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Privacy Policy

Last Updated: August 8, 2026

1. DATA CONTROLLER

The controller of your personal data is the owner of the nohodl.org website, with a seat in Poland, reachable via email at: nohodl@zohomail.eu

2. DATA PROTECTION OFFICER

For all matters related to personal data protection, you can contact us at: nohodl@zohomail.eu

3. SCOPE AND PURPOSES OF DATA PROCESSING

3.1. Data processed during account registration:

  • Data: Email address, password (hashed), username, country, region, registration date.
  • Purpose: To create and manage your user account, authorize access, and communicate.
  • Legal Basis: Performance of a contract (Article 6(1)(b) GDPR).
  • Retention Period: Up to 5 years from the last activity.

3.2. Data in listings (with registration):

  • Data: Name/nickname, contact details (phone, email), location, listing content, images, prices in cryptocurrencies/fiat.
  • Purpose: To publish the listing and enable contact between users.
  • Legal Basis: Performance of a contract (Article 6(1)(b) GDPR).
  • Retention Period: Until deleted by the user or for 2 years from the last edit.

3.3. Data in listings (without registration):

  • Data: Email address, listing content, images, location.
  • Purpose: For a one-time publication of the listing.
  • Legal Basis: Performance of a contract (Article 6(1)(b) GDPR).
  • Retention Period: 30 days from publication (or until deleted via the provided link).

3.4. Messages between users:

  • Data: Sender's email address, message content, listing identifier.
  • Purpose: To enable communication between interested parties.
  • Legal Basis: Performance of a contract (Article 6(1)(b) GDPR).
  • Retention Period: 90 days from sending.

3.5. Transactional data (P2P):

IMPORTANT: nohodl.org does NOT process payment data, credit card details, or specifics of cryptocurrency transactions. Transactions occur directly between users.

3.6. Analytical data:

  • Data: IP address, browser type, operating system, pages visited, visit duration, traffic source.
  • Purpose: Traffic analysis, functionality improvement, fraud detection.
  • Legal Basis: Legitimate interest (Article 6(1)(f) GDPR).
  • Retention Period: 30 days.

3.7. Data for newsletter (optional):

  • Data: Email address, topic preferences.
  • Purpose: Sending information about news and promotions (only with consent).
  • Legal Basis: Consent (Article 6(1)(a) GDPR).
  • Retention Period: Until consent is withdrawn.

4. COOKIES AND TRACKING TECHNOLOGIES

4.1. Essential cookies:

  • Purpose: Session maintenance, security, basic functionality.
  • Storage: Session or up to 24 hours.
  • Opt-out possibility: No (the website cannot function without them).

4.2. Analytics cookies:

  • Purpose: Anonymous statistics (Google Analytics, Matomo).
  • Storage: 24-26 months.
  • Opt-out possibility: Yes (in the configuration panel).

4.3. Marketing cookies:

  • Purpose: Ad personalization (if displayed).
  • Storage: 1-24 months.
  • Opt-out possibility: Yes (disabled by default).

Detailed information: A full list of cookies is available in the Cookie Policy.

5. RECIPIENTS OF DATA

5.1. Other users of the service: Contact details from listings (name, phone, email, location) for the purpose of enabling contact regarding the listing.

5.2. Technical service providers:

  • Hosting: Servers in Germany (or another EU provider).
  • Email: Google Workspace (data may be processed in the USA with the protection of Standard Contractual Clauses).
  • Analytics: Google Analytics (with IP address anonymization).

5.3. State authorities: Only upon lawful request (police, courts, tax authorities).

5.4. External escrow tools (DIMI, DEM, EFL). NH provides, free of charge, links to independent escrow tools operated by third parties (the developers of the DIMI, DEM and EFL projects), as part of a courtesy, entirely unpaid cross-promotion between services — with no fee, commission, or other benefit for either party. Clicking such a link takes the user away from the nohodl.org website. NH does not automatically transfer any personal data of the user to these tools, has no insight into data processed by these third parties, and bears no responsibility for them. Data entered directly on the external website is governed exclusively by that third party's own privacy policy, independent of NH.

