1. Controller and contact
The controller of personal data processed in connection with your Earnando account is N2XO, Inc., a company registered in the USA. Address: 1001 S Main St, Ste 500, Kalispell, MT 59901-1498, USA. For data protection matters and requests concerning your rights, contact [email protected].
2. Data we process
- Account: email, user identifier, password hash, account creation and verification dates, role, status, display name and accepted document versions.
- Profile: details you provide, such as name, date of birth, country, address, phone and company details. Self-reported data is not automatically verified.
- Verification: Sumsub process identifiers, status and outcome. You submit documents and facial images directly to Sumsub. Earnando does not store copies in its account database.
- Operations: blockchain addresses, transaction identifiers, assets, amounts, ledger balances, order statuses and links needed to operate your wallet.
- Referrals and security: referral codes and relationships, accrual history, sign-in and administrative logs, token hashes and authentication-attempt records. Network infrastructure also processes connection data, including IP addresses.
- Contact: your messages and information needed to handle your request.
3. Purposes and legal bases
Where the GDPR applies, we process data for these purposes:
- account creation and operation, sign-in, requested features and support: performance of a contract or steps requested before entering one (Article 6(1)(b));
- verification, anti-money-laundering and transaction records: compliance with a legal obligation where it applies to the operator and service (Article 6(1)(c));
- account and infrastructure security, abuse prevention and establishing, pursuing or defending claims: the controller’s legitimate interests in protecting the service and its rights (Article 6(1)(f)).
Accepting the terms and reading this policy do not constitute consent to unrestricted data processing or marketing. Where a specific process requires consent, it must be obtained separately, with its purpose and withdrawal options explained.
4. Documents and biometrics
Identity verification is a separate process handled by Sumsub. It may include documents, facial images, liveness checks and biometric matching. Biometrics used for unique identification require a specific legal basis separate from accepting the account terms.
Before uploading a document, read the verification form’s information about the parties processing data, purposes, legal bases, retention and international transfers. Ask the operator about any uncertainties. Not completing required verification may prevent access to some features.
5. Recipients and suppliers
Authorized members of the operator’s team may access data as needed for support and security. We use the following providers:
- Amazon Web Services: application and database hosting in the Stockholm region, and Amazon SES for account emails;
- Cloudflare: domain, internet connection and traffic protection services;
- Sumsub: document and identity verification;
- Cobo: wallet infrastructure and cryptoasset transaction processing;
- demonstration feature providers: Lightspark and Stillman infrastructure for features available in the panel.
We share data needed for the relevant operation, not your entire profile with every provider. Data may be disclosed to competent authorities when required by law. We do not sell user data.
6. International data transfers
The operator is based in the USA and some providers operate internationally. Hosting the primary infrastructure in Sweden does not mean all data is processed only within the European Economic Area.
Transferring GDPR-covered data outside the EEA requires a valid basis under Chapter V, such as an applicable adequacy decision or appropriate safeguards. Contact the controller for the basis and a copy of the safeguards applicable to a particular provider. Using the service does not constitute consent to transfers without the required safeguards.
7. Data retention
We retain account and profile data while your account is open. After closure, further retention depends on pending transactions, applicable record-keeping obligations and limitation periods for claims. This does not mean retaining your entire profile indefinitely.
Verification and transaction records may be subject to separate retention obligations. The operator’s published AML policy states a minimum of five years for customer and transaction records. Whether this period applies and when it starts depend on the relationship and applicable law. Ask the controller for information about your own data.
An account session is valid for up to 12 hours, an activation link for one hour and a password-reset link for 30 minutes. Expiry does not mean the technical record is immediately deleted from the database.
Daily local database backups are kept for 14 days and are accessible only to the server administrator. Data on a public blockchain remains there after account closure; the operator cannot delete it.
9. Your rights
Where the GDPR applies, you may request access to and a copy of your data, rectification, erasure, restriction and, in the cases provided by law, portability. You may object to processing based on legitimate interests. Where processing relies on consent, you may withdraw it without affecting the lawfulness of earlier processing.
Send your request to [email protected]. We may request information necessary to verify your identity securely. We respond within the applicable statutory deadlines; GDPR requests are generally answered within one month.
You may complain to the competent supervisory authority; in Poland, to the President of the Polish Personal Data Protection Office. The right to erasure does not cover records that must be retained by law and cannot remove data from a public blockchain.
10. Providing data and automated decisions
Your email address and password are needed to create and secure your account. Other profile details may be optional for the account itself but required for a particular service or verification. Without the required data, that service may not be available.
The system uses automated access rules and verification results, such as email confirmation or Sumsub status. If an access refusal seems incorrect, contact the operator for an explanation and human review. This policy does not replace information about automated assessments performed by the verification provider.
11. Document version
Effective from 29 October 2026. Version: earnando-privacy-2026-10-29-v3. Material changes to data processing require updated information for users. You can print this document or save it as a PDF from your browser.