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Annex I to the SCCs: Description of Processing Activities for Novi under SMS Agreement

Last Modified: December 2021

Data Exporter: Novi Financial Ireland Limited.

Data Importer: Provider as identified in the SMS Agreement.

Sub-Processor: If applicable, listed under the Sub-processors Exhibit in the SMS Agreement.

Data subjects The Personal Data transferred concern individuals who visit, access, use or otherwise interact with products and services of the data exporter.

Categories of data: Facebook Data as defined in the Data Protection Addendum, to the extent it constitutes Personal Data in the controllership of Novi Financial Ireland Limited.

The frequency of the transfer: Continuous, as may be required from time to time to provide the services or carry out the other activities as set out in more detail in the SMS Agreement.

Nature of the processing: Depending on the products and services visited, accessed, or used by the data subject, and subject to any relevant permissions, controls, and other internal instructions, the Personal Data transferred may be subject to the following types of processing activities in relation to the activities carried out under the SMS Agreement, including:

  • sending transactional messages (such as the deposit/withdrawal of funds, add/remove of payment methods, and send/receive of funds).

  • sending account messages (such as registration, onboarding, and feedback)

  • sending messages to confirm phone number ownership;

  • sending password reset messages;

  • carrying out two factor authentication;

  • responding to customer services queries;

  • providing updates about products and services;

  • generating program performance data or aggregate information for product and market analysis;

  • promoting safety and security (such as using information to verify accounts, investigate suspicious activity or possible violations of terms or policies, or responding to law enforcement, civil law, and other legal requests); and

  • providing technical engineering support and trouble-shooting.

Purpose(s) of the data transfer and further processing: The purpose of the processing is the provision of services and other activities as set out in more detail in the SMS Agreement.

The period for which the personal data will be retained: Until the completion of the processing activities or the termination of the SMS Agreement, whichever is the earlier.