6. TRANSFER OF DATA OUTSIDE THE EU/EEA

Data may be transferred outside the European Economic Area only:

  • To countries with an adequacy decision from the European Commission (e.g., Canada, Japan).
  • With the application of the European Commission's Standard Contractual Clauses.
  • In the case of Google Workspace – with appropriate safeguards in place.
  • For users based in Switzerland – NH applies data protection standards equivalent to those under the GDPR, to the extent consistent with the Swiss Federal Act on Data Protection (FADP).

7. YOUR RIGHTS

Under the GDPR, you have the right to:

  • 7.1. Access your data (Art. 15 GDPR): You can request information about what data we process.
  • 7.2. Rectification of data (Art. 16 GDPR): You can correct inaccurate data in your account.
  • 7.3. Erasure of data (Art. 17 GDPR): You can request the deletion of your account and data (subject to legal exceptions).
  • 7.4. Restriction of processing (Art. 18 GDPR): You can request the restriction of processing in specific situations.
  • 7.5. Data portability (Art. 20 GDPR): You can receive your data in a structured, commonly used format.
  • 7.6. Objection (Art. 21 GDPR): You can object to processing for marketing purposes.
  • 7.7. Withdrawal of consent (Art. 7(3) GDPR): Consent for the newsletter can be withdrawn at any time.

Exercising your rights: All rights can be exercised by contacting us at nohodl@zohomail.eu. We will respond within 30 days.

8. DATA SECURITY

8.1. Technical measures:

  • SSL/HTTPS encryption across the entire website.
  • Passwords stored in hashed form.
  • Regular security updates.
  • Firewalls and intrusion detection systems.

8.2. Organizational measures:

  • Limited access to data for personnel.
  • Data protection training.
  • Incident response procedures.

8.3. Sensitive data: We do NOT collect: PESEL numbers, national ID card details, payment card data, private cryptocurrency keys. WARNING: Do not post sensitive data in your listings.

9. SPECIAL RULES FOR CRYPTOCURRENCIES

9.1. Information on cryptocurrencies in listings:

  • Exchange rates are for informational purposes only.
  • nohodl.org does not guarantee the accuracy of rates.
  • The user is solely responsible for verifying current market rates.

9.2. Warnings:

  • Cryptocurrency transactions are irreversible.
  • nohodl.org does not act as an intermediary in transactions.
  • We recommend in-person transactions (local P2P).
  • Should the user choose to use the independent, external escrow tools linked from the website (see section 5.4), the above remains unchanged — NH still does not act as an intermediary in the transaction, does not guarantee its safety, and bears no responsibility for it.

9.3. User obligations:

  • Independently verify the legality of cryptocurrencies in your country.
  • Fulfill tax obligations according to your local law.
  • Exercise caution during transactions.

10. CHILDREN'S DATA

  • The service is not directed at persons under the age of 13.
  • Persons aged 13-18 may use it with parental/guardian consent.
  • If we detect data of a child, we will delete the account.

11. AUTOMATED DECISION-MAKING

We DO NOT use profiling or automated decision-making that produces legal effects.

12. CHANGES TO THE PRIVACY POLICY

  • Changes will be published on this page with an updated date.
  • We will notify registered users via email about significant changes, at least 15 days before they take effect.
  • Continued use of the service signifies acceptance of the changes.

13. CONTACT AND COMPLAINTS

Contact for data protection matters:

  • Email: nohodl@zohomail.eu
  • We respond in Polish or English.

Right to lodge a complaint: You have the right to lodge a complaint with the Polish supervisory authority, the President of the Personal Data Protection Office (Urząd Ochrony Danych Osobowych, ul. Stawki 2, 00-193 Warsaw), if you believe the processing violates the GDPR.

14. FINAL PROVISIONS

14.1. User responsibility:

  • The user is responsible for the content of their listings.
  • By publishing a listing, you consent to the disclosure of your contact data to other users.

14.2. Limitation of nohodl.org's liability:

  • We are not a party to transactions between users.
  • We do not verify the truthfulness of listings.
  • We are not liable for cryptocurrency transactions.
  • We are not liable for the services, security, availability, or outcomes of using the independent, external escrow tools (DIMI, DEM, EFL) we link to as part of the free, courtesy cooperation described in section 5.4.

14.3. Governing law:

  • This Policy is governed by Polish law.
  • Any disputes shall be resolved by the court in Wrocław, Poland.