(A) This statement
Summary - This statement
This statement explains how we process personal data. This statement may change or be updated from time to time, so please check it regularly for updates.
This Notice is issued by each of the data controller entities listed in section (Q) below (collectively, "Nobia", "we", "us" and "our") and is addressed to individuals outside of our organisation with whom we interact, including customers, visitors to our websites, users of our apps, other users of our products or services and visitors to our premises (collectively, "you"). Defined terms used in this statement are explained in section (R) below.
This Statement may be modified or updated from time to time to reflect changes in our personal data processing practices or changes in applicable law. We encourage you to read this Statement carefully and to check this page periodically for any changes that we may make in accordance with the terms of this Statement.
(B) Collection of personal data
Summary - Collection of personal data
We collect or obtain personal data: when this information is provided to us (e.g. if you contact us), in the course of our relationship with you (e.g. if you make a purchase), when you publish personal data (for example, if you publish a post about us on social media), when you download, install or use any of our apps, when you visit our websites, when you register to use any of our websites, apps, products or services, or when you interact with any third-party content or advertising on a website or app. We may also receive personal data about you from third parties (e.g. law enforcement authorities).
Collection of personal data: We collect or obtain personal data about you from the following sources:
- Information provided to us: We collect personal data when this information is provided to us (e.g. if you contact us by email or phone, or in any other way, or when you provide us with your business card or when you submit a job application).
- Relationship information: We collect or obtain personal data in the course of our normal business relationship with you (e.g. we provide a service to you, or to your employer).
- Information that you make public: We collect or obtain personal data that you manifestly choose to make public, including via social media (e.g. we may collect information from your social media profile(s) if you make a public post about us).
- App information: We collect or obtain personal data when you download or use any of our apps.
- Website information: We collect or obtain personal data when you visit any of our websites or use any of its features or resources available on or through a website.
- Registration details: We collect or obtain personal data when you use, or register to use, any of our websites, apps, products or services.
- Content and advertising information: If you interact with any third-party content or advertising on a website or app (including third-party plugins and cookies), we receive personal data from the relevant third-party provider of that content or advertising.
- Third party information: We collect or obtain personal data from third parties who provide it to us (e.g. credit reference agencies, law enforcement agencies, etc.)
(C) Creation of personal data
Summary - Creation of personal data
We create personal data about you (e.g. records of your interactions with us).
We also create personal data about you in certain circumstances, such as records of your interactions with us and details of your purchase history.
(D) Categories of personal data we process
Summary - Categories of personal data we process
We process: your personal data (e.g. your name), demographic data (e.g. your age), your contact details (e.g. your address), records of your consents, purchase data, payment data (e.g. your billing address), information about our websites and apps (e.g. the type of device you use), details of your employer (if applicable), information about your interactions with our content or advertising, and any views or opinions you provide to us.
We process the following categories of personal data about you:
- Personal data: first name(s), preferred name and photograph.
- Demographic information: gender, nationality, salutation, title, and language preferences.
- Contact details: correspondence address, delivery address, telephone number, email address, personal assistant details where applicable, instant messaging app details, instant messaging details, and social media details.
- Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g. the subject matter of the consent).
- Purchase information: records of purchases and prices, recipient's name, address, phone number and email address, and installation instructions.
- Payment information: invoice records, payment records, billing address, payment method, payment amount, payment date, and cheque records.
- Information relating to our websites and apps: device type, operating system, browser type, browser settings, IP address, language settings, dates and times of connection to a website, app usage statistics, app settings, dates and times of connection to an app, location information, and other technical communication information (some of which may constitute personal data), username, password, login security information, usage information, aggregate statistical information. login, usage information, aggregate statistical information.
- Employer information: when you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent applicable.
- Content and advertising information: records of your interactions with our online advertising and content, records of advertising and content that appears on pages or app screens displayed to you, and any interaction you may have had with such content or advertising (including, when hovered over, mouse clicks, any forms you complete in whole or in part) and any interactions with touch screens.
