Privacy Policy

These privacy policies (“Privacy Policies”) apply to Personal Information (as defined below) collected by Num Finance (“Num”) under loan agreements (“Loan Agreements”) entered into between Num and users (“Users”). Capitalized terms not defined herein are defined in the applicable Loan Agreements.

This Privacy Policy shall be effective as of the date of execution of the applicable Loan Agreement between the Data Subject (as defined below) and Num, and shall be in effect for the term set forth in Section 1.4 hereof. In addition, this Privacy Policy is subject to changes and updates, and we encourage those interested on the topic to keep updated. As a normal part of our general activities, we collect information about our Users (hereinafter, “Data Subject”). This Privacy Policy describes what information Num collects about Data Subjects and what may be done with that information. This policy is very detailed because it is important that all Data Subjects who enter into Loan Agreements with Num are aware of Num’s practices as accurately as possible. By entering into Loan Agreements with Num and by becoming associated with Num, the Data Subject consents to the use of his or her personal information (“Personal Information”) in accordance with the policies described below.

The privacy of Data Subject information is of the utmost importance to Num, which is why we take precautions to safeguard Personal Information by using the most comprehensive and effective information security mechanisms available.

1- Rights of Access, Cancellation and Rectification of Personal Information

1.1. The Data Owners may exercise their rights to access, cancel and update their Personal Information, including their e-mail address, as well as to object to the processing thereof and to be informed of the assignments and/or international transfers of the Personal Information carried out, all in accordance with the provisions of the applicable regulations. Likewise, the Data Subject has the right to have his/her personal data rectified, updated and -when applicable- deleted or subject to confidentiality, within 5 (five) working days of accrediting his/her identity and of requesting the measure in question. It should be noted that the request for withdrawal or deletion shall not proceed when there is a legal obligation to keep the data.

1.2. The Data Subjects guarantee and are responsible, in any case, for the truthfulness, accuracy, validity and authenticity of the Personal Information provided, and undertake to keep it duly updated. Num does not guarantee to Data Subjects the accuracy of the data provided by the rest of the Data Subjects. This is without prejudice to Num's obligation to rectify, update or delete incorrect data and other obligations under applicable law and the provisions herein.

1.3. Once a Loan Agreement has been entered into with Num, the Data Subject may review and change the information submitted to Num during the process of entering into the Loan Agreement, including:

  • The user and email address. Notwithstanding any changes you make, Num will retain the above Personal Information for security and fraud control purposes.
  • The photograph of the National Identity Card or other identification document, accepted at Num's sole discretion.

1.4. Num will retain Personal Information of Data Subjects for a period of ten (10) years in order to resolve disputes or claims, detect and remedy problems or incidents, and to comply with the provisions of the Loan Agreements, as well as to comply with its legal obligations.

2- Personal Information

2.1. In order to enter into Loan Agreements, Data Subjects must provide certain complete and accurate personal information. Num may request, collect and store the following Personal Information: first and last name, valid ID number, physical contact information (such as telephone number, address, e-mail address, etc.). Num may confirm the Personal Information provided by contacting public entities, specialized companies or credit bureaus, for which the Data Subject hereby expressly authorizes Num to do so. The information Num obtains from these entities will be treated confidentially.

2.2. The Data Subject who enters into Loan Agreement expressly consents to Num having access, at any time, to all of the information provided for the purpose of entering into the Loan Agreements. It is expressly stated that the data collected by Num will at no time exceed the scope and purpose for which it was obtained, in accordance with current regulations.

3- Use of Personal Information

3.1. In order to comply with its legal obligations and to enable Data Subjects to enter into Loan Agreements in an agile and dynamic manner, Num requires certain personal information, including e-mail address and photograph of ID card. The Personal Information collected has the following purposes:

  • (i) To have an accounting record of the funds lent to Users segmented by each of the Users;
  • (ii) To carry out a credit study of the Users; and
  • (iii) Verify that they are not on local and international Sanctions lists.
4- Confidentiality of Personal Information

4.1. Once a Loan Agreement has been entered into, Num will not sell, rent or share Personal Information. Notwithstanding the foregoing, the Data Subject expressly consents to Num transferring all or part of the Personal Information to any of Num's controlled, controlling and/or related companies, in any capacity and at any time, in any manner and on any terms and conditions it deems appropriate. You further authorize Num to transfer your Personal Information in the event of the sale or transfer of all or any portion of Num or Num's assets (including in the event of any restructuring, dissolution or liquidation).

