Privacy Policy

Introduction

Your privacy is important to Nami ML Inc. and its affiliates (collectively "Nami," "we," "us," or "our"). This online privacy statement describes how we collect, use, disclose, and secure personal information through our website at www.nami.ml, our application, social media accounts, and customer interactions (collectively, the "Services").

Personal information means data classified as personal information or personal data under applicable data privacy and security laws and regulations.

1. You Consent to This Statement

By accessing, browsing, downloading, or otherwise using the Services, you confirm that you have read, understood, and agreed with this Statement. If you do not agree, you may not use the Services.

This Statement applies regardless of how the Services are accessed and covers any technologies or devices by which we make the Services available to you.

We may provide additional privacy notices where appropriate. It is important that you read this Statement together with any other privacy notice or terms we may provide on specific occasions.

If you have questions or concerns about our personal information policies or practices, please contact us as described in the "Contact Us" section below.

2. What Types of Information Do We Collect?

We collect information you voluntarily provide, information we collect automatically, and information collected from third parties.

Categories of Personal Information We Collect

• Account Information: First name, last name, email address, and authentication credentials (passwords are stored as one-way hashes, not in their original form). Collected for account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Analytics Information: Cookies, tracking pixels, tags or similar tools that collect information about your browser, device, geolocation, and interactions with the Services. Collected for account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Contact Information: Name and email address. Collected when you sign up for newsletters, request information, create an account, or fill out a form. Used for account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Commercial History: Information regarding purchases made through our Services and subscription information. Collected for account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Chat Information: Contents of conversations from the Site's chat services. Please note that information relating to your communications may be shared with our service provider. Collected for account creation and management, customer service, and website security and maintenance.
• Payment Information: Name, address, phone number, and debit or credit card information. Collected by us or our service providers for account creation and management, analytics and research, customer service, and website security and maintenance.
• Responses to Surveys and Questionnaires: Information provided when you voluntarily participate in market research surveys such as email address, age, and interested activities. Collected for advertising and marketing, analytics and research, customer service, and website security and maintenance.
• Social Media Information: Information you post by sharing on a blog or another social media platform. Please note that your comments will be visible to the public, so you should never share personal information you would like to keep private. Collected for advertising and marketing, analytics and research, customer service, and website security and maintenance.
• User-Generated Content: If you post, upload, comment, or otherwise submit content on the Services, we may collect information about you such as your name, email address, and products you may have purchased. As a default, any information you post may be available to and searchable by all users. Collected for account creation and management, advertising and marketing, analytics and research, customer service, and website security and maintenance.

Other Ways We May Collect, Use, or Share the Information

• For Legal Purposes: We reserve the right to cooperate with local, provincial, state, federal and international officials in any investigation requiring personal information or reports about lawful or unlawful user activity on this site. We also reserve the right to share your personal information to establish, exercise, or defend our legal and property rights, including providing information to others for the purposes of fraud prevention. We may also share your personal information with any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information.

If we are ordered by a legal process or government to provide data about one or more individual users, we will notify those users of our compliance with that order, to the extent permitted by law.

• To Present the Site: We will use personal information to present our Site and its contents in a suitable and effective manner for you and your device.
• To Provide the Services: We will use personal information to provide the Services, including to improve operations and for security purposes.
• Customer Service: We will use your personal information to provide you with customer service, troubleshoot issues, and respond to requests, questions or comments.
• Marketing communications: We use your contact information to send product updates, event invitations, and offers we think you'll find relevant. You can unsubscribe anytime — see "Advertising and Marketing Choice" below.
• Business Transactions or Mergers: We reserve the right to share your personal information to third parties as part of any potential business or asset sale, merger, acquisition, investment, round of funding, or similar type of transaction. Additionally, if we are entering into a corporate transaction with a third party, we may receive personal information in connection with the diligence. If we close a transaction, the third party may transfer personal information, which we would use as described in this Policy.
• Bankruptcy or Insolvency: In the event of bankruptcy, insolvency, or dissolution proceedings, we may share your personal information with third parties as part of the sale or reorganization process.
• Information From Our Partners: We may collect information from our partners, our affiliates, subsidiaries, joint ventures, or other companies under common control. We may combine that information with other information we collect about you, but we will always use the information as described in this Policy. We may also share information with our affiliates, subsidiaries, joint ventures or other companies under common control.

3. How Do We Use "Cookies" and Other Tracking Technologies?

We may send one or more cookies to your computer or other device. We may also use other similar technologies such as tracking pixels, tags, or similar tools when you visit our Services. These technologies can collect data regarding your operating system, browser type, device type, screen resolution, IP address, and other technical information, as well as navigation events and session information as you interact with our Services. This information allows us to understand how you use the Services.

Our Site also contains embedded applications, widgets, plug-ins, and links to social media platforms and other third-party websites. You consent to the collection, use, and sharing of your personal information when you utilize these features.

