Legal

Privacy Policy

This Privacy Policy explains what personal data Nodalbank collects when you use our platform, why we collect it, how it is protected, how long it is kept, and the rights you hold over it. It applies to our website, our member dashboard and every related service we operate.

Last updated August 14, 2026

1. Introduction

This Privacy Policy explains how NodalBank (“NodalBank,” “we,” “us,” or “our”) collects, receives, records, uses, stores, analyses, verifies, transfers, discloses and otherwise processes information relating to individuals who access or use our websites, applications, dashboards, investment services, payment-related services, node infrastructure, account services, customer support channels and any other products or services made available by or through NodalBank (collectively, the “Services”).

This Privacy Policy forms part of the legal framework governing your relationship with NodalBank and should be read together with our Terms of Service, Cookie Policy, Risk Disclosures and any additional notices or agreements applicable to a particular Service.

By creating or maintaining an account, submitting information to us, or using the Services, you acknowledge that you have been provided with this Privacy Policy and understand the processing activities described herein.

Where consent is required by applicable law for a particular processing activity, we will request such consent separately where appropriate.

2. Who We Are

For purposes of applicable data protection legislation, the entity responsible for determining the purposes and means of processing your personal information is:

Nodal AI Infrastructures
Trading as: NodalBank
Registered Address: Mysore, Karnataka, India
Privacy Contact: privacy [at] nodalbank [dot] com

Where another NodalBank entity is responsible for a specific Service, that entity may act as the relevant data controller or joint controller as applicable.

The use of the name “NodalBank” in this Privacy Policy refers to the relevant NodalBank entity providing the applicable Service and does not, by itself, constitute a representation that any particular entity is a licensed bank, deposit-taking institution or other regulated financial institution unless expressly stated in the documentation relating to that Service.

3. Scope of This Policy

This Privacy Policy applies to information collected through:

  • nodalbank.com and its subdomains;
  • NodalBank member dashboards and account interfaces;
  • NodalBank investment-related services;
  • Nodal Pay and payment or settlement services, when made available;
  • Nodal Nodes and infrastructure-related services, when made available;
  • Nodal Company services, when made available;
  • Nodal Prop and proprietary trading-related services, when made available;
  • account registration, authentication and verification procedures;
  • Know Your Customer (“KYC”), Know Your Business (“KYB”) and Anti-Money Laundering (“AML”) procedures;
  • customer support and communications;
  • promotions, surveys and referral programs;
  • blockchain and digital-asset transactions associated with the Services; and
  • interactions with our authorised service providers and partners.

Separate or supplemental privacy notices may apply to particular Services.

4. Information We May Collect

Depending on the Services you use and applicable regulatory requirements, we may collect and process the following categories of information.

4.1 Identity Information

This may include:

  • full legal name;
  • date and place of birth;
  • nationality;
  • citizenship;
  • gender where legally necessary;
  • photograph;
  • signature;
  • government-issued identification information;
  • passport information;
  • national identification number;
  • residency information;
  • taxpayer identification information; and
  • other information necessary to establish or verify your identity.

4.2 Contact Information

This may include:

  • email address;
  • telephone number;
  • residential address;
  • mailing address; and
  • other contact information supplied by you.

4.3 KYC, KYB and Compliance Information

We may collect information required to conduct customer due diligence, enhanced due diligence or other compliance procedures, including:

  • identification documents;
  • proof of address;
  • selfie photographs;
  • video or liveness verification data;
  • facial verification results;
  • occupation and employment information;
  • source of funds;
  • source of wealth;
  • expected account activity;
  • beneficial ownership information;
  • corporate ownership and control information;
  • politically exposed person (“PEP”) status;
  • sanctions screening information;
  • adverse-media screening results;
  • fraud-risk indicators;
  • transaction-risk information; and
  • information reasonably required to satisfy legal, regulatory, contractual or risk-management obligations.

Where biometric or similar sensitive information is processed, such processing will be carried out only where permitted by applicable law and subject to appropriate safeguards.