4.2. Num will use its best efforts to protect the privacy of Personal Information. Notwithstanding the foregoing, as set forth in Section 5 hereof, Num may be required by court or administrative order or legal regulation to disclose Personal Information to law enforcement authorities or third parties under certain circumstances.

5- Legal Requirements

5.1. Num will cooperate with the competent authorities and other third parties to ensure compliance with laws, for example, regarding the protection of intellectual property rights, fraud prevention, prevention of money laundering and terrorist financing and other matters.

5.2. Num may disclose Personal Information of Data Subjects as required by law or as requested by competent judicial or governmental authorities for the purposes of investigations conducted by them and in the face of any activity that may be illegal or that may expose Num or Data Subjects to any legal liability. In such situations, Num will cooperate with the competent authorities in order to safeguard the integrity and security of the community and its Data Subjects, complying with the minimum and indispensable requirements requested by law or competent judicial authority without compromising the Personal Information of the Data Subjects unnecessarily. In all cases, Num will require the corresponding notification duly signed by a judge and/or competent authority in the event of a request for information requested by the authorities. In no event will Num provide Personal Information of Data Subjects pursuant to information requests that are excessive and/or do not comply with applicable legal requirements.

5.3. In addition, Num reserves the right (and Data Subjects expressly authorize it to do so) to disclose information to entities or third parties where there is sufficient reason to believe that a Data Subject's activity is suspected of attempting or committing a crime or attempting to harm others. This right will be exercised by Num to maintain the integrity and security of the community and that of its Data Subjects, to enforce the Loan Agreements and for purposes of cooperating with law enforcement and Num’s compliance and AML/CFT Policy. This right will be exercised by Num irrespective of any court or administrative order to that effect.

5.4. Num will use its best efforts to protect the privacy of Personal Information, and will share such information in the instances referred to in this clause only as appropriate or necessary.

6- Security and Storage of Personal Information

6.1. Num is obligated to comply with all applicable regulations regarding security measures applicable to Personal Information. Num considers the Personal Information of Data Subjects to be an asset that must be protected from loss or unauthorized access. To this end, Num employs various security techniques to protect such data from unauthorized access by Data Subjects inside or outside the company. Notwithstanding the foregoing, considering that the Internet is an open, publicly accessible system, Num cannot guarantee that unauthorized third parties will not be able to overcome security measures and misuse Personal Information.

6.2. All information we receive about Data Subjects is stored on secure servers and we have implemented appropriate and necessary technical and organizational measures to protect Personal Information. Num continually evaluates the security of its network and the adequacy of its internal information security program designed to (a) help keep your data secure in the event of accidental or unlawful loss, access or disclosure; (b) identify reasonably foreseeable risks to the security of Num's network; and (c) minimize security risks through regular risk assessments and reviews.

6.3. Data Subject expressly acknowledges and agrees that Num, in its sole discretion, collects, stores and eventually monitors the exchange of messages and emails between its Data Subjects and Num, for the purpose of contributing to the security of the relationships and communications that develop between Data Subjects and Num.

6.4. Num is therefore not responsible for unlawful interception or breach of its systems or databases by unauthorized persons. Num is also not responsible for the misuse of information obtained by such means.

6.5. All personal data of Data Subjects will be stored in an automated personal data file or IT support. The Num Data Subject's personal data file or carrier resides in the British Virgin Islands.

7- Modification of Privacy Policies

7.1. Num may amend this Privacy Policy at any time by posting the amended Privacy Policy on its website. All amended terms will be effective 10 (ten) calendar days after they are posted. In case of disagreement with respect to such amendments, the Data Subject shall communicate to Num his or her non-acceptance by sending an e-mail to from his or her e-mail address within 10 (ten) calendar days of the posting of the amendments, in which case the Loan Agreements entered into pursuant to the terms therein shall be terminated and his or her relationship with Num shall be deemed terminated, and such Data Subject shall first be required to fulfill any outstanding obligations. Upon expiration of the aforementioned term without expressing disagreement with the new Privacy Policies, the Data Subject shall be deemed to have accepted the same and the parties shall continue to be bound by such terms.

8- Contact

8.1. To make any inquiry, claim and/or request related to Personal Information, the Data Owners may contact

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