Introduction
Nolly Services Inc (Nolly.com) (“Nolly.com,” “we,” “us,” “our,” or “Company”) is committed to protecting your privacy and ensuring you have a positive experience on our website and when using our services. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website nolly.com and use our services, including but not limited to ITIN applications, EIN registration, FIRPTA refund assistance, incorporation filings, and tax return preparation services.
Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use our services. By accessing and using Nolly.com’s website and services, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy.
1Information We Collect
AInformation You Provide Directly
We collect information that you provide directly when you interact with our website and services, including:
- Contact Information: Full name, email address, phone number, and mailing address
- Identification Documents: Government-issued ID, passport number, birth date, Social Security Number (or alternative tax identification), and other identity verification documents required for ITIN/EIN applications
- Financial Information: Bank account details, income information, tax filing history, and payment information for service fees
- Tax and Business Information: Employment status, business structure, income sources, business type, and U.S. property details for FIRPTA services
- Communication Information: Messages, inquiries, and correspondence you send us through contact forms, email, WhatsApp, phone calls, or other communication channels
- Service Request Information: Details about which services you’re requesting (ITIN, EIN, tax returns, incorporation, FIRPTA) and your specific needs
- Payment Information: Credit card numbers, bank account information, and billing address (processed securely through third-party payment processors)
BInformation Collected Automatically
When you visit our website, certain information is collected automatically, including:
- Log Data: IP address, browser type, operating system, referring URL, pages visited, and time spent on our website
- Device Information: Device type, mobile device identifiers, and hardware model
- Location Information: General geographic location based on IP address (not precise GPS location)
- Behavioral Data: Website navigation patterns, features accessed, searches performed, and user interaction data
- Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar tracking technologies (see Section 8)
CInformation From Third Parties
We may receive information about you from third parties, including:
- Payment Processors: Transaction information and verification details
- Government Databases: Limited verification through IRS-authorized channels for ITIN/EIN applications
- Referral Sources: Information provided by friends, family, or referral partners who refer you to our services
- Analytics Providers: Website usage and behavior data from Google Analytics and similar services
- Social Media: Public profile information if you interact with us on social platforms
Important Note: We only collect Sensitive Personally Identifiable Information (SPII) such as Social Security Numbers, passport information, and financial data when absolutely necessary for providing our services. This information is treated with the highest level of security and confidentiality.
2How We Use Your Information
Nolly.com uses the collected information for various purposes:
APrimary Service Purposes
BCommunication Purposes
- Sending service-related notifications and updates
- Responding to your inquiries and customer service requests
- Sending administrative information and policy updates
- Notifying you about changes to our services or fees
- Requesting feedback about your experience with our services
CBusiness and Legal Purposes
DMarketing and Improvement Purposes
Marketing Opt-Out: You may opt out of receiving marketing communications at any time by clicking the “unsubscribe” link in any marketing email or by contacting us directly at info@nolly.com.
3Legal Basis for Processing Personal Information
We process your personal information based on the following legal foundations:
4Information Sharing and Disclosure
AWith Whom We Share Your Information
We only share your personal information with third parties in the following circumstances:
BGovernment Agencies and Required Disclosures
- IRS (Internal Revenue Service): We submit your information as required when filing ITIN applications, EIN registrations, FIRPTA claims, and tax returns. This is a legal requirement of our service.
- Government Compliance: We disclose information as required by law, court order, or government request
- Regulatory Authorities: Information may be shared with tax authorities and regulatory agencies as legally required
CService Providers and Contractors
We may share information with third-party service providers who assist us in providing our services, including:
- Payment Processors: Credit card processors and payment gateways (PCI-DSS compliant)
- Document Management Systems: Secure cloud storage providers for document management
- Communication Providers: Email service providers and messaging platforms
- Legal and Accounting Advisors: Professionals assisting with compliance and legal matters
- Cloud Infrastructure Providers: Secure hosting and data storage providers
All service providers are contractually required to maintain the confidentiality and security of your information and may only use it to provide the services we have engaged them to perform.
DBusiness Transfers
If Nolly.com is involved in a merger, acquisition, bankruptcy, dissolution, reorganization, or similar transaction or proceeding, your information may be transferred as part of that transaction. We will provide notice before your information becomes subject to a different privacy policy.