5. Financial and Transaction Information

We may collect and process information relating to:

  • deposits;
  • withdrawals;
  • investments;
  • account balances;
  • payment instructions;
  • transaction history;
  • currencies and digital assets;
  • wallet addresses;
  • blockchain transaction hashes;
  • originating and destination addresses;
  • transaction timestamps;
  • payment providers;
  • bank or financial institution information where applicable;
  • investment plans and positions;
  • commissions, rewards, referrals and earnings;
  • transaction disputes; and
  • related financial records.

We may also receive transaction-related information from blockchains, blockchain analytics providers, payment providers, financial institutions and compliance providers.

6. Blockchain Information

Certain Services may involve public or permissioned blockchain networks.

Users should understand that transactions recorded on a public blockchain may be public, permanent and independently accessible to third parties.

Information recorded on a blockchain may include wallet addresses, transaction amounts, transaction identifiers and timestamps.

NodalBank generally cannot erase, modify, reverse or conceal information that has been permanently recorded on a blockchain that we do not control.

We may associate publicly available blockchain information with information held in your NodalBank account where reasonably necessary for:

  • transaction processing;
  • security;
  • reconciliation;
  • fraud detection;
  • sanctions screening;
  • AML and counter-terrorist financing controls;
  • investigation of suspicious activity;
  • enforcement of our Terms;
  • dispute resolution; and
  • compliance with applicable laws.

7. Technical and Device Information

When you access the Services, we or our service providers may automatically collect information including:

  • IP address;
  • device identifiers;
  • device type;
  • browser type and version;
  • operating system;
  • language settings;
  • approximate geographic location derived from IP;
  • login timestamps;
  • session information;
  • authentication records;
  • cookie identifiers;
  • crash reports;
  • usage logs;
  • pages or functions accessed;
  • referral URLs; and
  • information relating to suspected automated, abusive or malicious activity.

We may use this information to secure the Services, prevent unauthorised access and improve platform performance.

8. Information Obtained From Third Parties

We may obtain information relating to you from third parties where permitted by law, including:

  • identity-verification providers;
  • KYC/KYB providers;
  • sanctions and PEP databases;
  • fraud-prevention services;
  • blockchain analytics providers;
  • payment processors;
  • banks and financial institutions;
  • cybersecurity providers;
  • affiliates;
  • business partners;
  • public authorities;
  • public databases;
  • credit or risk-information providers where legally permitted;
  • publicly accessible blockchain networks; and
  • other users where they identify you in connection with referrals, payments or transactions.

We are not responsible for the independent privacy practices of third parties acting as separate data controllers.

9. How We Use Your Information

We may process personal information for the following purposes.

9.1 Providing the Services

Including to:

  • create and maintain accounts;
  • authenticate users;
  • process transactions;
  • administer investments;
  • calculate balances, returns, rewards or commissions;
  • provide payment or settlement services;
  • provide customer support;
  • communicate operational information;
  • maintain account records; and
  • provide requested products and services.

9.2 Identity Verification and Compliance

Including to:

  • verify your identity;
  • conduct KYC and KYB procedures;
  • establish beneficial ownership;
  • verify source of funds or source of wealth;
  • perform sanctions and PEP screening;
  • conduct transaction monitoring;
  • detect suspicious activity;
  • perform enhanced due diligence;
  • comply with AML, counter-terrorist financing, sanctions, fraud-prevention and other applicable requirements.

9.3 Security and Fraud Prevention

We may process information to:

  • prevent account takeover;
  • identify fraudulent registrations;
  • detect suspicious transactions;
  • identify multiple or unauthorised accounts;
  • prevent abuse of promotional or referral programs;
  • identify device or network manipulation;
  • investigate security incidents;
  • protect NodalBank, its users and third parties; and
  • enforce account restrictions and platform rules.

9.4 Risk Management

We may use personal, transactional, technical and behavioural information to assess:

  • account risk;
  • transaction risk;
  • fraud risk;
  • compliance risk;
  • security risk;
  • credit or counterparty risk where applicable; and
  • risks to NodalBank, its users or the integrity of the Services.

9.5 Legal Claims and Enforcement

We may process and retain information where reasonably necessary to:

  • establish, exercise or defend legal claims;
  • investigate disputes;
  • enforce our Terms of Service;
  • recover amounts owed;
  • respond to chargebacks;
  • preserve evidence;
  • investigate misconduct;
  • cooperate with lawful investigations; and
  • protect our legal rights, property and legitimate business interests.