What Are Cookies?

Cookies are small files created by websites, including our Services, that reside on your computer's hard drive and that store information about your use of a particular website. When you access our Services, we use cookies and other tracking technologies to:

• Estimate our audience size and usage patterns;
• Store information about your preferences, allowing us to customize our Services according to your individual needs;
• Contact you to provide you with information or services that you request from us;
• Advertise new content, events, and services that relate to your interests;
• Provide you with more personalized content that is most relevant to your interest areas; and
• Recognize when you return to our Services.

We set some cookies ourselves and others are set by third parties. You can manage your cookies preference as described in the "Managing Your Cookies" section below.

What Types of Cookies Do We Use and Why?

The cookies below are representative of those we and our service providers set on the Services. The specific cookies set may vary over time and by page; this table is illustrative.

Cloudflare Turnstile, used to protect our forms (see Section 4), runs in a configuration that does not set cookies on nami.ml.

We do not use analytical tools in a manner that discloses to third parties that a specific person viewed specific video materials.

How Long Do Cookies Stay on My Device?

Some cookies operate from the time you visit the Services until the end of that particular browsing session. These cookies, which are called "session cookies," expire and are automatically deleted when you close your Internet browser.

Some cookies will stay on your device between browsing sessions and will not expire or automatically delete when you close your Internet browser. These cookies are called "persistent cookies" and the length of time they will remain on your device will vary from cookie to cookie. Persistent cookies are used for a number of purposes, such as storing your preferences so that they are available for your next visit and to keep a more accurate account of how often you visit the Services, how your use of the Services may change over time, and the effectiveness of advertising efforts.

Managing Your Cookies

It may be possible to block cookies by changing your Internet browser settings to refuse all or some cookies. If you choose to block all cookies (including essential cookies), you may not be able to access all or parts of the Services.

You can find out more about cookies and how to manage them at allaboutcookies.org, or through your browser's built-in cookie controls.

Does the Site Respond to "Do Not Track" Signals?

There is currently no industry agreed-upon response to a Do Not Track signal. At this time, our Site does not respond differently based on a user's Do Not Track signal.

4. Form Security and Bot Protection (Cloudflare Turnstile)

We use Cloudflare Turnstile to protect our website forms from automated abuse and spam. When you submit a form, Turnstile may collect browser signals, IP address, and limited interaction data to confirm you are a human visitor. This processing is performed by Cloudflare, Inc. as a data processor on our behalf. Cloudflare is certified under the EU-U.S. Data Privacy Framework.

The legal basis for this processing is our legitimate interest in preventing fraud, abuse, and spam submissions. For more information about how Cloudflare handles this data, see Cloudflare's privacy policy.

5. European Users' Rights

This section of our Privacy Policy is applicable to persons located in the European Union ("EU"), an European Economic Area member state ("EEA"), United Kingdom ("UK"), or Switzerland as well as to persons whose personal information is processed in or transferred from the EU, EEA, UK, or Switzerland. You are entitled under the EU General Data Protection Regulation and UK General Data Protection Regulation (collectively, the "GDPR"), to the information in this section of our Privacy Policy.

Your Rights

You are entitled by law to access, correct, amend, or delete personal information about you that we hold. A summary listing these rights appears below. Please note that these rights are not absolute and certain exemptions may apply to specific requests that you may submit to us.

To exercise these rights, please contact us using the information below in the "Contact Us" section or view our "Manage privacy" link in the footer of our website. For your protection, we may need to verify your identity before responding to your request. In the event that we refuse a request, we will provide you a reason as to why.

Asking us to access your personal information

You have the right to obtain from us confirmation as to whether or not we are processing personal information about you, and if so, the right to be provided with the information contained in this Policy. You also have the right to ask us for copies of your personal information. When making a request, please provide an accurate description of the personal information to which you want access. Where requests are repetitive or manifestly unfounded or excessive, we may charge a reasonable fee based on administrative cost.

Asking us to rectify your personal information

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.

Asking us to delete your personal information

You have the right to ask us to erase your personal information if:

• We no longer need it for the purposes for which we collected it;
• We have been using it with no valid legal basis;
• We are obligated to erase it to comply with a legal obligation to which we are subject;
• We need your consent to use the information and you withdraw consent; or
• You object to us processing your personal information where our legal basis for doing so is our legitimate interests and there are no overriding legitimate grounds for the processing.

However, this right is not absolute. Even if you make a request for deletion, we may need to retain certain information for legal or administrative purposes, such as record keeping, maintenance of opt-out requirements, defending or making legal claims, or detecting fraudulent activities. We will retain information in accordance with the "How Long Is Your Personal Information Kept" section below.

