Privacy Policy

Effective Date: November 1, 2025

1. Introduction

At No Friction, we take your privacy seriously. This Privacy Policy describes our practices concerning the information we collect from you when you visit our website or use our services. By accessing our website or using our services, you acknowledge that you have read and understood this Privacy Policy.

2. Who We Are

No Friction is a product of CCA Innovations OU, a company committed to providing innovative technological solutions while respecting your privacy. We act as both a "data controller" and a "service provider" as defined under applicable privacy laws.

3. Information We Collect

3.1 Information You Provide to Us

We may collect the following categories of personal information that you voluntarily provide to us:

• Identifiers: Name, email address, phone number, postal address, and online identifiers
• Professional Information: Company name, job title, industry, and professional interests
• Communication Content: Records of your communications with us, including inquiries, feedback, and support requests
• Transaction Data: Records of products or services you've requested or purchased from us

3.2 Information We Collect Automatically

When you visit our website or use our services, we may automatically collect certain information about your device and usage patterns. This information may include:

• Device Information: IP address, browser type and version, operating system, device type
• Usage Data: Pages visited, time spent on pages, links clicked, features used, and interaction patterns
• Location Data: General location information derived from IP address
• Cookies and Similar Technologies: Information collected through cookies, web beacons, and similar technologies

By using our site, you acknowledge and agree that we track this information while ignoring personally identifiable information (PII) unless you explicitly provide it to us.

4. How We Use Your Information

We use your personal information for the following purposes:

• To provide the services you've requested
• To respond to your inquiries, comments, or support requests
• To personalize and improve your experience with our services
• To send you information about our services that may interest you, but only when you've explicitly requested such information
• To comply with legal obligations
• To protect our rights, property, and safety, as well as the rights, property, and safety of our users or others

5. Disclosure of Your Information

We do not share or disclose your personal information except in the following limited circumstances:

• Service Providers: We may disclose your information to trusted third-party service providers who assist us in operating our website and providing our services, such as hosting providers and email service providers. These providers are contractually bound to use your information only for the purposes of providing services to us.
• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).
• Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information.
• Protection of Rights: We may disclose your information when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

We do not share your data with partners for their own marketing or other purposes.

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. When determining the appropriate retention period, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, and the purposes for which we process the information.

7. Your Rights and Choices

7.1 Your California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: You have the right to request information about the personal information we collect, use, disclose, and sell.
• Right to Delete: You have the right to request the deletion of your personal information, subject to certain exceptions.
• Right to Correct: You have the right to request correction of inaccurate personal information.
• Right to Opt-Out of Sale or Sharing: You have the right to direct us not to sell or share your personal information. However, as stated throughout this policy, we do not sell or share your personal information with third parties for their own use.
• Right to Limit Use of Sensitive Personal Information: You have the right to limit the use of sensitive personal information.
• Non-Discrimination: You have the right not to be discriminated against for exercising your privacy rights.

To exercise these rights, please contact us at privacy@nofriction.io. We will respond to your request within 45 days.

7.2 Your European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), United Kingdom, or Switzerland, you have certain rights under the General Data Protection Regulation (GDPR) and similar laws:

• Right of Access: You have the right to request a copy of the personal information we hold about you.
• Right to Rectification: You have the right to request correction of any inaccurate personal information we hold about you.
• Right to Erasure: You have the right to request deletion of your personal information in certain circumstances.
• Right to Restrict Processing: You have the right to request that we restrict the processing of your personal information in certain circumstances.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to our processing of your personal information in certain circumstances.
• Right to Withdraw Consent: Where we rely on your consent to process your personal information, you have the right to withdraw that consent at any time.

To exercise these rights, please contact us at privacy@nofriction.io. We will respond to your request within one month. If you are in the EEA, you also have the right to lodge a complaint with a supervisory authority.

7.3 International Data Transfers

For users in the European Economic Area (EEA), United Kingdom, or Switzerland, please note that your information may be transferred to, stored, and processed in the United States and other countries where our servers and service providers are located. These countries may not have data protection laws as comprehensive or protective as those in your country.

When we transfer your personal information outside the EEA, UK, or Switzerland, we ensure that adequate safeguards are in place to protect your information, such as Standard Contractual Clauses approved by the European Commission or other appropriate transfer mechanisms.

8. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website. Cookies are small text files that are stored on your device when you visit a website. We use the following types of cookies:

• Necessary Cookies: These cookies are essential for the operation of our website and enable basic functions like page navigation and access to secure areas.
• Analytical/Performance Cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously.
• Functionality Cookies: These cookies enable our website to remember choices you make (such as your language preference) to provide enhanced features.

You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of our website.

9. Data Security

We implement reasonable and appropriate security measures to protect your personal information from accidental loss, unauthorized access, use, alteration, and disclosure. However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security.

10. Children's Privacy

Our services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under 16. If we learn that we have collected personal information from a child under 16, we will promptly take steps to delete such information.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Effective Date" at the top of this page. We encourage you to review this Privacy Policy periodically.

12. Contact Us

Last Updated: November 1, 2025