1.Introduction
This privacy notice (“Notice”) describes how the companies in Noah’s group (together referred to as "Noah", "we" or "us") will make use of your data, including what data we collect from you, what we will use it for and whom we share that data with.
It applies to the processing activities in which Noah acts as a data controller. This means we decide how to process your data and have certain responsibilities in relation to your data.
It also describes your data protection rights, including the right to object to some of the processing which Noah carries out. These rights vary according to the laws in different jurisdictions. More information about your rights, and how to exercise them, is set out in the local jurisdiction addendums.
Please note that some privacy rights and obligations may differ in certain locations based on applicable local data protection laws. We have included supplemental information for certain jurisdictions as addendums to this Notice.
2.Personal data we process about you
We collect and process personal data about you when you interact with us, our websites (including noah.com), mobile apps, emails or social media pages, and when you access or use our products and services. This includes:
| Category | Details |
| Identification Information | Your name, username and password (or other login credentials), gender, age/date of birth, facial biometrics (based on your ID and provided selfie and/or video), passport or driving licence, tax identification number, or details from any other identity documents you provide to us. |
| Contact Information | Your title, name, home address (and address history), email address and phone number. |
| Marketing Information | Your marketing preferences, including any consents you have given us. |
| Device and Web Information | Online identifiers (including IP address), information related to the browser or device you use to access our websites and/or mobile applications, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs) and methods used to browse away from the page. This also includes information obtained via cookies and similar technologies – see our Cookie Policy for further information. |
| Financial Information | Banks account details, card details, wallet address details and transaction details. |
| Account Activity Information | Information about your relationship with us, including the products and services you use, and your ways of interacting with us. |
| Due Diligence and Compliance Information | Information from investigations we conduct such as due diligence checks, sanctions and anti-money laundering checks and information collected and used for our other regulatory and compliance checks. |
| Support and Complaints Information | Details about your query or complaint, and the progress and outcome of your query or complaint. |
Sometimes, we receive information about you from third parties and public sources. In particular:
3.How do we use this information
We will process your personal data for the purposes set out below:
4.Privacy in relation to blockchains
Please note that we will record certain transactions on a public blockchain. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. If you interact with our products and services (including via third party partners) to initiate a transaction, Blockchain Data will be recorded on the blockchain. While this information does not contain your name, it is stored on the blockchain where all transactions are transparent and viewable by anyone in principle for as long as the blockchain exists. This transparency is a core feature of most blockchains, ensuring trust and security.
By itself, your public key address does not directly identify you. However, if it is linked to other information - like if you share your address publicly and link it to you - this may lead to your identification and the revelation of personal data.
We also want to note that because blockchains are decentralized or third-party networks which are not controlled or operated by Noah, we are not able to erase, modify, or alter personal data on such networks.
However, it also means you should be mindful of how and where you use your public address if you want to protect your privacy.
5.How we share your personal data
We share your data with the following categories of recipients:
| Recipient | Why? |
| Noah Group of Companies | To operate, improve, develop our services, and respond to your requests. |
| Banking Partners and Third-Party Service Providers | To provide services to you, including to execute transactions and fulfil our contractual obligations to you. We also employ other companies and individuals to perform functions on our behalf. Examples include website hosting and maintenance, customer service operations, identity checking, sending communications and providing customer service. |
| Third-Party Partners | Where you access our services via a third party, we will share personal data with that party to enable the provision of the products/services. |
| Credit Reference Agencies, Law Enforcement and Fraud Prevention Agencies | To prevent, investigate and/or report fraud, terrorism, misrepresentation, security incidents or crime, in accordance with applicable law. |
| Prospective Buyer/Seller and Advisers | In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business. |
| Analytics and Marketing Vendors | To analyse how you use our services, website and our mobile app, and interact with our emails. |
| Legal or Governmental Authorities | Pursuant to a subpoena, court order, governmental inquiry or other legal process or as otherwise required by law, to protect our rights or the rights of third parties or to protect the safety or security of any person or entity. |
We may also share the information we collect with other parties with your consent or otherwise disclosed at the time of data collection or sharing.
We use only those service providers who have installed or committed to install appropriate technical and organisational security measures and we ensure that such service providers comply with the appropriate personal data protection, security and confidentiality obligations.
For U.S. users, note that we may share information that has been de-identified or aggregated without limitation.
6.Digital advertising and analytics
We may also work with third parties that collect data about your use of our websites or mobile apps over time for non-advertising purposes. Noah uses Google Analytics and other third-party services to improve the performance of the website and for analytics and marketing purposes. For more information about how Google Analytics collects and uses data when you use our websites, visit www.google.com/policies/privacy/partners, and to opt out of Google Analytics, visit tools.google.com/dlpage/gaoptout.
Additionally, your browser may offer tools to limit the use of cookies or to delete cookies; however, if you use these tools, our websites may not function as intended.
7.Third-party links and tools
As discussed above, our websites may provide links to third-party websites or apps. We do not control the privacy practices of those websites or apps, and they are not covered by this privacy policy. You should review the privacy policies of other websites or apps that you use to learn about their data practices.
Our websites also include integrated social media tools or “plug-ins,” such as social networking tools offered by third parties. If you use these tools to share personal data or you otherwise interact with these features on our websites, those companies may collect data about you and may use and share such data in accordance with your account settings, including by sharing such data with the general public.
Your interactions with third-party companies and your use of their features are governed by the privacy policies of the companies that provide those features. We encourage you to carefully read the privacy policies of any accounts you create and use.
8.Your Choices
To opt out of our email marketing, you can use the link provided at the bottom of each marketing message. If you opt out of our email marketing, we will still send you messages related to our transactions and relationship with you, such as order confirmations.
9.Updates to this Notice
We reserve the right to update this Notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal data.
10.Contact us
If you have questions, comments or concerns about this notice or wish to contact us for any reason in relation to our personal data processing, please contact us at support@noah.com or you can write to us using the relevant postal address: