Privacy policy

1 Who we are

NOEUD Limited (“we”, “us”) is a company registered in Ghana, number CS184900825. We provide the noeud service (“noeud”), and we are responsible for the personal data this policy describes.

2 Whose personal data this policy covers

• people who visit getnoeud.com;
• people who apply for a pilot or contact us;
• people at our customers who use noeud;
• people named in documents our customers give us, such as contacts at their suppliers, clients, funders and banks;
• people at banks and other organisations we work with.

3 What we collect

When you visit getnoeud.com. Our website host receives technical information such as your IP address and browser details in order to deliver and secure the site.

When you use the breakeven calculator. The figures you enter stay in your browser and are never sent to us. If you give your business name, we receive it with the two currencies you chose and the time, to understand which businesses use the tool.

When you apply for a pilot. We collect what the form asks for: your company’s name, your name, your work email, the other details the form requests, such as trade type and annual foreign-currency volume, and anything you write in the notes.

When your organisation uses noeud.

• Account details of its users, such as their name, work email, phone number and role, and sign-in and security records such as sign-in times and IP addresses.
• The documents and data your organisation puts into noeud, such as purchase orders, invoices, letters of credit, grant tranches and bank confirmations. These can include the names and contact details of people at your suppliers, clients, funders and banks.
• Your settings and decisions: the tolerance you set, the quotes you request, accept or decline, and the notes you record.
• Messages between us.

When you work at a bank or partner. Your name, role and work contact details, and the quotes and messages you send us.

When we contact you about noeud. We may send one first message to people at organisations noeud could serve, using work contact details that are public, for example on a company website or a professional network such as LinkedIn. We keep a record of that message and of any reply. We send nothing further about noeud unless you agree to hear more, and we stop whenever you ask.

When you subscribe or attend. If you subscribe to our research or register for a briefing: your name, work email, organisation and role, and whether you attended.

4 How we use it

• To provide noeud to your organisation under our Terms of service.
• To review applications and set up pilots. We use the details from the application form only to set up your pilot, which includes reviewing your application and replying to you.
• To keep noeud secure and working, and to find and fix faults.
• To meet our legal duties, including keeping the business records the law requires and answering lawful requests from authorities.
• To produce statistics and benchmarks that do not identify anyone, as section 6 explains.
• To tell you about our research and briefings where you have asked us to, and to send the first messages section 3 describes. You can tell us to stop at any time, and we will.

We do not sell personal data. We do not make decisions about you by automated means alone.

5 Who we share it with

Banks, when your organisation asks. When your organisation asks for quotes, we send each bank on noeud’s panel the details it needs to price the trade. When your organisation accepts a quote, or asks its own bank to match one, we share with that bank the documents and contact details it needs to deal with you, with your organisation’s agreement. Each bank uses that information under its own privacy policy and its duties under Ghanaian law.

Professional advisers, such as our lawyers, auditors and accountants, who owe us confidentiality.

Authorities, such as the Bank of Ghana, the Data Protection Commission and the courts, where the law requires us to.

A buyer or investor, if all or part of NOEUD Limited is sold or restructured, under confidentiality and on the terms of this policy.

We never sell information that identifies you or your trades.

6 Statistics and benchmarks that do not identify anyone

noeud records the quotes banks give through it (the time, the bank, the terms, and whether each quote was taken), the quotes customers report from their own banks, the past bank confirmations customers choose to share, and the foreign-currency obligations customers record. We keep these quote records with each organisation’s identity removed. Combined with other organisations’ records, we may use them to produce:

• comparisons for our customers, such as where their quotes sit against other customers’;
• reports on how banks price companies’ foreign-currency trades, which we may send to customers and publish;
• statistics and benchmarks, which we may license to institutions such as audit firms, development finance institutions, asset managers, insurers and banks.

We publish, show or license a figure only when it draws on enough different organisations and banks that none can be singled out, and we hold back any figure that could be worked out from the ones we show. These figures never name an organisation or a person.

7 Where your data is stored

Some of our service providers store data outside Ghana, including in the European Union and the United States. We use providers that commit by contract to keep it secure and confidential.

8 How long we keep it

• Applications that do not lead to a pilot: 12 months from our last contact, then deleted.
• Customer data: while your organisation uses noeud. When it leaves, it can export its data for 30 days; we then delete that data, except records the law requires us to keep, quote records with the organisation’s identity removed, and statistics that identify no one.
• Business and tax records: for as long as the law requires.
• Records of people we have contacted about noeud: until you ask us to stop, or 24 months after our last contact, whichever comes first. We keep a note of a request to stop, so that we do not contact you again.

9 How we protect it

We protect personal data with technical and organisational measures suited to the risk, including encryption in transit and access limited to the people who need it for their work. No system is free of risk. If there are reasonable grounds to believe that your personal data has been accessed or acquired by someone without authority, we will tell you and the Data Protection Commission as soon as reasonably practicable, as the law requires.

10 Your rights

Under the Data Protection Act, you can ask us:

• whether we hold personal data about you, and for a copy of it;
• to correct personal data that is wrong or incomplete;
• to delete personal data we no longer have a lawful reason to keep;
• to stop using your personal data for a particular purpose;
• to stop contacting you about noeud, at any time.

To use any of these rights, write to info@getnoeud.com. We may ask you to confirm who you are, and we will reply within the time the Act allows. If your personal data reached us in your employer’s records, we may need to work with your employer to respond.

11 Cookies

getnoeud.com does not use advertising or tracking cookies. The noeud service uses only the cookies it needs to sign you in and keep your session secure.

12 Children

noeud is for organisations. We do not knowingly collect personal data from anyone under 18.

13 Changes to this policy

We post any change here with a new date. If a change affects how we use personal data you have already given us, we will tell our customers before it takes effect.

14 Complaints

If you are unhappy with how we have handled your personal data, please tell us at info@getnoeud.com so that we can put it right.