privacy@nanogon.co
This Privacy Policy describes the ways in which Nanogon Limited, on behalf of itself and affiliated companies (“Nanogon”, “we”, “our”, or “us”), may collect, process, use, and disclose information about you through websites, social media properties, applications, meetings, phone calls, contractual and precontractual business activities, your visit to our office, other online services operated by us, and Nanogon-hosted or co-branded events, trainings, and contests (collectively, the “Services”), and the choices you can make about the way your information is collected and processed through the Services. By using any Service, you consent to the processing of your information as set forth in this Privacy Policy, now and as may be amended by us from time to time.
We enter into contracts with our customers (“Customers”) for Nanogon and partner products or services. The processing of personal information in the context of Customer applications (“Customer Application”) that are built on or incorporate Nanogon and its partner software or cloud services is controlled by the Customer and is subject to the Customer’s privacy policy and practices, which may differ from this policy.
We and our service providers may collect and receive personal information and other information from a variety of sources that generally fall into the following three categories:
Direct Interactions: Data from your use of and interaction with us through any Service, social media channel, and/or other activity such as account creation, Customer support requests, interactions related to a pending or signed contract or testing, submissions of registrations and posting to forums, or sales inquiries and transactions. Publicly Available Data or Data from Third Parties: Data from automated interactions on non- Publicly Available Data or Data from Third Parties: Data from automated interactions on non-Nanogon websites, or any other data you may have made publicly available, such as social media posts, or data provided by third-party sources, such as marketing lists, alliance or partner referrals, or data aggregators.
1. Direct Interactions
You, or the organization you work for, may submit data that includes your name, contact information such as a physical address, email address, phone number, username, password, employer and job title, activity logs, and registration information to us when using the Services. We also collect and receive information when you:
The information that you provide us may include one or more of the following:
When you use a Service, we will collect and store information about your use of these Services, including contracts you negotiate and sign, RFPs and questionnaires you submit, Nanogon events you attend, Nanogon communities in which you participate, training and courses you register for, training and courses you complete, and certifications that you receive. We only collect sensitive personal information when you voluntarily provide us with this information or if you consent. Nanogon will not use sensitive personal information unless you consent to use it for our business purposes, including carrying out and supporting human resources functions and activities. The definition of “sensitive personal information” may vary by law, and generally includes personal information regarding a person’s race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, disabilities, biometrics, precise geolocation, sexual orientation, or criminal record.
2. Automated Interactions
Automated Interactions through our Services and the search terms you enter on the Services allow us to recognize you and personalize your experience if you return to a Service, to improve the Services and the products and services we provide, and to provide you with advertisements targeted to your interests (commonly referred to as “Targeted Advertisements”). We and our service providers may collect and store this information using “cookies,” which are small text files that many websites save on your computer when you visit and access when you return, or similar technologies. For more information about the use of cookies on the Services, please review your Cookie Preferences, available by clicking on the Cookie Preferences link on www.nanogon.co.
3. Publicly Available Data or Data from Third Parties
We may collect or receive business-related information about you from public sources and various third parties, including providers of marketing lists. Information from public sources may include business contact data obtained from search information providers (e.g. Google) or social media (e.g. LinkedIn). We may also occasionally purchase third-party marketing lists of business contact data in order to send direct marketing communications.
Personal data transferred to us by a Customer (“Customer Data”) will be processed in accordance with the Customer’s instructions as outlined in our contract with that Customer (“Customer Agreement”) and as required by applicable law. Customers may use our cloud services to grant and remove access to a Customer Application; assign roles and configure settings, access, modify, export, share and remove Customer Data; and otherwise, apply its policies to the Customer Application. If your personal information is being processed as Customer Data and you wish to exercise any rights you may have to access, correct, update, port, or delete such personal information, please inquire directly with the Customer. We may process and use your personal data and other information that we collect or receive for a number of purposes as necessary to fulfil contractual obligations and other lawful bases, including our legitimate interest in engaging in commerce; offering products and services; performing due diligence on Customers, prospects and business partners; preventing fraud; ensuring information and network security; conducting direct marketing; and complying with industry practices, including:
We may use your personal information to interact with you on third-party social networks. Our interactions with you on a third-party social network are subject to that network’s privacy policies and terms of use. We also provide social computing tools on some of our websites to enable online sharing and collaboration among members who have registered to use them. These include forums, blogs, and other social media platforms. Information will be subject to and protected in accordance with this Privacy Policy, except for the information that is automatically made available to other participants as part of your profile or information you post on blogs and forums. We may combine or aggregate any of the information we collect or receive through the Services or elsewhere (e.g. through telephone, email, social media interactions, personal contact with us or our employees, product registration, call centers, or public events such as trade shows or live events) for the purposes listed above. When you make a purchase using a credit card on the Services, your credit card information is transmitted directly to our third-party payment processor.
