Privacy Policy

Nomen Financial, Inc. ("Nomen," "we," "us," or "our") is a financial technology company headquartered in Georgia. We operate the Nomen platform at usenomen.com and related mobile applications (collectively, the "Platform").

Athlete: A college or high school student who uses Nomen to track NIL deals, file taxes, and receive payments.

Collective: A NIL collective or organization that uses Nomen to disburse payments to Athletes and manage 1099 issuance.

Agent: A sports agent or athlete advisor with read-only access to an Athlete's financial dashboard.

NIL Income: Compensation earned under Name, Image, and Likeness rights, classified as self-employment income under IRS rules.

Connected Accounts: Stripe Connect Express accounts linked to individual Athletes for payment receipt.

1099-NEC Data: Tax information, including Taxpayer Identification Numbers (TINs) and income records, used to generate IRS Form 1099-NEC.

KYC Data: Know Your Customer identity verification data collected through Persona, including government ID and selfie verification.

3.1 Information You Provide Directly

Account registration: full legal name, email address, university or school affiliation, graduation year, sport, and position.

KYC verification (via Persona): government-issued photo ID, selfie biometric image, date of birth, and Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN). This information is transmitted directly to Persona and Stripe and is subject to their privacy policies.

Tax information: income records, 1099-NEC form data, deductible expenses, and filing status. Transmitted to Column Tax for preparation and filing.

Payment information: bank account details for ACH disbursement, collected and held by Stripe. Nomen does not store raw bank account numbers.

NIL deal details: brand name, deal value, payment schedule, deliverable descriptions, and NCAA disclosure status. This information is stored on Nomen servers.

Communications: emails, support messages, and feedback you send to Nomen.

3.2 Information Collected Automatically

Usage data: pages visited, features used, session duration, clicks, and navigation patterns.

Device information: IP address, browser type, operating system, and device identifiers.

Transaction data: payment amounts, timestamps, transaction IDs, and payment status from Stripe webhooks.

Log data: server logs, error reports, and API call records for security and debugging purposes.

3.3 Information from Third Parties

Stripe: payment status, KYC verification results, payout records, and account.updated webhook events.

Persona: identity verification status and risk signals (pass, fail, or review).

Column Tax: filing status, return submission confirmation, and IRS acceptance status.

Track1099: 1099-NEC filing confirmation and IRS acceptance status.

Providing the Platform: processing payments, issuing 1099s, preparing and filing tax returns, and displaying financial dashboards.

Identity verification: confirming your identity before enabling payment receipt through Stripe Connect Express, as required by financial regulations.

Tax compliance: aggregating income data, calculating self-employment tax estimates, generating 1099-NEC forms, and transmitting data to Column Tax for filing with the IRS.

Communications: sending transactional emails including payment confirmations, 1099 availability notices, tax deadline reminders, and KYC status updates.

Security: detecting fraud, preventing unauthorized access, and monitoring for suspicious activity on your account.

Platform improvement: analyzing usage patterns to fix bugs and develop new features. We use aggregated, de-identified data for this purpose.

Legal compliance: responding to lawful requests from government authorities, including the IRS, and fulfilling our obligations under applicable law.

We do not sell your personal information. We share data only as described below.

5.1 Service Providers

Stripe, Inc.: Payment processing, KYC verification via Stripe Connect Express, and payout disbursement. Your financial account data is governed by Stripe's Privacy Policy.

Persona Identities, Inc.: Identity document verification and biometric matching. KYC data is transmitted to and stored by Persona under their privacy framework.

Column Tax: Federal and state tax return preparation and IRS submission. Income and tax data is shared to enable filing.

Track1099: 1099-NEC form generation, TIN matching, and IRS e-filing. Payee name, TIN, and payment amount are transmitted.

Supabase, Inc.: Database hosting for account data, deal records, and transaction history. Data is stored in encrypted form.

Vercel, Inc.: Application hosting and content delivery.

5.2 Within Your Account

Agents: if you grant an Agent read-only access to your account, they may view your income summary, deal list, and 1099 status. They cannot view your SSN, bank details, or KYC documents.

Collectives: if a Collective onboards you to their account, the Collective admin may view payment history related to their disbursements. They cannot view income from other brands or your tax return.

5.3 Legal Requirements

We may disclose your information when required by law, subpoena, or valid legal process, including IRS information requests, court orders, and regulatory inquiries. We will notify you of such requests where legally permitted to do so.

5.4 Business Transfers

If Nomen is acquired, merged, or undergoes a change of control, your data may be transferred to the successor entity. We will provide notice prior to your data becoming subject to a materially different privacy policy.

Nomen handles sensitive financial data and applies additional protections beyond standard account data:

SSN and ITIN values are encrypted at rest using AES-256 and are never displayed in full within the Platform after initial submission.

Bank account numbers are never stored by Nomen. They are transmitted directly to Stripe and governed by Stripe's security practices.

Tax return data transmitted to Column Tax is encrypted in transit (TLS 1.2 or higher) and is not used by Nomen for any purpose other than filing.

1099 income data is accessible only to the Athlete who earned it and to Nomen for compliance purposes. Brands and payers cannot access an Athlete's aggregated tax picture through Nomen.

Nomen does not offer financial advice. Tax estimates are provided for informational purposes and are not a substitute for advice from a licensed tax professional.

Account data is retained for the duration of your active account plus seven (7) years, as required for tax record retention under IRS guidelines.

KYC documents (government ID images and selfie data) are retained by Persona per their retention policy. Nomen stores only the verification result (pass/fail) and a Persona-issued record ID.

Tax returns and 1099 records are retained for seven (7) years following the tax year they relate to.

Payment transaction records are retained for seven (7) years for financial audit and compliance purposes.

If you request account deletion, we will delete or anonymize your personal information within 30 days, except for records we are required to retain by law.

8.1 Access and Correction

You may access, review, and correct your account information at any time through the Platform's settings. For information held by our service providers (Persona, Column Tax, Track1099), you may need to contact them directly.

8.2 Deletion

You may request deletion of your account by emailing privacy@usenomen.com. We will process your request within 30 days subject to retention obligations described in Section 7.

8.3 Communications

You may opt out of marketing communications at any time using the unsubscribe link in any email. You cannot opt out of transactional emails (payment confirmations, 1099 availability, tax deadline notices) while your account is active, as these are required for Platform operation.

8.4 Agent Access Revocation

You may revoke Agent read-only access at any time through account settings. Revocation takes effect immediately.

8.5 California Residents

California residents have rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete personal information, and the right to opt out of the sale of personal information. We do not sell personal information. To exercise your rights, email privacy@usenomen.com with the subject line "California Privacy Request."

Nomen implements reasonable technical and organizational safeguards including:

TLS 1.2+ encryption for all data in transit.

AES-256 encryption for sensitive data fields at rest (SSN, ITIN, tax identifiers).

Row-level security (RLS) policies enforced at the database level to prevent cross-account data access.

Role-based access controls (athlete, agent, collective_admin, admin) enforced at the application and database layers.

Multi-factor authentication support for all accounts.

Regular security reviews prior to production deployment.

No security system is perfect. In the event of a data breach affecting your personal information, we will notify you as required by applicable law.

Nomen is not directed to children under 13. Users under 18 may use the Platform only with verifiable parental or guardian consent as required by applicable law, including COPPA. If we learn that we have collected personal information from a child under 13 without verified consent, we will delete that information promptly.

We may update this Privacy Policy as our practices change or as required by law. We will notify you of material changes by email and by posting a notice on the Platform at least 30 days before the changes take effect. Your continued use of the Platform after the effective date constitutes acceptance of the updated policy.