This Notice describes how Nomisma LLC processes personal data collected through the actaa.ai website; personal data processed within the Actaa service is governed separately by the Actaa Platform Privacy Policy.
01 Scope
This Website Privacy Notice (the “Notice”) describes how Nomisma LLC (“Nomisma,” “we,” or “us”) processes personal data collected through its marketing website at actaa.ai (the “Website”).
This Notice applies only to the Website. It does not apply to personal data processed within the Actaa service. Where a company uses Actaa, personal data processed within the service is governed by the separate Actaa Platform Privacy Policy and not by this Notice.
Nomisma LLC is a limited liability company formed in the State of Wyoming, United States, and is the controller of the personal data described in this Notice.
02 Information We Collect
Nomisma collects a deliberately limited amount of information through the Website, comprising two categories.
Information provided through the early-access form
When a User requests early access, Nomisma collects the details entered into the form:
- name;
- work email address;
- company; and
- the message the User elects to provide.
First-party analytics
To understand how the Website is used, Nomisma records a limited set of first-party, aggregate measurements for each page view:
- the page path visited;
- the referrer domain (the site from which the visitor arrived);
- a coarse classification of device, browser, and operating system;
- the visitor’s timezone; and
- a daily-rotating, salted visitor hash, used solely to count unique visits.
Google Analytics (with consent)
Subject to the User’s consent, the Website also uses Google Analytics 4, a web-analytics service provided by Google LLC. Google Analytics is loaded only after the User accepts analytics cookies through the consent banner shown on first visit. If the User declines, or has not yet made a choice, Google Analytics is not loaded and its cookies are not set.
Where enabled with consent, Google Analytics sets cookies (including _ga and _ga_) and processes usage information such as the pages viewed, an approximate location derived from the IP address, and device and browser characteristics. This information is processed by Google, including in the United States, acting as Nomisma’s processor for website analytics. Nomisma has enabled IP anonymization, does not use Google Analytics for advertising, and does not combine it with the early-access data described above.
The User may withdraw consent at any time through Cookie settings, or by declining and clearing cookies in the browser. Google’s processing of data is further described in Google’s own privacy documentation.
03 Purposes of Processing
Nomisma processes the information described above in order to:
- respond to a User’s early-access request and, where relevant, contact the User regarding early access and related product updates; and
- understand overall Website traffic in order to maintain and improve the Website.
Nomisma does not use this information to construct advertising profiles, to make automated decisions producing legal or similarly significant effects, or to track Users across other websites.
04 Legal Bases Under the GDPR
Where the EU or UK General Data Protection Regulation (the “GDPR”) applies, Nomisma relies on the following legal bases:
- Early-access requests — to take steps at the User’s request in response to the enquiry, and Nomisma’s legitimate interest in evaluating and responding to interest in Actaa.
- First-party analytics — Nomisma’s legitimate interest in understanding and securing the Website, using data designed to minimize any impact on privacy (cookieless, without cross-site tracking, and without storage of raw IP addresses).
- Google Analytics — the User’s consent under Article 6(1)(a), obtained through the cookie banner; the User may withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal.
Where Nomisma relies on legitimate interests, it has weighed those interests against the rights and interests of the data subject. A data subject may object to processing based on legitimate interests, as described under “Your Rights” below.
05 No Sale, Sharing, or Marketing Use
Nomisma does not sell personal data and does not “share” personal data for cross-context behavioral advertising. Nomisma does not add a User to marketing lists solely on the basis that the User has made contact.
Nomisma does not disclose personal data to third parties except to the service provider that hosts the Website on its behalf, as described under “Data Storage and Hosting”; to Google, where the User has consented to Google Analytics, as described under “Information We Collect”; or where disclosure is required by law.
06 Data Storage and Hosting
The Website and the data it collects are hosted on Nomisma’s own Amazon Web Services (AWS) infrastructure located in the United States. AWS acts as Nomisma’s hosting provider (a processor or sub-processor) and does not use this data for its own purposes.
07 Data Retention
Nomisma retains early-access messages while it evaluates the User’s interest and for a reasonable period thereafter, after which they are deleted. Exact retention period: up to twenty-four (24) months from submission, or until the User requests deletion, whichever occurs first.
The first-party analytics contain no directly identifying information and may be retained in aggregate form for a longer period. Because the daily visitor hash is re-salted each day, it cannot be linked to a data subject once the salt has rotated.
08 Your Rights
Depending on the data subject’s jurisdiction, the following rights may apply.
Under the GDPR (EU and UK)
- Access — to obtain a copy of the personal data held about the data subject;
- Rectification — to request correction of inaccurate personal data;
- Erasure — to request deletion of personal data (Article 17);
- Portability — to receive personal data in a portable, machine-readable format (Article 20); and
- Objection — to object to processing based on Nomisma’s legitimate interests.
Under California law (CCPA / CPRA)
- the right to know the personal information collected and the purposes for which it is used;
- the right to delete personal information held about the consumer;
- the right to opt out of the sale or sharing of personal information, noting that Nomisma does not sell or share personal information; and
- the right not to be subject to discrimination for exercising these rights.
Nomisma honors the Global Privacy Control (GPC) signal as an opt-out request. To exercise any of these rights, a data subject may contact Nomisma using the details set out under “Contact.” Nomisma will respond as required by applicable law. A data subject also has the right to lodge a complaint with the competent data-protection authority.
09 International Transfers
Nomisma is established in the United States and hosts the Website’s data in the United States. Where a User makes contact from the European Economic Area, the United Kingdom, or another jurisdiction, personal data will be transferred to and processed in the United States. Where required for such transfers, Nomisma relies on the European Commission's Standard Contractual Clauses and, for the United Kingdom, the International Data Transfer Addendum. Where Nomisma is required to designate an EU or UK representative under Article 27, it will identify that representative in this Notice.
10 Children’s Privacy
The Website is intended for businesses and professionals. It is not directed to children, and Nomisma does not knowingly collect personal data from any person under the age of 16. If a parent or guardian believes that a child has provided personal data through the Website, they may contact Nomisma, and the data will be deleted.
11 Amendments
Nomisma may amend this Notice from time to time. Upon any amendment, Nomisma will revise the “Last updated” date set out at the top of this page. Material changes will be reflected in this Notice, which data subjects are encouraged to review periodically.
12 Contact
Questions regarding this Notice, or requests to exercise privacy rights, may be directed to info@actaa.ai.
Nomisma LLC — a Wyoming limited liability company, USA. Contact: info@actaa.ai.