We do not store your credit card information, and the third-party payment processor does not share your credit card information with us. If you submit an application for Nanogon alliance programs, we may use your application and all information and materials included in your application for conducting due diligence, evaluating potential business transactions, and tracking applicants, founders, investors, and companies. To the extent that our processing of your personal data is subject to the General Data Protection Regulation (GDPR) or other privacy laws, we may rely on the legal bases described above to process your personal data. We may also process your personal data for direct marketing purposes and for administration of contractual and pre-contractual relationships. You have a right to object to our use of your personal data for this purpose at any time.If you have questions about our legal basis for processing your data, please contact us at privacy@nanogon.co
We use personal information from consumers, customers, suppliers and others (a) to respond to their requests, (b) to evaluate the quality of our products and services, (c) to communicate with them about our products, services and related issues, (d) to notify them of and administer offers, contests and other promotions, and (e) for internal administrative and analytical purposes, and (f) to comply with our legal obligations, policies and procedures. We also collect or have access to personal data from our employees, including the following types: contact information, for example, name and personal email address and phone number; date of birth; gender; government-issued identification; information, visa or passport information; educational, employment or military service history; work eligibility and/or authorization; job performance and compensation information; bank account or other financial account information; and other information that an employee may provide.
With regards to personal information from our employees, we use such personal information to carry out and support human resources functions and activities, which may include: (i) recruiting and hiring job applicants; (ii) managing employee communications and relations; (iii) providing compensation and benefits; (iv) administering payroll; (v) processing corporate expenses and reimbursements; (vi) managing employee participation in human resources plans and programs; (vii) carrying out obligations under employment agreements; (viii) managing employee performance; (ix) conducting training and talent development; (x) facilitating employee relocations and international assignments; (xi) managing employee headcount and office allocation; (xii) managing the employee termination process; (xiii) managing information technology and communications systems, such as the corporate email system and company directory; (xiv) conducting ethics and disciplinary investigations; (xv) administering employee grievances and claims; (xvi) managing audit and compliance matters; (xvii) complying with applicable legal obligations, including government reporting and specific local law requirements; and (xviii) other general human resources purposes. We also may obtain and process personal information about our employees’ emergency contacts and other individuals (such as spouse, family members, dependents and beneficiaries), to the extent employees provide such information to us. We process this information to comply with its legal obligations and for benefits administration and other internal administrative purposes.
We may disclose the information we collect and receive about you to:
We may enable you to post information to certain parts of the Services, such as the Online Communities. Information you disclose through any Online Communities may be publicly available. We urge you to exercise discretion and caution when deciding to disclose personal information, or any other information, through any Online Community. By using any Service, you agree to adhere to all applicable copyright laws.
A Service also may contain links to third-party websites and applications for your convenience and information. We do not control those third-party websites and applications or their privacy practices, which may differ from our own. You acknowledge and agree that we are not responsible for the collection and use of your information by third party websites and applications that are not under our control, and such information is not governed by this Privacy Policy.
We strive to maintain reasonable and appropriate administrative, technical, and physical safeguards designed to safeguard the information collected by the Services from loss, misuse, and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the information. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks
Information collected through the Services may be processed using resources and servers located in various countries around the world, including but not limited to the United States, Canada, Mexico, Brazil, United Kingdom, Germany, France, Spain, Poland, the Netherlands, Switzerland, Sweden, United Arab Emirates, India, Japan, Singapore, the Philippines, Australia and the various African States. Therefore, your personal information may be transferred, processed, and stored outside the country where your information was collected by using or attending a Service. By using a Service, you consent to such transfer to, and processing and storage in, the United States and other countries.
We, our affiliates, and/or third parties may transfer your information outside the country in which you are located, including the United States. Such countries may not offer the same level of protection as in other parts of the world regarding data protection and privacy regulations. By providing us with your information and confirming your consent, you agree to such transfer and/or processing. We will take all steps reasonably necessary to ensure that your data is transferred and processed securely in accordance with the terms of this notice.
