0.0 March 2018
0.1 May 2018
Review & Update
0.2 May 2018
Review & Update
Table of Contents
1. Collection of Information. 3
a. Information You Provide to Us. 3
b. Information We Collect Automatically When You Use the Services. 3
c. Information We Collect From Other Sources. 4
2. Use of Information. 4
d. Sharing of Information. 4
e. Social Sharing Features. 5
f. Advertising and Analytics Services Provided by Others. 5
g. Transfer of Information. 5
h. Residents of the European Economic Area. 6
3. Controllers. 6
i. Legal Basis for Processing. 6
4. Data Retention. 6
5. Data Subject Requests. 6
6. Questions or Complaints. 7
7. EU-U.S. Privacy Shield Framework. 7
8. Security. 7
9. Request access to one's personal data
j. Access Rights.
k. Account Information.
l. Location Information.
1. Collection of Information
a. Information You Provide to Us
We collect information you provide directly to us. For example, we collect information when you create an account, participate in any interactive features of the Services, fill out a form, participate in a contest, promotion or survey, register for an event or course, apply for a job, request customer support or otherwise communicate with us. The types of information you may choose to provide include your name, email address, postal address, phone number, fax number, payment information, gender, information about your company and current position, and employment history.
b. Information We Collect Automatically When You Use the Services
When you access or use our Services, we automatically collect some or all of the following information about you:
Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Services.
Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
Location Information: We collect information about the precise location of your device each time you access or use one of our mobile applications. We collect this information in accordance with the permission process established by your mobile device operating system. If you want to later opt out of this collection, please see “Your Choices” below.
Product Usage Information: When you use our enterprise products and services on behalf of your organization, we collect information about your device and your use of those products and services, including the device IP address, login credentials, time zone, error messages, product interactions and configurations and other similar usage information.
Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this includes sending cookies to your computer or mobile device. .
c. Information We Collect From Other Sources
We also obtain information from other sources and combine that with information we collect through our Services. For example, if you connect an NITBY account with your social media account, we may have access to certain information from the company that owns or operates the social media account in accordance with the authorization procedures determined by such social media company. Additionally, NITBY receives information about you from other third parties whom you have authorized to share your information or who collect information in connection with co-branded offerings.
2. Use of Information
We use information about you for the following purposes:
Provide, maintain and improve our Services;
Provide and deliver the products and services you request, process transactions and send you related information, including confirmations and invoices;
Send you technical notices, updates, security alerts and support and administrative messages;
Respond to your comments, questions and requests and provide customer service;
Communicate with you about products, services, offers, promotions, rewards, and events offered by NITBY and others, and provide news and information we think will be of interest to you;
Monitor and analyze trends, usage and activities in connection with our Services;
Personalize and improve the Services and provide advertisements, content or features that match user profiles or interests;
Comply with our legal obligations; and
Process and deliver contest entries and rewards.
d. Sharing of Information
In connection with a joint marketing campaign, seminar, NITBY Marketplace product offering or other product or service offered by NITBY in conjunction with a third party, we share your information with the third parties participating in such offering and such parties may use this information for their direct marketing purposes. Please see “Your Rights to Information about Sharing” below for more information about this sharing.
With resellers of NITBY products and services or with sellers of products and services complementary to NITBY products and services, in order to pursue sales opportunities and for other direct marketing purposes. Please see “Your Rights to Information about Sharing” below for more information about this sharing.
With vendors, consultants and other service providers who need access to such information to perform services for us, including providing Product Usage Information to Google Analytics, which processes data as described at
In response to a request for information if we are required by, or believe disclosure is required by, any applicable law, regulation or legal process, including in connection with lawful requests by law enforcement, national security, or other public authorities;
To protect the rights, property and safety of NITBY or others;
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and
With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information.
We also share aggregated or de-identified information, which cannot reasonably be used to identify you.
e. Social Sharing Features
The Services offer social sharing features and other integrated tools (such as the Facebook “Like” button), which let you share actions you take on our Services with other media and vice versa. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.
f. Advertising and Analytics Services Provided by Others
g. Transfer of Information
NITBY processes information in Ireland in AWS Center. Accordingly, we and our service providers may transfer your information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal data receives an adequate level of protection in the jurisdictions in which we process it. We use European Commission-approved Standard Contractual Clauses to ensure an adequate level of protection for data originating from the EEA. .
h. Residents of the European Economic Area
If you are a resident of the EEA, you have certain rights and protections under the law regarding the processing of your personal data. Please see the sections below for more details.
NITBY sarl is controller of the data collected about you.
i. Legal Basis for Processing
If you are a resident of the EEA, when we process your personal data we will only do so in the following situations:
We need to use your personal data to perform our responsibilities under our contract with you (e.g., providing our services you have requested).
We have a legitimate interest in processing your personal data. For example, we process the personal data we collect from you to send you marketing communications, to communicate with you about changes to our Services, and to provide, secure, and improve our Services.
If we request your consent to a specific processing activity, and you provide your consent in the manner indicated.
In some cases, processing will be necessary for compliance with a legal obligation, such as response to legal process requests.
4. Data Retention
We store the information we collect about residents of the EEA for as long as is necessary for the purposes for which we originally collected it. We may retain certain information for legitimate business purposes or as required by law.
5. Data Subject Requests
If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected. In certain cases, you may also have the right to request that we erase data we are processing or to restrict or object to certain of our processing activities. You may also have the right to request that we provide the personal data you have provided us in a portable form for transmission to another controller’s service. If you would like to exercise any of these rights, you may contact us to email@example.com
6. Questions or Complaints
If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data protection authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
7. EU-U.S. Privacy Shield Framework
NITBY SARL adheres in their processing of personal data received from the EEA (“EU Data”) to the EU-U.S. Privacy Shield Framework Principles established by the U.S. Department of Commerce and the European Commission (the “Principles”). For more information about the Principles, please visit the Department of Commerce’s Privacy Shield website.
Please direct any inquiries or complaints regarding our compliance with the Principles to firstname.lastname@example.org
NITBY takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.
9. Request access to one's personal data
j. Access Rights
If you are a resident of a country that provides you with the right to request a copy of the personal data NITBY holds about you and/or to correct any inaccuracies within such data, and NITBY is required by applicable laws to respond to such requests, then you may address such requests to email@example.com. NITBY will use reasonable efforts to supply, correct or delete information that we hold about you or to advise you if we are not required by applicable laws to comply with such requests.
k. Account Information
If you have registered for an account via our Services, you may update, correct or delete your account information by logging into your online account.
l. Location Information
Some of our mobile applications collect precise geolocation information from your mobile device. Prior to collecting such information, you will be asked to consent to the application’s collection of this information. If you initially consent to our collection of location information, you may be able to subsequently stop the collection of this information through your device operating system settings. You may also stop our collection of location information by following the standard uninstall process to remove our mobile applications from your device.
10. Personal Data Officer
As of May 1st, 2018, Sebastien Juvin, CEO of NITBY sarl is appointed as Personal Data Officer.