- Views and opinions: any feedback you provide.
(E) Sensitive personal data
Summary - Sensitive Personal Data
We do not seek to collect or otherwise process sensitive personal data. If we need to process sensitive personal data for a legitimate purpose, we will do so in accordance with applicable law.
We do not seek to collect or otherwise process your sensitive personal data in the course of our normal business operations. When it becomes necessary to process your sensitive personal data for any reason, we rely on one of the following legal bases:
- Compliance with applicable legislation: We may process your sensitive personal data where the processing is required or authorised by applicable law (e.g. to comply with our diversity reporting obligations),
- Detection and prevention of crime: We may process your sensitive personal data where the processing is necessary for the detection or prevention of crime (e.g. fraud prevention),
- Establishing, exercising or defending legal rights: We may process your sensitive personal data where the processing is necessary for the establishment, exercise or defence of legal rights; or
- Consent: We may process your sensitive personal data where, in accordance with applicable law, we have obtained your prior explicit consent prior to processing your sensitive personal data (this legal basis is only used for processing that is entirely voluntary - it is not used for processing that is necessary or obligatory in any way).
If you provide us with sensitive personal data, you must ensure that it is lawful for you to disclose such data to us and you must ensure that a valid legal basis applies to the processing of that sensitive personal data.
(F) Purpose of processing and legal basis for processing
Summary - Purpose of processing and legal basis for processing
We process personal data for the following purposes: providing our websites, apps, products and services to you, running our business, communicating with you, managing our IT systems, health and safety, managing finances, conducting surveys, ensuring the security of our premises and systems, conducting investigations where necessary, complying with applicable laws, improving our websites, apps, products and services, fraud prevention, and recruitment and job applications.
The purposes for which we process personal data, subject to applicable law, and the legal bases on which we carry out such processing are as follows:
(G) Disclosure of personal data to third parties
Summary - Disclosure of personal data to third parties
We disclose personal data to: legal and regulatory authorities, our external advisors, our data processors, any party as necessary for legal proceedings, any party as necessary to investigate, detect or prevent criminal offences, any purchaser of our business, and any third-party providers of advertising, plugins or content used on our websites or our apps.
We disclose personal data to other entities within the Nobia Group for legitimate business purposes and the operation of our websites, apps, products and provision of services to you, in accordance with applicable law. In addition, we disclose your personal data to:
- you and, where applicable, your appointed representatives,
- judicial and supervisory authorities, upon request, or for the purpose of reporting any actual or suspected breach of applicable law or regulation,
- accountants, auditors, lawyers and other external professional advisors to Nobia, subject to binding contractual confidentiality obligations,
- third-party processors (such as payment service providers, shipping companies, etc.), located anywhere in the world, subject to the requirements set out below in this section (G),
- any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights,
- any relevant party for the prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties,
- any relevant third party acquirer(s) if we sell or transfer all or any relevant part of our business or assets (including in the event of reorganisation, dissolution or liquidation); and
If we engage a third-party data processor to process your personal data, the data processor is subject to binding contractual obligations to: (i) process the personal data only in accordance with our prior written instructions; and (ii) take measures to protect the confidentiality and security of the personal data, together with any additional requirements under applicable law.
(H) International transfer of personal data
Summary - International transfer of personal data
We transfer personal data to recipients in other countries. When we transfer personal data from the EEA to a non-EEA recipient that does not provide an adequate level of data protection, we do so through standard contractual clauses with our partners.
Due to the international nature of our business, we transfer personal data within the Nobia group of companies, and to third parties as set out in section (G) above, in connection with the purposes set out in this Statement. For this reason, we transfer personal data to other countries that may have different laws and data protection compliance requirements than those applicable in the country where you are located.
When we transfer personal data from the EEA to a non-EEA recipient that does not provide an adequate level of data protection, we do so through Standard Contractual Clauses with our partners. You have the right to request a copy of our Standard Contractual Clauses using the contact details set out in section (Q) below.