By providing us with your information and confirming your consent, you agree to such transfer and/or processing. When we transfer your data outside of EEA, the UK or Switzerland we will implement appropriate safeguards to protect your data in a manner which provides a degree of protection similar to the EU (or UK or Switzerland as applicable). To achieve this (i) we put in place intercompany agreements incorporating Standard Contractual Clauses with our affiliates outside of the EEA, (ii) we rely on Standard Contractual Clauses or other lawful transfer mechanisms approved by the European Commission with our third-party providers outside of the EEA (or UK or Switzerland as applicable), (iii) we also adopted certain supplementary measures such as technical measures, including, where applicable, government access procedures, data minimization, encryption, enhanced access controls, or sharing with protected recipients and updated policies for reviews of data requests. We remain accountable for processing of the personal data in case of onward transfer.
Nanogon complies with the EU-U.S., UK-U.S. and Swiss-U.S. Data Privacy Frameworks as set forth by the U.S. Department of Commerce with respect to personal information that is transferred from the European Economic Area, the United Kingdom and Switzerland to the United States.
Data protection laws in certain jurisdictions differentiate between the “controller” and “processor” of personal data. In general, our Customers are the controller of Customer Data and we are the processor of Customer Data. For other personal data, we may be the controller of such personal data. Different Nanogon entities provide the Services in different parts of the world. For Customer Data, the processor is the entity with which the Customer has contracted to provide the Customer Application. Our contact information for Customers is contained in the relevant Customer Agreement. For other personal data, Nanogon Limited is the controller, if applicable, and you may contact us as privacy@nanogon.co
We will retain Customer Data in accordance with the applicable terms in the Customer Agreement and as required by applicable law. The Customer may be able to customize its retention settings and apply those customized settings depending on the Nanogon product. We may retain other information pertaining to you for as long as necessary for the purpose described in this Privacy Policy. This may include keeping your personal data after you have deactivated your Nanogon account for the period of time needed for us to pursue legitimate business, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.
If you reside in certain states or in certain countries, including within the European Union, you may have one or more of the following rights available to you under the data protection laws in relation to your personal data: the right to access, update, correct, receive, port, object, delete, or restrict processing of your personal data. Access – In certain jurisdictions, you have the right to request that we disclose certain information to you about our collection and use of your personal information. To require access to your personal data that we have collected, used, or disclosed, please contact privacy@nanogon.co. Update or Correct – To update or correct your personal data, please contact proivacy@nanogon.co.
Port – To request a copy of your personal data that we have collected about you in a commonly used and machine-readable format, please contact privacy@nanogon.co. Object – To object to processing of your personal data, please contact privacy@nanogon.co. Opt-Out, Delete or Restrict Processing – To opt-out, delete or change how we process your personal data for marketing purposes, please contact privacy@nanogon.co. or the unsubscribe instructions from Nanogon marketing emails can be followed for Opt-Out. For all other processing purposes, to opt-out, delete or change how we process your personal data, please email privacy@nanogon.co. If your personal data is processed based on your consent, you may withdraw your consent any time, without affecting the lawfulness of our processing based on such consent before was withdrawn. To exercise any of the above-listed rights (with the exception of the right to lodge a complaint with a Data Protection Authority (“DPA”), which you may do directly to a DPA), please follow the instructions above or contact us at privacy@nanogon.co.
The General Data Protection Regulation (EU) 2016/679 (“GDPR”) aims to protect the personal data and uphold data privacy rights of anyone in the European Union territory by requiring organizations to lawfully process and safeguard their personal data. The processing of data by Nanogon may include “Personal Information” of individuals from the European Union. Nanogon is committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. Nanogon has implemented this Privacy Policy that explains our measures to comply with GDPR. Nanogon has internal policies and organizational procedures for the security and protection of data and confidential information. enters into confidentiality and data protection agreements with its sub-processors that include standard contractual clauses for data transfers as applicable. For more information on the measures that Nanogon takes to comply with the GDPR, please refer to the applicable sections of this Privacy Policy. To review your individual data rights under the GDPR, please refer to the section of this Privacy Policy titled “Your Rights.”
The Services are not directed to, nor do we knowingly collect information from, children under the age of 16. If you become aware that your child or any child under your care has provided us with information without your consent, please contact us through the means listed below.
f we update this Privacy Policy, we will notify you by posting a new Privacy Policy on this page and updating the revision date below. If we make any revisions that materially change the ways in which we use or disclose the information previously collected from you through a Service, we will give you the opportunity to consent to such changes before applying them to that previously collected information.
If you have any questions about this Privacy Policy or our use of your information collected through the Services, please contact privacy@nanogon.co. Our address is Nanogon Limited. Registered Office Address: 20 Wenlock Road. London N1 7GU.