[ Legal · Nomisma LLC ]

Notice to Users in India

Version v1 · Effective 26 October 2026 · Last updated 26 October 2026

This notice is given under the Digital Personal Data Protection Act, 2023 and the Rules made under it. It is shown to you, on its own and separately from the Terms of Service, when you create a Smartsteps account from India, and you can read it here at any time. It is written in plain English; if you would like it in another language listed in the Eighth Schedule to the Constitution of India, email info@nomisma.ai and we will provide it.

1. Who is processing your personal data

Nomisma LLC, 30 N Gould St, Ste R, Sheridan, Wyoming 82801, United States, which provides Smartsteps (smartsteps.ai). Contact: info@nomisma.ai. Our Grievance Officer is our Managing Member, reachable at the same address.

2. The personal data we process

(a) your name, work email address, password (stored only as an Argon2id hash), company name and country;
(b) records of your sign-ins and other security events, including IP address and browser user agent;
(c) billing contact details and transaction records, if your company buys a Plan;
(d) the content of support requests you send us.

We do not ask for any other personal data to create an account.

3. The purposes

We process this data only to:

create and secure your account and sign you in;
provide the Smartsteps Service to your Workspace, including analyses, Reports and monthly standing updates;
take payment and keep billing and tax records;
answer your support requests;
comply with sanctions and other legal obligations.

4. The services this enables

Access to your account and Workspace; analysis of your websites and policies; Reports and monthly standing emails; billing and invoices; and support.

You consent to this processing by ticking the separate box next to this notice at sign-up; the box is never pre-ticked. We record the time, this notice's version and the exact text you agreed to.

You may withdraw your consent at any time, as easily as you gave it: in Settings, choose Delete my account, or email info@nomisma.ai. We will then stop processing your personal data within a reasonable time and cause our processors to stop, except where the law requires or permits us to keep it (for example, billing and tax records). Withdrawal does not affect processing carried out before it. Because we cannot provide the Service without your account data, withdrawing consent closes your account.

6. Your rights

You may access a summary of your personal data and how it is processed, have it corrected, completed, updated or erased, nominate another person to exercise your rights if you die or become incapacitated, and have a grievance redressed. To exercise a right, email info@nomisma.ai or use Help in the Service. Our Grievance Officer responds within ninety (90) days.

7. Complaints

If you are not satisfied with our response, you may complain to the Data Protection Board of India in the manner the Board prescribes.

8. Where your data is processed

Your personal data is transferred to and processed in the United States. We monitor notifications made by the Government of India under section 16 of the Act and will not transfer personal data to any country or territory it restricts.

9. More information

Our full Privacy Policy describes our processing in detail, including retention periods and security measures.