Effective: 20 May 2018
Nome Ltd understands that your privacy is important to you and that you care about how your information is used and shared online. We respect and value the privacy of everyone who use Our Services and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and interpretation:
In this Policy the following terms shall have the following meanings:
“Account” means an account required to access and/or use certain areas and features of Our Services;
“Data” means collectively all the information that you submit to Nome. This definition shall, where applicable, incorporate the definitions provided in the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR)
“Cookie” means a small text file placed on your computer by Nome when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out below;
“Nome/We/Us/Our” means Nome Ltd, a company registered in England and Wales under Company Registration Number 10282209, of registered office 20-22 Wenlock Road, London, N1 7GU, England;
“Services” means the Nome mobile device application (the “App”), Nome website getnomeapp.com (the “Website”), and the Nome browser extension (the “Browser Extension”). The App, Website and Browser Extension are collectively referred to as the “Services.”
“UK and EU Cookie Law” means the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011;
“User” means any third party that accesses the Services and is not employed by Nome and acting in the course of their employment;
2. Information About Us
Our Services, is owned and operated by Nome Ltd, a limited company registered in England and Wales under Company Registration Number 10282209, of registered office 20-22 Wenlock Road, London, N1 7GU, England;
3. Scope – What Does This Policy Cover?
This Policy applies only to the actions of Nome and Users with respect to these Services. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites. We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.
4. What Data Do We Collect?
b. Email address;
d. Preferences and interests;
e. Mobile device information such as device type, model, manufacturer, operating system version (automatically collected);
f. Web browser type and version (automatically collected);
g. Location Information. When you use our App, we may collect and store information about your location by converting your IP address into a rough geolocation or by accessing your mobile device’s GPS coordinates or coarse location if you enable location services on your device. We may use location information to improve and personalise our Services for you.
5. How Do We Use Your Data?
a. All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation(EU) 2016/679) (GDPR). For more details on security see section 6, below.
b. We use your data to provide the best possible services to you. This includes:
i. Providing and managing your Account;
ii. Providing and managing your access to Our Services;
iii. Personalising and tailoring your experience on Our Services;
iv. Responding to communications from you;
v. Provide or offer software updates and product announcements;
vi. Supplying you with communications e.g. newsletters, alerts etc. that you have subscribed to (you may unsubscribe or opt-out at any time by follow the instructions provided in any of the communications to unsubscribe or turn off push notifications for the App in your device’s settings);
vii. Analysing your use of Our Services and gathering feedback to enable Us to continually improve Our Services and your user experience.
c. In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the services We can provide you without your consent for Us to be able to use such data.
d. With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our Services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
e. Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
i. you have given consent to the processing of your personal data for one or more specific purposes;
ii. processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
iii. processing is necessary for compliance with a legal obligation to which we are subject;
iv. processing is necessary to protect the vital interests of you or of another natural person;
v. processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
vi. processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
6. How and Where Do We Store Your Data?
a. We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:
i. Any personal Data you submit will be retained by Nome for six (6) months after closure of your account with us.
b. Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Services and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
c. Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Services.
d. Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
a. We will display your personal data in your profile page and elsewhere through the Services according to the preferences you set in your account. Any information you choose to provide should reflect how much you want all other Nome users to know about you. We will share your personal data with third-party sites or platforms, such as social networking sites, if you have expressly requested that we do so.
b. We may contract with third parties to offer you certain services or promotions. These may include delivery of goods, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
c. We may compile statistics about the use of Our Services including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties for industry research and analysis, demographic profiling and other similar purposes. Data will only be shared and used within the bounds of the law.
d. In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
b. In the event that any of your data is to be transferred in such a manner, you will be contacted in advance and informed of the changes. When contacted you will be given the choice to have your data deleted or withheld from the new owner or controller.
9. How Can You Control Your Data
a. When you submit information via Our Services, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails).
b. All users may review, update, correct or delete their personal data provided in their registration or account profile by contacting us at firstname.lastname@example.org or by changing your user preferences within the App. If you completely delete all such information, then your account may become deactivated.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
b. You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 16, and We will delete Your data from Our systems. However, you acknowledge this means cancelling your account from Our Services and you will no longer have access to Our Services.
11. How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at email@example.com.
12. What Data Do We Automatically Collect, Use and What For?
a. Log Data. We use Mixpanel and Fabric to automatically record information about how people (both account holders and non-account holders) use Our Services. This information, referred to as “Log Data,” may include, but is not limited to, your computer’s Internet Protocol address, browser type, operating system, the web page you were visiting before you accessing our Services, the pages or features of our Services that you browsed and the time spent on those pages or features, search terms, the links on our Services that you clicked and other statistics. We use Log Data to administer the Services and to analyse (or have third parties analyse) the Log Data to improve, customise and enhance our Services by expanding their features and functionality and tailoring them to our users’ needs and preferences.
13. Summary of Your Rights under GDPR
Under the GDPR, you have:
a. the right to request access to, deletion of or correction of, your personal data held by Us;
b. the right to complain to a supervisory authority;
c. be informed of what data processing is taking place;
d. the right to restrict processing;
e. the right to data portability;
f. object to the processing of your personal data;
g. rights with respect to automated decision-making and profiling (see section 14 below).
14. Automated Decision-Making and Profiling
a. In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
b. The right described in section 14.a does not apply in the following circumstances:
i. The decision is necessary for the entry into, or performance of, a contract between the You and Us;
ii. The decision is authorised by law; or
iii. You have given you explicit consent.
c. Where We use your personal data for profiling purposes, the following shall apply:
i. Clear information explaining the profiling will be provided, including its significance and the likely consequences;
ii. Appropriate mathematical or statistical procedures will be used;
iii. Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
iv. All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
d. We currently profile your personal data for the following purposes:
i. Provide recommendations of users to connect with in Our Services to better improve your experience;
ii. Provide recommendations of places to visit to better improve your experience with Our Services.
15. Our Policy Toward Children
The Services are not directed to children under the age of 18. We do not knowingly collect personally identifiable information from children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with PII without their consent, he or she should contact us at firstname.lastname@example.org. If we become aware that a child under 13 has provided us with personal data, we will delete such information from our files.
16. Contacting Us