Please note that when you transfer any personal data directly to a Nobia entity registered outside the EEA, we are not responsible for that transfer of your personal data. Nevertheless, we will process your personal data from the time we receive that information in accordance with the provisions of this notice.
(I) Data security
Summary - Data security
We implement appropriate technical and organisational security measures to protect your personal data. Please ensure that any personal data you send to us is sent securely.
We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access and other unlawful or unauthorised forms of processing, in accordance with applicable law.
Because the Internet is an open system, the transmission of information via the Internet is not completely secure. Whilst we will implement all reasonable measures to protect your personal data, we cannot guarantee the security of your data transmitted to us via the internet. Any such transmission is at your own risk and you are responsible for ensuring that any personal data you transmit to us is transmitted securely.
(J) Accuracy of information
Summary - Accuracy of information
We take all reasonable steps to ensure that your personal data is kept accurate and up to date and deleted or rectified if we become aware of any inaccuracies.
We will take all reasonable steps to ensure that:
• your personal data that we process is accurate and, where necessary, kept up to date; and
• any of your personal data that we process that is inaccurate (taking into account the purposes for which it is processed) is erased or rectified without undue delay.
From time to time, we may ask you to confirm the accuracy of your personal data.
(K) Data minimisation
Summary - Data minimisation
We take all reasonable steps to limit the amount of your personal data that we process to what is necessary.
We take all reasonable steps to ensure that your personal data that we process is limited to the personal data that is reasonably necessary for the purposes set out in this statement.
(L) Data storage
Summary - Data storage
We take all reasonable steps to ensure that your personal data is only kept for as long as necessary for a lawful purpose.
We take all reasonable steps to ensure that your personal data is only processed for the minimum period necessary for the purposes set out in this statement. The criteria for determining the period of time for which we retain your personal data are as follows:
(1) we only store personal data in a form that enables identification for as long as:
(a) we maintain an ongoing relationship with you (e.g. if you are a user of our services or if you are legally included in our mailing list and have not unsubscribed); or
(b) your personal data is necessary for the lawful purposes set out in this statement for which we have a valid legal basis (for example, if your personal data is included in a contract between us and your employer and we have a legitimate interest in processing that data for the purposes of operating our business and fulfilling our obligations under that contract, or if we have a legal obligation to retain your personal data),
(2) the duration of:
(a) any applicable limitation period under applicable law (i.e. any period during which any person could bring a legal claim against us in relation to your personal data or under which your personal data is relevant); and
(b) an additional period of two (2) months after the end of such applicable limitation period (so that if an individual brings a claim at the end of the limitation period, we still have a reasonable period of time to identify any personal data relevant to that claim),
(3) In addition, if any relevant legal claims are brought, we will continue to process personal data for such additional periods as are necessary in connection with that claim.
During the periods specified in clauses (2)(a) and (2)(b) above, we will limit our processing of your personal data to storing and maintaining the security of that data, except to the extent that that data needs to be reviewed in connection with any legal claim or obligation under applicable law.
When the periods set out in points (1), (2) and (3) above, each to the extent applicable, have ended, we will either:
- permanently erase or destroy the relevant personal data; or
- anonymise the relevant personal data.
(M) Your legal rights
Summary - Your legal rights
Under applicable law, you may have a number of rights, including: the right not to provide your personal data to us, the right of access to your personal data, the right to request rectification of inaccuracies, the right to request erasure or restriction of processing of your personal data, the right to object to the processing of your personal data, the right to have your personal data transferred to another controller, the right to withdraw consent, and the right to lodge complaints with data protection authorities. In some cases, we may require proof of your identity before we can fulfil these rights.