10. Legal Bases for Processing

Where applicable data protection law requires us to identify a lawful basis, we may rely on one or more of the following:

Performance of a Contract

Processing necessary to provide Services requested by you or perform our contractual obligations.

Compliance With Legal Obligations

Processing necessary to comply with laws, regulations, court orders, sanctions requirements, AML obligations, tax obligations, accounting requirements or lawful governmental requests.

Legitimate Interests

Processing necessary for legitimate interests pursued by NodalBank or a third party, including:

  • preventing fraud;
  • securing our infrastructure;
  • managing business risk;
  • investigating misconduct;
  • enforcing contractual rights;
  • improving our Services;
  • preventing abuse;
  • protecting users; and
  • establishing or defending legal claims,

provided those interests are not overridden by rights that require protection under applicable law.

Consent

Where required, we may rely on your consent for specific processing activities.

Where processing is based on consent, you may withdraw consent in accordance with applicable law. Withdrawal does not affect processing lawfully performed before withdrawal.

11. Automated Monitoring and Decision Support

NodalBank may use automated systems, algorithms, risk models and third-party technologies to assist in:

  • identity verification;
  • liveness checks;
  • fraud detection;
  • transaction monitoring;
  • sanctions screening;
  • security monitoring;
  • account-risk scoring;
  • suspicious-activity detection; and
  • abuse prevention.

These systems may identify transactions or accounts for additional review, temporary restriction or enhanced verification.

Where applicable law provides rights concerning decisions based solely on automated processing that produce legal or similarly significant effects, those rights will be respected.

Nothing in this section obliges NodalBank to disclose confidential fraud-detection rules, security methodologies, proprietary algorithms, risk thresholds or information where disclosure would compromise the security or integrity of the Services or violate applicable law.

12. When We May Share Information

We may disclose information to third parties where reasonably necessary for the purposes described in this Privacy Policy.

Such recipients may include:

Service Providers

Including providers of:

  • hosting and cloud infrastructure;
  • cybersecurity;
  • identity verification;
  • KYC/KYB services;
  • sanctions screening;
  • blockchain analytics;
  • payment processing;
  • banking services;
  • communications;
  • customer support;
  • analytics;
  • data storage;
  • fraud prevention;
  • accounting;
  • auditing;
  • legal services; and
  • professional advisory services.

Affiliates

Information may be shared within the NodalBank corporate group where reasonably necessary to provide Services, manage risk, prevent fraud, conduct compliance functions or operate our business.

Financial and Digital-Asset Service Providers

Where necessary to process transactions, we may disclose information to banks, payment processors, custodians, liquidity providers, blockchain service providers, exchanges or similar entities.

Government and Regulatory Authorities

We may disclose information where we reasonably believe disclosure is required or permitted by applicable law, regulation, court order, subpoena, warrant, regulatory request or other lawful process.

Where legally permissible, we may also disclose information where reasonably necessary to:

  • prevent or investigate fraud;
  • detect money laundering or terrorist financing;
  • investigate cybersecurity incidents;
  • protect persons from harm;
  • enforce our agreements;
  • protect our rights or property; or
  • cooperate with governmental, judicial or regulatory investigations.

Nothing in this Privacy Policy requires NodalBank to challenge, notify you of or disclose the existence of a governmental request where doing so is prohibited by law or would compromise a legitimate investigation.

13. We Do Not Sell Personal Information

NodalBank does not sell personal information to third parties in exchange for monetary consideration as part of its ordinary business model.

However, disclosure of information to service providers, compliance providers, affiliates, transaction counterparties or other recipients described in this Policy shall not be construed as a “sale” merely because such disclosure is necessary to provide, secure or administer the Services.

Where applicable privacy legislation defines “sale” or “sharing” differently, we will provide any rights required under that legislation.

14. International Data Transfers

NodalBank operates in an international digital environment.

Your information may therefore be processed or stored in countries other than the country in which you reside.

Those jurisdictions may have privacy and data protection laws that differ from the laws applicable in your country.