If you do exercise a valid right to have your personal information deleted, please keep in mind that deletion by third parties to whom the information has been provided might not be immediate and that the deleted information may persist in backup copies for a reasonable period (but will not be available to others).

Asking us to restrict our use of your personal information

You have the right to ask us to place a restriction on our use of your personal information if one of the following applies to you:

• You contest the accuracy of the information that we hold about you, while we verify its accuracy;
• We have used your information unlawfully, but you request us to restrict its use instead of erasing it;
• We no longer need the information for the purpose for which we collected it, but you need it to deal with a legal claim; or
• You have objected to us using your information, while we check whether our legitimate grounds override your right to object.

The right to transfer your personal information to another service provider

You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you (i.e. data portability). This applies to personal information we are processing to service a contract with you and to personal information we are processing based on your consent.

The right to withdraw consent

If we obtain your written consent to collect and process your personal information, you can subsequently withdraw such consent as to any further processing of such information.

The right to lodge a complaint with a supervisory authority

If you believe your rights under the GDPR have been violated, the GDPR gives you the right to file a complaint with your supervisory authority. A list of supervisory authorities is available here: EEA and EU Data Protection Authorities (DPAs); Swiss Federal Data Protection and Information Commissioner (FDPIC); UK Information Commissioner's Office (ICO).

Rights related to automated decision-making

To the extent that we engage in decision-making based solely on automated processing, including profiling, which produces legal effects concerning you or which significantly affects you, you have the right not to be subject to such decision-making.

Right to object to processing

You have the right to object to the processing of your personal information that is based on legitimate interests or your consent (rather than when the reason for using it is to perform an obligation due to you under a contract with us). If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or we can demonstrate the processing is for the establishment, exercise, or defense of legal claims. You can object to the processing of your personal information by contacting us using the information in the "Contact Us" section below.

Legal Bases for Processing Your Personal Information

Nami collects your personal information to provide our products and Services to you; otherwise, we may not be able to process the transactions you request. We will only process your personal information when we have a lawful basis for doing so. If you are in a country in the EU, EEA, UK, or Switzerland, you are entitled to an explanation of the legal bases we rely on to process your personal information. The legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it, which is discussed below.

• Consent. We may process your personal information based on your consent such as when you purchase a service or ask us to send you certain kinds of marketing communications. You have the right to withdraw your consent at any time without affecting the lawfulness of the processing based on consent before its withdrawal.
  • Children's Consent. We do not knowingly process data of EU, EEA, UK, or Swiss residents under the age of 16 without reasonably verified parental consent.
• Our Legitimate Interests. We may process your personal information if doing so is necessary for our legitimate interests relating to our business purposes arising from your relationship with us, and your rights as an individual do not override those legitimate interests. For example, our legitimate interests include but are not limited to when we process your personal information to carry out fraud prevention activities and activities to increase network and information security, identify usage trends, determine the effectiveness of promotional campaigns, expand our business activities and improve our services and the content and functionality of our Services. Our legitimate interests also include providing you with the products and services you request, view, engage with, or purchase and communicating with you regarding your account or transactions with us.
• To Perform a Contract. We may process your personal information to administer and fulfill contractual obligations to you. We will also collect and process your personal information as necessary for the performance of a contract to which you are a party.
• To Enable Us to Comply With a Legal Obligation. We may process your personal information to comply with legal obligations to which we are subject. This may include any requirement to produce audited accounts, any legal obligation to share information with law enforcement agencies, public or governmental authorities, and to comply with legal process.
• Necessary for the Exercise or Defense of Legal Claims. If you bring a claim against us or we bring a claim against you, we may process your personal information in relation to that claim.

Depending on the situation, we may be the controller or the processor for personal information collected from residents of the EU, EEA, UK or Switzerland. If you have any questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us using the "Contact Us" section below.

Cross-Border Transfers of Personal Information

Our Services are operated in the United States. Personal information you provide while in the EU, an EEA member state, the UK, or Switzerland may be transferred to the United States. The United States does not have an adequacy decision or adequacy regulation. The GDPR permits such transfers when necessary for the performance of a contract between you and us, if we obtain your explicit consent to such transfer, or if it is in our legitimate interest to transfer the personal information. The laws in the United States may not be as protective as the GDPR or the laws of other jurisdictions where you may be located. If we transfer personal information from the EU, EEA, UK, or Switzerland, or another country with cross-border transfer obligations, we will provide an appropriate safeguard, such as using standard contractual clauses.

To obtain a copy of the safeguard(s), please contact us using the information provided in the "Contact Us" section below.

