Our privacy policy applies when you use our website. Please ensure that you read this policy carefully. We are committed to ensuring that your privacy is protected. Should we collect or ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this privacy policy. We may change this privacy policy by updating this page. You should check this page from time to time to ensure that you are happy with any changes to our privacy policy and to continue using our website on this basis. This privacy policy was last updated on 20.06.2023.
WHO COLLECTS THE INFORMATION?
This website is operated by Nobi Bv. So in this privacy policy, references to “we”, “us” “Nobi” means Nobi Bv. By customers, we mean data subjects and by clients we mean the legal entity to whom we provide our services under a signed agreement.
We mainly process customers’ information as directed by our clients for the provision of our services. Our clients are the data controllers who determine the purpose of processing personal data and, accordingly, Nobi is a data processor of customer information with respect to those services. In other cases, Nobi is a data controller of customer information (e.g. regards to visitors of our web page and sending marketing materials to customers). We may also process certain information in anonymized form for the development and improvement of our services and in other forms and purposes set forth in this Privacy Policy.
WHAT INFORMATION DO WE COLLECT ABOUT YOU?
We collect information about you when you visit our site and fill in the forms:
Your name
Your contact information including your email address, phone number, address
Your IP address
Your actions while visiting and interacting with us
Your company information
Your preferences and interests
Website usage information is collected using cookies (see more information about the cookies below).
Here we have not brought out personal data we process for our clients, as this data can vary and is specifically regulated in the agreement signed between us and the client. If you wish to know more about what personal data we process on behalf of a specific client, then please contact that client.
Legal grounds and Purposes of processing
We may ask you to grant us consent for processing, to send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided. The details of processes and purposes will be outlined in the consent itself.
Consent is the legal basis for processing personal data for marketing messages. Please note that giving consent is voluntary and you have the opportunity to withdraw your consent at any time.
Regarding personal data processed about customers, Nobi’s main purpose for processing is to provide data analysis for our clients, and for this purpose we analyse the data provided to us by our clients in order to fulfil the agreement entered into with the client for:
(1) performance of the Agreement (including for the provision of the service);
(2) performance of the obligations arising from the Agreement (including the realisation of rights arising from the provision of the service);
(3) the purpose of realisation of rights and fulfilment of obligations deriving from legal acts;
(5) processing your inquiries and requests.
We also process your personal data if processing is necessary in our legitimate interests, meaning our interest in the management and direction of our business in order to be able to offer the best possible services on the market. For our legitimate interest, we may process data for the following purposes:
for analysing the use of our website and/or services, and using research and analysis results, among other methods, for carrying out satisfaction surveys, feedback questionnaires and developing our products and services;
for analysis of identifiers and personal data collected upon the use of our website, and services. We may use the collected data for web analysis or for the analysis of mobile and information society services, for ensuring, customising and improving functioning, for statistical purposes and for analysing and improving the experience of our website and for providing better and more personalised services;
for network, information and cyber security considerations, for example, for ensuring the security of our websites and service, as well as for the measures taken for making and storing backup copies;
for the establishment, exercise or defence of legal claims;
We only process personal data on legitimate interest, after careful assessment in order to ascertain that the legitimate interest is in compliance with the interests and rights of the data subject.
WHERE IS THIS INFORMATION HELD?
Information is held at our offices and those of our group companies, IT partners, on hosting providers (i.e. Hubspot), representatives and agents as described in this policy.
WHO DO WE SHARE THIS INFORMATION WITH?
We might also share the information about you with our selected partners. We disclose your personal data to data controllers for whom we are data processors (e.g. clients) and to our authorised processors (sub-processors), as well as to persons who are legally entitled to receive your personal data, such as our professional advisers or external contractors, who we have signed an agreement with. We may also be required to share some personal information as required to comply with the law.
DO WE TRANSFER INFORMATION FROM THE EUROPEAN ECONOMIC AREA (EEA)?
We process your personal data within the EEA. In the event that we need to transmit your personal data outside the EEA (e.g. for utilising the sub-processors’ services and technical infrastructure provided from or located in the US or the UK), the transmission shall be in accordance with the requirements, principles and safeguards as stated in the GDPR, such as relying on adequacy decisions issued by or standard contractual clauses approved by the European Commission. In cases where Nobi acts as the data controller, we make available further information on the safeguards applied (if relevant) upon your request.
HOW LONG WE KEEP THIS INFORMATION?
We shall store your personal data for as long as required by law or in accordance with the law, or for the purposes stated in this privacy policy.
We store the data of customers during the period set forth in the agreement signed between Nobi and the client (we may have different data retention periods agreed upon with the client) or as long as it is necessary for possible establishment, exercise or defence of legal claims of customers, clients or ourselves.
We may store your personal data for a longer period than the agreement duration if we have a lawful basis to do so, e.g. you have given us consent to use your personal data for marketing purposes or we have assessed that we have a legitimate aim to do so.
When the retention period of your personal data ends, we will destroy it in such a manner, that it would no longer be possible to reidentify you in any manner.
HOW DO WE SAFEGUARD THIS INFORMATION?
We are committed to ensuring that your personal data is secure and have adopted security measures in-line with applicable data protection law.
To preserve the integrity of your personal data and prevent data loss and unauthorised access or disclosure, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online and protect it from loss, misuse and unauthorised alteration and destruction.
Only our authorised employees, and those of our service providers’ processing data on our behalf, have access to your personal data. Our employees who have access to your personal data are required to adhere to our Privacy Policy and Security Policies and all third-party service providers acting as data processors for us are subject to contractual obligations to ensure that an appropriate level of security required is in place and that your personal data is only processed in accordance with our instructions.
