Privacy Policy
Effective Date: 1 January 2024
Thank you for visiting Nakamoto Notes (“we,” “us,” “our”). We respect your privacy and are committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit www.nakamotonotes.com (the “Site”) and when you interact with any of our services—now or in the future.
1. Who We Are
Data Controller: Nakamoto Notes*
Registered Address: Almere, The Netherlands
Email: privacy@nakamotonotes.com
Because we are established in the Netherlands, the General Data Protection Regulation (EU) 2016/679 (“GDPR”) applies to our processing of personal data, even when we serve users outside the European Economic Area (“EEA”).
2. Scope of This Policy
This Policy applies to:
- Visitors who browse or interact with the Site;
- Users who may create an account in the future; and
- Any other interaction you have with us (e.g., support requests, newsletter sign-ups).
It does not apply to third-party websites, services, or applications that we do not control. We encourage you to review the privacy policies of any third-party services you access.
3. Information We Collect
3.1 Information We Collect Now (No Account Required)
| Category | Examples | Purpose |
|---|---|---|
| Device & Log Data | IP address, browser type & version, operating system, referrer URL, time-stamp, pages visited, error logs. | Ensure the Site functions securely, debug errors, generate anonymous usage statistics. |
| Cookies & Similar Tech | Session cookies, analytic cookies (if enabled). | Maintain your session, remember preferences, improve performance. |
We do not combine this data with other identifiers to create user profiles.
3.2 Information We Collect When You Create an Account
When you create an optional user account, we collect:
- Account Identifiers (e.g., username, password hash, email address);
- Profile Data (e.g., profile photo, preferred fiat currency, account preferences);
- Communication Data (e.g., messages you send us, support tickets);
- Usage Data linked to your account (e.g., saved indicators, dashboard settings, portfolio data if provided).
All account creation is voluntary, and we only collect data necessary to provide the requested services.
4. Legal Bases for Processing (GDPR Art. 6)
| Legal Basis | When We Rely on It |
|---|---|
| Consent (Art. 6 (1)(a)) | Optional features (e.g., analytics cookies; marketing emails). |
| Contract (Art. 6 (1)(b)) | Providing requested services (e.g., maintaining your account). |
| Legal Obligation (Art. 6 (1)(c)) | Compliance with Dutch tax, bookkeeping, or regulatory requirements. |
| Legitimate Interests (Art. 6 (1)(f)) | Security, fraud prevention, internal analytics, improving the Site—provided your rights do not override our interests. |
5. How We Use Your Information
- Operate & Maintain the Site: Monitor uptime, troubleshoot, and ensure security.
- Improve Services: Analyze aggregated usage patterns to refine features.
- Communicate with You: Reply to inquiries or legal requests.
- Account Features: Provide personalized dashboards, save preferences, process payments, and maintain user accounts.
- Legal & Regulatory Compliance: Keep records and respond to lawful requests.
We do not sell or rent your personal data to third parties.
6. Cookies & Similar Technologies
We use only strictly necessary cookies by default. Optional cookies (e.g., Google Analytics) will be loaded only with your prior consent, obtained via a cookie banner that complies with EU Directive 2002/58/EC (e-Privacy Directive) and GDPR.
You can manage or delete cookies via your browser settings. Detailed information is provided in our separate Cookie Statement (link on the Site footer).
7. Disclosure to Third Parties
We may share your data with:
- Service Providers: Hosting partners, content-delivery networks (CDNs), email delivery platforms, and payment processors—solely to perform services on our behalf.
- Professional Advisers: Lawyers, auditors, insurers, when necessary.
- Authorities: Government bodies, regulators, or courts when legally required or to protect our rights.
Whenever we transfer data to third parties, we enter into data-processing agreements (DPAs) that meet GDPR Art. 28, ensuring adequate safeguards.
8. International Data Transfers
Our primary servers are located in the EU. If we transfer personal data outside the EEA (e.g., to a U.S. cloud provider), we will rely on:
- An adequacy decision (GDPR Art. 45); or
- Standard Contractual Clauses (SCCs) approved by the European Commission (GDPR Art. 46).
9. Data Security
We employ administrative, technical, and physical safeguards such as:
- HTTPS/TLS encryption in transit;
- Firewall and intrusion-detection systems;
- Regular security audits and patch management;
- Strict access controls and multi-factor authentication for admin accounts.
However, no internet transmission is 100 % secure. We cannot guarantee absolute security, but we work continuously to protect your data.
10. Data Retention
- Browsing Data: Erased or anonymised within 14 days.
- Account Data: Stored for as long as your account is active. We will delete or anonymise it within 30 days after you close the account, unless we must keep it longer for legal reasons.
- Legal/Tax Records: Retained for up to 7 years, as required by Dutch law.
11. Your Rights (GDPR Arts. 15–22)
You have the right to:
- Access your personal data;
- Rectify inaccurate or incomplete data;
- Erase data (“right to be forgotten”);
- Restrict processing;
- Object to processing based on legitimate interests;
- Data Portability (obtain your data in a structured, machine-readable format);
- Withdraw Consent at any time (without affecting prior lawful processing);
- Lodge a Complaint with a supervisory authority. Our lead authority is the Autoriteit Persoonsgegevens (autoriteitpersoonsgegevens.nl).
To exercise any of these rights, email us at privacy@nakamotonotes.com.
12. Children’s Privacy
Our services are not directed to children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us personal data, please contact us so we can delete it.
13. Changes to This Privacy Policy
We may update this Policy from time to time. We will post the new version on this page and, where material changes apply, notify you via the Site or email (if you have an account) at least 14 days before the changes take effect.
14. Contact Us
Nakamoto Notes
Attn: Privacy Officer
Almere, The Netherlands
Email: privacy@nakamotonotes.com