Where required by applicable law, we will use appropriate safeguards for international transfers, which may include:

  • adequacy decisions;
  • approved contractual protections;
  • Standard Contractual Clauses;
  • contractual data-protection obligations;
  • recognised certification mechanisms; or
  • another lawful transfer mechanism.

By using internationally accessible Services, you acknowledge that the provision of those Services may necessarily involve cross-border processing of information, subject to applicable legal requirements.

15. Data Retention

We retain personal information for as long as reasonably necessary for the purposes for which it was collected and for legitimate legal, regulatory, compliance, operational, security and dispute-resolution purposes.

Closing or deleting your account does not necessarily result in immediate deletion of all information.

We may retain information after account closure where required or reasonably necessary for:

  • AML/KYC obligations;
  • sanctions compliance;
  • tax and accounting obligations;
  • transaction records;
  • fraud prevention;
  • security investigations;
  • audit requirements;
  • regulatory inquiries;
  • dispute resolution;
  • enforcement of agreements;
  • preservation of evidence;
  • legal claims; and
  • compliance with applicable statutes of limitation.

Retention periods may vary depending on the type of information, applicable law and nature of the relationship.

When information is no longer required, we may securely delete, anonymise or otherwise dispose of it in accordance with our applicable retention procedures.

16. Account Closure and Data Deletion Requests

A request to close an account is not necessarily equivalent to a request to erase personal information.

Even where you request deletion, we may be legally entitled or required to retain certain information.

We may deny or limit an erasure request where retention is necessary for, among other things:

  • compliance with law;
  • AML/KYC requirements;
  • fraud prevention;
  • security;
  • recordkeeping;
  • establishment or defence of legal claims;
  • exercise of contractual rights;
  • investigation of suspected misconduct; or
  • protection of the rights of another person.

Information permanently recorded on public blockchains may not be capable of deletion by NodalBank.

17. Security

We use reasonable technical, organisational and administrative safeguards designed to protect personal information against:

  • unauthorised access;
  • accidental loss;
  • unlawful disclosure;
  • alteration;
  • misuse; and
  • destruction.

These measures may include access controls, authentication mechanisms, encryption, logging, monitoring, segregation of responsibilities and security review procedures where appropriate.

However, no information system, internet transmission, blockchain system, software platform or storage mechanism can be guaranteed to be completely secure.

Accordingly, NodalBank does not warrant or guarantee that unauthorised third parties will never be able to defeat security measures or improperly access information.

Users are responsible for maintaining the confidentiality and security of their own credentials, devices, authentication mechanisms and account access.

You should immediately notify us if you suspect unauthorised access to your account.

18. Your Privacy Rights

Depending on the laws applicable to you, you may have the right to:

  • request confirmation that we process your information;
  • request access to your personal information;
  • request correction of inaccurate information;
  • request deletion of certain information;
  • request restriction of certain processing;
  • object to certain processing;
  • request portability of certain information;
  • withdraw consent where processing is based on consent;
  • request information concerning certain international transfers;
  • request review of certain automated decisions where applicable; and
  • lodge a complaint with an applicable data protection authority.

These rights are not absolute and may be subject to legal exceptions.

Before acting on a request, we may require information sufficient to verify your identity and confirm your entitlement to make the request.

We may decline, restrict or defer a request where permitted by law, including where complying with the request would:

  • adversely affect the rights of another person;
  • interfere with regulatory or legal obligations;
  • compromise fraud or security controls;
  • prejudice an investigation;
  • reveal protected confidential information;
  • conflict with applicable recordkeeping requirements; or
  • prevent the establishment, exercise or defence of legal claims.

Requests may be submitted to: privacy [at] nodalbank [dot] com

19. Communication Records

When you contact NodalBank, we may retain communications including:

  • support tickets;
  • emails;
  • chat messages;
  • complaints;
  • call records;
  • submitted documents; and
  • other correspondence.

These records may be retained for customer support, quality assurance, security, dispute resolution, regulatory compliance and legal evidentiary purposes.

Where permitted by applicable law, customer support calls or electronic communications may be recorded or monitored.

20. Cookies and Similar Technologies

We may use cookies, pixels, local storage, software development kits and similar technologies for purposes including:

  • authentication;
  • account security;
  • session management;
  • fraud prevention;
  • user preferences;
  • analytics;
  • performance monitoring; and
  • improving the Services.