DATA SUBJECT’S RIGHTS IN RELATION TO PERSONAL DATA
You as a data subject, have the following rights in relation to your personal data:
Right of access to personal data – you have the right to know which of your personal data we store and how we process it, including the right to know the purpose of the processing, the persons to whom we will disclose your personal data, information about automated decision-making and the right to receive copies of personal data.
Right to rectification of personal data – you have the right to request the rectification of inadequate, incomplete and/or misleading personal data.
Right to withdraw the consent given for the processing of personal data – you have the right at any time to withdraw the consent given to us for the processing of personal data. Please note that withdrawal of your consent shall not affect the legality of the processing that was made on the basis of consent before the withdrawal.
Right to erasure of personal data (“right to be forgotten”) – you have the right to request that we erase your personal data (for example, if you take back consent for the processing of personal data, or if personal data is no longer needed for the purpose for which it was collected). We have the right to refuse the erasure of personal data if the processing of personal data is necessary for the fulfilment of our legal obligation, to exercise the right to freedom of expression and information, for the preparation, presentation and protection of legal claims, or in the public interest.
Right to restriction of processing – in certain cases, you have the right to prohibit or restrict processing of your personal data for a certain period of time (e.g., if you have filed an objection to personal data processing).
Right to object – you have the right to file an objection if your personal data processing takes place on the basis of our legitimate interest or public interest. You shall have the right to object at any time to processing of personal data for direct marketing purposes, and we shall respond promptly. If we perform automated decision-making (including profiling) that will produce legal effects for you or have a significant effect on you, then you may file an objection and require human intervention in the decision-making process.
Right to data portability – If your personal data is processed automatically, you shall be entitled to receive personal data about you that you submitted to us as the data controller, in a structured, commonly used and machine-readable format, and you shall have the right to transmit or request us to transfer this personal data to another data controller, where technically feasible and the personal data has not been deleted by that time.
Submission of complaint – If you find that your rights have been breached, you have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority in the EEA.
HOW DO WE USE COOKIES?
We use cookies to analyse, personalise and improve our website.
A cookie is a small text file placed on your computer’s hard drive, device or web browser when you use websites. Cookies help analyse web traffic or let you know when you visit a website, and allow web applications to respond to you as an individual. This enables the web application to tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. You can control how websites use cookies by configuring your web browser’s privacy settings and cookie controls.
There are different types of cookies and we and the companies that help us run our business use cookies in several ways.
Necessary Cookies: are crucial for the basic functions of our website and our website will not work in its intended way without them. They are used for page navigation, preserving user status across page views, distinguishing between humans and bots or load balancing. These cookies do not store any personally identifiable data.
Analytic Cookies: are used to understand how you interact with our website by collecting and reporting information. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc. and we use analytic, traffic log and timestamp cookies such as Google Analytics and Hot Jar to identify which pages are being used. We may also collect further information about your use of our website through log files and other technologies including: your domain name; your browser type and operating system; the web pages you view, links you click; your IP address; the length of time you spent on our website; the referring URL or the webpage that led you to our website; and your mobile device ID, name and model. This helps us analyse data about web page traffic and improve our website to tailor it to your needs. We only use this information for statistical analysis purposes.
Advertising Cookies: are used to track visitors across websites and display ads that are relevant to you based on the pages you have visited and to analyse the effectiveness of ad campaigns. We use tools such as Google AdWords, Google DoubleClick and CloudFlare to analyse user behaviour and navigation on our website, interaction with active campaigns and to optimise our ads and tailor them to your interests. We use cookies from Albacross, FaceBook and Linked:In to to present relevant advertisement based on your preferences, implement your preferences when you return to our website, deliver a series of advertisement products and track the use of embedded services
Functional Cookies: help to perform certain functionalities like sharing the content of our website on social media platforms, collecting feedback and other third-party features or remembering your location.
We may combine this information with other information that we have collected about you or that you have provided to us, including, where applicable, your username, name, and other personal information. Such information is stored on HubSpot. For further information about this please visit HubSpot cookie security and privacy and what cookies does HubSpot set in a visitor’s browser
Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of our website. You can also manage your preferences on our website banner.
You can set your browser not to accept cookies. However this may mean that some of our website features may not function as a result.
DO WE HAVE LINKS TO OTHER WEBSITES?
Our website may contain links to other websites that are not governed by this privacy policy, instead they will be governed by their own privacy policies. Once you have used these links to leave our website, you should note that we do not have any control over the other websites you visit and are not responsible for the protection and privacy of any information which you provide whilst visiting such websites.
CONTROLLING YOUR PERSONAL INFORMATION AND CORRECTION
You may choose to restrict the collection or use of your personal information in the following ways:
Whenever you are asked to fill in a form on our website, you will be able to indicate via an ‘opt-in’ checkbox if you want the information to be used by anybody for direct marketing purposes if you have previously agreed to us using your personal information for direct marketing purposes, you may also opt-out of receiving future communications of this type by following the opt-out instructions contained in the e-mail
You can change your settings, delete cookies and withdraw consent at any time. If you wish to do so, please send an email to privacy@nobi.digital.
You may request details of personal information which we hold about you under local data protection laws. If you would like a copy of the information held on you please email to privacy@nobi.digital.
HOW TO CONTACT US
Please contact us if you have any questions about our privacy policy or information we hold about you: by email privacy@nobi.digital. If we are not able to resolve your query or concern, please contact the supervisory authority in your country of residence, country of work or country of alleged infringement for further information about your rights and how to make a formal complaint.