EWith Your Consent
We may share your information with other third parties with your explicit consent, such as:
- Sharing your testimonial or case study publicly
- Referral to other trusted service providers you request
- Any other purpose for which you provide specific authorization
FWhat We Do NOT Do
- We do NOT sell your personal information to third parties for their marketing purposes
- We do NOT share your information with data brokers or list services
- We do NOT rent your email address or contact information
- We do NOT disclose sensitive information (SSN, passport, financial data) except as legally required
Data Processing Agreements: All service providers who handle your personal information have executed Data Processing Agreements ensuring GDPR, CCPA, and other regulatory compliance.
5Data Security and Protection
ASecurity Measures
Nolly.com implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include:
BTechnical Security
CAdministrative Security
- Access Controls: Strict access controls limit who can view and handle your information
- Employee Training: All staff members receive privacy and security training
- Non-Disclosure Agreements: All employees and contractors sign confidentiality agreements
- Need-to-Know Basis: Information is shared only with employees who need it to perform their jobs
- Audit Trails: We maintain detailed logs of all access to personal information
DPhysical Security
- Secure offices with access controls and surveillance
- Locked storage for physical documents
- Secured document disposal procedures
ELimitations
While we implement strong security measures, no internet transmission or electronic storage system is completely secure. We cannot guarantee absolute security, but we are committed to protecting your information to the greatest extent possible under applicable law.
Security Incident Response: In the unlikely event of a data breach, we will notify affected individuals without unreasonable delay as required by applicable law and regulations.
6Data Retention
ARetention Periods
We retain your personal information for as long as necessary to provide our services and fulfill the purposes outlined in this Privacy Policy. Specific retention periods are as follows:
BDeletion Procedures
When information is no longer needed, we securely delete or anonymize it. Deletion is performed through secure methods that prevent recovery, such as:
- Encrypted deletion of electronic files
- Physical destruction of paper documents
- Data anonymization making information impossible to identify you
CLegal Holds
If we receive a legal hold or court order, we may retain information for longer than normal retention periods to comply with legal obligations.
7Your Rights and Choices
AYour Privacy Rights
Depending on your location, you may have the following rights concerning your personal information:
BRight to Access
You have the right to request access to the personal information we hold about you and receive a copy in a portable format.
CRight to Correct
You have the right to request correction of inaccurate or incomplete personal information.
DRight to Delete
You have the right to request deletion of your personal information, subject to certain exceptions such as:
- Information required by law to be retained
- Information necessary to complete services you’ve requested
- Information needed to establish, exercise, or defend legal claims
ERight to Data Portability
You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another controller.
FRight to Object
You have the right to object to the processing of your information for certain purposes, including:
- Marketing communications
- Profiling or automated decision-making
- Processing based on legitimate interests
GRight to Withdraw Consent
If processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing before withdrawal.
HRight to Restrict Processing
You have the right to restrict how we process your information in certain circumstances.
IHow to Exercise Your Rights
To exercise any of these rights, please contact us using the information provided in Section 14. We will respond to your request within 30 days (or as required by applicable law). We may require verification of your identity before processing your request.
Limitation Note: Some requests may be subject to limitations if the information is necessary for legal compliance, service completion, or other legal requirements. We will explain any limitations when we respond to your request.
9Third-Party Services and Links
AThird-Party Websites
Our website may contain links to third-party websites, including social media platforms, payment processors, and other services. This Privacy Policy does not apply to third-party websites, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any third-party sites before providing your information.
BThird-Party Integrations
We may integrate third-party services that collect or access your information:
- Google Analytics: Website usage tracking and analysis
- Payment Processors: Secure payment processing and transaction management
- Email Marketing Platforms: Newsletter and marketing communication delivery
- Social Media Platforms: Integration with Facebook, Instagram, and WhatsApp for communications
- Customer Support Tools: Helpdesk and support ticket management systems
CYour Responsibility
When you access third-party services, you are subject to their privacy policies and terms of service. We recommend reviewing their policies before providing information.
DNo Endorsement
Links to third-party sites do not constitute an endorsement or approval of such sites or their content, privacy policies, or practices.
10Children’s Privacy
AAge Restriction
Our website and services are intended for users who are 18 years of age or older. We do not knowingly collect personal information from children under the age of 13. If we become aware that we have collected information from a child under 13, we will promptly delete such information.
BParental Consent
If a parent or guardian believes their child has provided information to us, they should contact us immediately at info@nolly.com.
CCOPPA Compliance
Our practices comply with the Children’s Online Privacy Protection Act (COPPA) and similar regulations in other jurisdictions.
Note: Nolly.com’s services (ITIN, EIN, tax filings) are intended for adults managing their own tax affairs. Our website and services are not designed for use by minors.
