Edition dated: November 2025
This Privacy Policy (“Policy”) explains how Spiry Ltd., operating the Numi platform (“Numi”, “we”, “our”, “us”), collects, uses, and protects your personal data when you use our fintech services for creators and content monetization. This Policy is designed in accordance with the General Data Protection Regulation (GDPR) and the Cyprus Law 125(I)/2018. We also comply with other applicable data protection laws.
The Data Controller is Spiry Ltd., a company registered in the Republic of Cyprus (HE 479622), with its registered office at Arch. Makariou III & Orfeos, 67 & 2B, 1st Floor, Apt/Office 104, 1070 Nicosia, Cyprus.
If you have any questions about this Policy or wish to exercise your data rights, please contact us at info@spiry.app.
Numi processes personal data to provide and improve our services, verify users (KYC/AML), process payments, prevent fraud, comply with financial regulations and communicate with users. We rely on (1) the necessity to perform a contract with you, (2) compliance with legal obligations, (3) our legitimate interests in (a) securing, optimizing and improving our service (b) to protect our rights and legitimate interests in case of possible disputes, and (4) your consent where applicable.
We process the following categories of personal data:
Your personal data may be shared with third-party partners such as payment processors/banks (e.g. Stripe), compliance providers (e.g. SumSub) and analytics tools as necessary for service delivery and regulatory compliance. These partners process data in accordance with their own privacy and security standards, acting as independent controllers or processors (as applicable). We may also share data with law enforcement or regulatory authorities if legally required.
Numi uses artificial intelligence technologies to analyze user activity, detect anomalies, and provide personalized recommendations.
We may transfer your personal data to countries outside the European Economic Area. Where such transfers occur, we ensure appropriate safeguards.
We retain personal data only for as long as necessary to fulfill the purposes of processing, unless longer retention is required by law. Financial and compliance-related data may be retained for as long as required by AML/finance regulations.
If such rights are available to you under the applicable laws, you have the right to access, correct, delete (“right to be forgotten”), restrict processing, object to processing, and request data portability. You can exercise your rights by contacting us at info@spiry.app.
We use cookies and analytics tools to personalize user experience, monitor traffic, detect fraud, and improve our services. You may disable cookies in your browser settings, but some features of Numi may not function properly.
We implement technical and organizational measures to protect your data from unauthorized access, disclosure, alteration, or destruction, including encryption, anonymization and access control protocols.
Our services are not directed to individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe that a child has provided us with personal data, please contact us and we will delete it promptly.
We may update this Policy from time to time. The latest version will always be available at https://numi-ai.com/privacy. Significant changes will be communicated via email or platform notifications.
