes reasonable endeavours to ensure reliability of the information presented on the app and website, but makes no warranties or representations whatsoever as to its accuracy or reliability. Similarly, due to the nature of the internet, we do not guarantee that the Nosso will be available on an uninterrupted and error free basis.