11International Data Transfers
AGlobal Operations
Nolly.com operates internationally and transfers personal information across borders to provide our services. Our company is based in Canada (Toronto, Ontario), but we serve clients worldwide and may transfer information to various jurisdictions.
BTransfer Mechanisms
When we transfer personal information internationally, we implement appropriate safeguards:
- Standard Contractual Clauses: We use EU Standard Contractual Clauses (SCCs) for transfers to jurisdictions outside the EU/EEA
- Data Processing Agreements: All transfer recipients have signed Data Processing Agreements ensuring adequate protection
- Encryption: Information is encrypted during transmission and storage
- Privacy by Design: We implement privacy-protecting technologies for international transfers
CYour Consent
By using our services, you consent to the transfer of your information to Canada and other jurisdictions where we operate, as necessary to provide our services and comply with legal obligations.
DGDPR and International Regulations
For users in the European Union and other jurisdictions with data protection regulations, we comply with all applicable requirements including GDPR.
12California Privacy Rights (CCPA/CPRA)
If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA):
ARight to Know
You have the right to know what personal information is collected, used, shared, or sold.
BRight to Delete
You have the right to request deletion of personal information collected, with certain exceptions.
CRight to Correct
You have the right to correct inaccurate personal information.
DRight to Opt-Out
You have the right to opt out of “sales” of personal information or sharing for targeted advertising.
ERight to Limit Use
You have the right to limit our use of sensitive personal information.
FRight to Non-Discrimination
We will not deny services, charge different prices, or provide different service quality based on your exercise of privacy rights.
GHow to Submit Requests
To submit a CCPA/CPRA request, contact us at info@nolly.com with “California Privacy Request” in the subject line. We will verify your identity and respond within 45 days.
HAuthorized Agent
You may designate an authorized agent to make requests on your behalf.
13Changes to This Privacy Policy
AUpdates and Modifications
Nolly.com may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will update the “Last Updated” date at the top of this policy when we make material changes.
BNotification of Changes
If we make material changes that adversely affect your privacy rights, we will notify you by:
- Sending an email to your registered email address
- Posting a prominent notice on our website
- Requiring your consent to the new terms before continued use of our services
CContinued Use
Your continued use of our website and services following the posting of changes constitutes your acceptance of the updated Privacy Policy.
DPrevious Versions
Previous versions of this Privacy Policy will be available upon request. Please contact us if you wish to review previous versions.
14Contact Information and Data Privacy Officer
If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us:
Company name: Nolly Services Inc (Nolly.com)
Mailing address
265 Rimrock Road, Suite 201Toronto, Ontario M3J 3C6
Canada
Response Time: We will respond to privacy inquiries within 30 days of receipt.
AYour Rights
You have the right to:
- Request access to your personal information
- Request correction of inaccurate information
- Request deletion of your information
- Submit complaints about our privacy practices
- Request a copy of this policy in an alternative format
BSupervisory Authorities
If you are not satisfied with our response to your privacy concerns, you have the right to lodge a complaint with your applicable supervisory authority or privacy commissioner. For Canadian residents, this includes the Office of the Privacy Commissioner of Canada.
CLegal Representation
You may contact us through a legal representative or authorized agent. We may require proof of authorization.
15Additional Important Information
AVerification of Identity
To protect your privacy and security, we may require you to verify your identity when submitting privacy requests. Verification methods may include:
- Providing information matching our records
- Answering security questions
- Providing government-issued identification
BService Provider Accountability
All our service providers are contractually obligated to maintain strict confidentiality and use your information only as necessary to provide their services. We regularly audit their compliance with this Privacy Policy.
CRegulatory Compliance
This Privacy Policy complies with:
- General Data Protection Regulation (GDPR) – European Union
- California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA)
- Personal Information Protection and Electronic Documents Act (PIPEDA) – Canada
- Other applicable international privacy laws and regulations
DAccuracy and Completeness
We strive to maintain accurate, complete, and up-to-date personal information. Please notify us immediately if any information in your account is inaccurate or requires updating.
ENon-Discrimination
We will not discriminate against you for exercising your privacy rights. We will not deny you services, charge you different prices, provide different service quality, or penalize you in any way for making privacy requests or exercising your legal rights.
Summary
This Privacy Policy establishes that Nolly Services Inc (Nolly.com) is committed to:
- Protecting your personal and sensitive information with industry-leading security measures
- Using your information only for legitimate, clearly-stated purposes
- Respecting your privacy rights and providing mechanisms to exercise them
- Being transparent about our data practices and compliance with applicable laws
- Providing responsive customer support for all privacy concerns