6. California Residents' Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA/CPRA"), provides you with the following rights regarding personal information we collect about you:

• Right to know. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources from which it was collected, the business or commercial purpose for collecting it, and the categories of third parties with whom we have disclosed it.
• Right to delete. You may request that we delete personal information we have collected from you, subject to certain exceptions permitted by law.
• Right to correct. You may request that we correct inaccurate personal information we maintain about you.
• Right to opt out of sale or sharing. You may opt out of any "sale" or "sharing" of your personal information as those terms are defined under CCPA/CPRA.
• Right to limit use of sensitive personal information. You may direct us to limit our use and disclosure of any sensitive personal information about you to those uses permitted under CCPA/CPRA.
• Right to non-discrimination. You may exercise any of the rights above without receiving discriminatory treatment in price, service quality, or other terms from us.

Sensitive personal information. We do not knowingly collect or process Sensitive Personal Information (as defined in California Civil Code §1798.140(ae)) about California residents through the Services. Account authentication credentials are stored as one-way cryptographic hashes for the limited purpose of account security.

How to exercise your rights. To exercise any of the rights above, contact us at [email protected]. We will verify your identity before responding to ensure that personal information is not disclosed to anyone other than you, and we will respond within forty-five (45) days, extendable by an additional forty-five (45) days with notice to you.

Authorized agents. You may designate an authorized agent to submit a request on your behalf. We may require the agent to provide proof of authorization (such as a written permission or a power of attorney) and may also require you to verify your identity directly with us before responding to an agent's request.

7. Advertising and Marketing Choice

We respect your rights in how your personal information is used and shared. If at any time you would like to unsubscribe from receiving future emails, you can email us at [email protected] or follow the instructions at the bottom of each email, and we will promptly remove you from marketing correspondence. Please note, however, that we may still need to contact you regarding other matters.

8. How Long Is Your Personal Information Kept

We will retain your personal information until the personal information is no longer necessary to accomplish the purpose for which it was provided. We may retain your personal information for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations, to protect you, other people, and us from fraud, abuse, an unauthorized access, as necessary to protect our legal rights, or for certain business requirements.

We will delete your personal information when it is no longer necessary for the purpose for which it was collected, or upon your request, subject to exceptions as discussed in this Statement or under applicable law, contract, or regulation.

If you use our mobile application, you can delete your account by submitting a request to [email protected] or by deleting your account through the application itself. If you delete your account from within the application, we will delete the accompanying personal data subject to legal and contractual requirements.

9. Our Commitment to Data Security

We protect personal information using industry-standard administrative, technical, and physical safeguards, including encryption in transit and at rest, access controls, audit logging, and single sign-on for administrative accounts. Customers operating under a Data Processing Agreement can find the technical and organizational measures Nami commits to in the DPA and the Security Addendum, available at /legal.

If required by law, we will notify you and/or the relevant supervisory authority in the event of a data breach. However, no method of transmission or electronic storage is fully secure, and we cannot guarantee absolute security.

10. Where Your Personal Information Is Held

We process personal information on our servers in the United States of America, and may do so in other countries. If you use our Services or otherwise provide us with information from outside of the United States, you expressly consent to the transfer of your data to the United States, the processing of your data in the United States, and the storage of your data in the United States.

11. Third Party Links

Nami's Services may contain links to third-party websites. When we provide links, we do so only as a convenience and we are not responsible for any content of any third-party website or any links contained within. It is important to note that this Statement only applies to Nami's Services. We are not responsible and assume no responsibility for any personal information collected, stored, or used by any third party as a result of you visiting third-party websites. We also advise that you carefully read the privacy notice of any third-party websites you choose to visit.

12. Children's Privacy

Protecting the privacy of the very young is especially important. Our Services are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. In the event that we learn that we have collected personal information from a child under age 13 without verification or parental consent, we will immediately delete that information. If you believe that we might have any information from or about a child under 13, please contact us using the information provided in the "Contact Us" section below.

A higher age threshold applies in the EU, EEA, UK, and Switzerland — see the "Children's Consent" note in Section 5 (European Users' Rights) for the under-16 threshold under the GDPR.

13. Policy Changes

This Statement may change from time to time. If we need to change this Statement at some point in the future, we will post any changes on this page. If we make a significant or material change to this Statement we will notify you via email. You should check these terms when you use the Site. Your continued use of the Site constitutes acceptance of the most current version of this Statement.

If your personal information changes, you may correct or update it by notifying us of the change using the contact information listed below or by clicking "Manage privacy" in the footer at www.nami.ml.

14. Contact Us

If you have any questions about this Privacy Policy, please contact us at:

Nami ML Inc.
1630 Welton Street, Suite 945
Denver, CO 80202 USA
+1 (917) 720-6264
[email protected]
www.nami.ml

Please be aware that Nami is based in and operates from the United States. When accessing our Site, you consent to and authorize us to transfer your information from the country in which you are located to the United States. The United States may not have laws consistent with privacy and data protection laws in other countries.

The Site and Services are not designed to solicit or collect personal information from children under the age of 13 years. If you are under 13, you should not use or enter information on the Site or Services.