Where applicable law requires consent for non-essential cookies, users will be provided with appropriate controls.

Additional information is available in our Cookie Policy.

21. Marketing Communications

Where legally permitted, we may send information concerning NodalBank products, services or promotions.

You may unsubscribe from promotional communications using the mechanism provided in the relevant communication.

Operational, transactional, security, compliance and account-related communications are not marketing messages, and users may continue to receive them where necessary to administer an account or Service.

22. Children and Minors

The Services are not intended for persons under 18 years of age, or any higher minimum age required to enter into a legally binding financial agreement in the user's jurisdiction.

We do not knowingly permit minors to open accounts where prohibited by applicable law.

If we reasonably believe an account is being used by or on behalf of an ineligible minor, we may suspend or close the account and take appropriate steps concerning associated information and assets, subject to applicable law and our Terms of Service.

23. Fraudulent, False or Misleading Information

Users must provide accurate, complete and current information.

Where we identify or reasonably suspect that information supplied to us is false, forged, stolen, misleading, manipulated or belongs to another person, we may:

  • conduct additional verification;
  • restrict account functionality;
  • suspend processing;
  • preserve relevant evidence;
  • investigate associated accounts;
  • engage third-party verification or fraud-prevention services; and
  • disclose information to competent authorities where required or permitted by law.

Such processing may continue after account closure where reasonably necessary for fraud prevention, compliance or legal claims.

24. Corporate Transactions

If NodalBank or any relevant part of its business undergoes or considers a:

  • merger;
  • acquisition;
  • restructuring;
  • financing;
  • reorganisation;
  • insolvency;
  • sale of assets;
  • change of control; or
  • transfer of business,

personal information may be disclosed or transferred to potential or actual counterparties, investors, professional advisers or successor entities where legally permissible and subject to appropriate confidentiality and data-protection safeguards.

25. Legal Preservation

NodalBank may preserve information that would otherwise be deleted where we reasonably believe the information is or may become relevant to:

  • litigation;
  • arbitration;
  • regulatory proceedings;
  • law-enforcement investigations;
  • internal investigations;
  • disputes;
  • suspected fraud;
  • security incidents; or
  • enforcement of legal rights.

Such information may be retained until the relevant matter and any reasonably anticipated related proceeding have concluded and applicable retention requirements have expired.

26. Third-Party Websites and Services

The Services may contain links to or integrations with services operated by third parties.

NodalBank does not control the independent processing activities of third parties acting as separate data controllers and is not responsible for their privacy practices.

Users should review the relevant third party's privacy documentation before providing personal information directly to that party.

27. Changes to This Privacy Policy

We may amend this Privacy Policy from time to time to reflect:

  • changes to our Services;
  • changes in technology;
  • changes to our business;
  • changes in applicable law or regulation;
  • new compliance requirements; or
  • changes to our information-processing practices.

The updated version will be published with a revised “Last Updated” date.

Where required by applicable law or where changes materially affect your rights, we may provide additional notice.

Continued use of the Services following an update does not override any consent requirement imposed by applicable law.

28. Regulatory and Legal Disclosures

Nothing in this Privacy Policy:

  • limits any right that cannot lawfully be limited;
  • requires NodalBank to process information where processing would violate applicable law;
  • prevents NodalBank from complying with lawful governmental, judicial or regulatory obligations; or
  • requires disclosure of information protected by law, legal privilege, confidentiality obligations or legitimate security interests.

If any provision of this Privacy Policy conflicts with mandatory applicable law, the mandatory law shall prevail to the minimum extent necessary, and the remaining provisions shall continue to apply to the fullest extent permitted by law.

29. Contact Us

Questions, complaints or requests concerning this Privacy Policy or the processing of personal information may be directed to:

NodalBank Privacy Team
Email: privacy [at] nodalbank [dot] com

For security reasons, we may require identity verification before responding to requests relating to personal information.

30. Acknowledgment

By accessing or using the Services, you acknowledge that you have had the opportunity to review this Privacy Policy.

Where your explicit consent is required by applicable law, your use of the Services alone will not be treated as a substitute for such consent.

End of Privacy Policy

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