Under applicable law, you may have the following rights regarding the processing of your relevant personal data:
- the right not to provide your personal data to us (please note, however, that we will not be able to provide the full functionality of our websites, apps, products or services to you if you do not provide your personal data to us - for example, we may not be able to process your requests without the necessary information),
- the right to request access to, or copies of, your relevant personal data, together with information regarding the nature, processing and disclosure of that relevant personal data,
- the right to request the rectification of any inaccuracies in your relevant personal data,
- the right to request, based on legitimate grounds:
- erasure of your relevant personal data; or
- restriction of processing of your relevant personal data,
- the right to have certain relevant personal data transmitted to another controller in a structured, commonly used and machine-readable format, where applicable,
- where we process your relevant personal data on the basis of your consent, the right to withdraw that consent (please note that such withdrawal does not affect the lawfulness of any processing carried out before the date on which we receive notification of such withdrawal and does not prevent the processing of your personal data on the basis of any other available legal basis); and
- the right to lodge complaints regarding the processing of your relevant personal data with a data protection authority (in particular, the data protection authority of the EU Member State where you live or where you work or where the alleged infringement took place, in each case, if applicable).
Subject to applicable law, you may also have the following additional rights regarding the processing of your relevant personal data:
- the right to object, on grounds relating to your particular situation, to the processing of your relevant personal data by us or on our behalf; and
- the right to object to the processing of your relevant personal data by us or on our behalf for direct marketing purposes.
This does not affect your statutory rights.
To exercise any of these rights or to ask a question about these rights or any other provision of this Notice, or about our processing of your personal data, please use the contact details set out in section (Q) below. Please note that:
- in some cases it will be necessary to provide proof of your identity before we can fulfil these rights; and
- when your request requires the establishment of additional facts (e.g. an assessment of whether any processing does not comply with applicable law), we will investigate your request as soon as possible before deciding what action to take.
(N) Cookies and similar technologies
Summary - Cookies and similar technologies
(P) Direct marketing
Summary - Direct Marketing
We process personal data in order to contact you with information regarding websites, apps, products or services that may be of interest to you. You can unsubscribe for free at any time.
We process personal data for the purpose of contacting you via email, telephone, addressed promotional mailings or other forms of communication to provide you with information regarding websites, apps, products or services that may be of interest to you. If we provide websites, apps, products or services to you, we may send you information regarding our websites, apps, products or services, upcoming promotions and other information that may be of interest to you using the contact details that you have provided to us, always subject to your prior opt-in consent, to the extent required by applicable law.
You can unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. Once you have unsubscribed, we will not send you any further promotional emails, but in some cases we will continue to contact you as necessary for any websites, apps, products or services you have requested.
(Q) Details of data controllers
Summary - Details of data controllers
There are several Nobia entities that act as data controllers for the purposes of this Privacy Statement.
For the purposes of this statement, the relevant data controllers:
Lars Bo Andersen, email@example.com
- "App" means any application made available by us (including if we make such applications available through third party stores or marketplaces, or by any other means).
- "Jurisdiction with adequate data protection" means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for personal data.
- "Cookie" means a small file that is placed on your device when you visit a website (including our websites). In this statement, a reference to a "cookie" includes analogue technologies such as web beacons and clear GIFs.
- "Data Controller" means the entity that decides how and why personal data is processed. In many jurisdictions, the data controller has primary responsibility for compliance with applicable data protection laws.
- "Data Protection Authority" means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
- "EEA" means the European Economic Area.
- "Personal data" means information relating to any individual or from which any individual can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
- "Treat" or "treated" means anything that is done with personal data, whether or not by automated means, such as collection, recording, organisation, organisation, arrangement, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- "Data processor" means any person or entity that processes personal data on behalf of the controller (other than the controller's employees).
- "Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
- "Relevant personal data" means personal data for which we are the data controller.
- "Sensitive personal data" means personal data revealing race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sex life, any actual or alleged offences or criminal sanctions, national identification number, or any other information considered sensitive under applicable law.
- "Standard contractual clauses" means standard transfer provisions adopted by the European Commission or adopted by a data protection authority and approved by the European Commission.
- "Homepage" means any website operated or maintained by us or on our behalf.