NABLA GENERAL PRIVACY AND COOKIES POLICY

Date of policy: December 20th 2022

PART A NABLA GENERAL PRIVACY POLICY

  1. Purpose of this privacy policy.

Nabla respects your privacy and is committed to protecting your personal data and to respecting data privacy legislation, and in particular the (EU) 2016/679 General Data Protection Regulation of the European Parliament and of the Council of 27 April 2016 on the protection of persons with regard to the processing of personal data. This privacy policy will inform you as to how we look after your personal data when you subscribe to the products or services we offer (the “Solution”) and tell you about your privacy rights and how the law protects you.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below. This policy (together with our terms and conditions) applies to your use of the Solution.

This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

  1. Data controller

Nabla Technologies is a company registered in France. Our company registration number is 838 878 155 and our registered office is at 22 rue Chapon 75003 Paris - FRANCE.

Nabla Technologies is the data controller and is referred to in this privacy policy as “Nabla”, “we”, “us” or “ours”.

We are committed to protecting your personal data and respecting your privacy.

If you have any questions about this privacy policy, please contact us using the details set out below.

  1. Contact details

Our contact details are:

  1. Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email and/or when you next log into the Website. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the Solution.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

  1. Third party links

Our Website may, from time to time, contain links to and from the websites of our partner networks, and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

  1. The data we collect about you

Depending on the level of your engagement with our website or the Solution, we may collect, use, store and transfer different kinds of personal data about you as follows:

Identity Data:

Includes first name, last name, username or similar identifier, position.

This is information you provide to us when you subscribe to our Solution.

Contact Data:

Includes email address.

It also includes some contact data within your organisation when you are about to enter or have entered a Contract with us.

We require this information to manage the Contract we have entered or we are about to enter with you and to enable you to communicate with us.

We also collect these data for our regulatory and legal compliance obligations.

Technical Data:

In relation to the use of the Solution, this includes: internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Solution.

Please see our cookies policy at Part B below for more details about why and how we use cookies and other tracking technologies.

Usage Data:

Includes details of your use of the Solution including but not limited to, traffic data and other communication data, and the resources that you access, the number of active users of our Solution.

We collect this data to monitor and measure the performance of the Solution and to manage the Contract.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Solution feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

  1. How is your personal data collected?

Most of the personal data that we process about you will be provided by you, for example when entering a Contract for the use of our Solution. The provision of such information is voluntary, but if you cannot provide it to us, you may not be able to work with Nabla. Each time you use the Solution we will automatically collect personal data including Technical Data and Usage Data. We collect this data using cookies and other similar technologies. Please see our cookie policy at Part B below for further details.

  1. Cookies

We use cookies and/or other tracking technologies to distinguish you from other users of the Solution and to remember your preferences. This helps us to provide you with a good experience when you use the Solution and also allows us to improve the Solution. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy at Part B below.

  1. How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

The table below explains what we use (process) your personal information for (other than the special category of data) and our reasons for doing so.

Purpose/activity

Type of data

Lawful basis for processing

To manage our relationship with you including responding to your queries and requests, notifying you of changes to the Website and/or to the Solution and/or our Terms of Service or Terms of Use of the Solution or this privacy policy

Identity

Contact

Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)

Necessary to perform a contract

To administer and protect our business and the Solution, including troubleshooting, data analysis and system testing

Identity (optional)

Contact

Technical

Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)

To ensure that you are able to meet your regulatory obligations

Identity (optional)

Contact

Performance of a contract with you

To comply with a legal or regulatory obligation or expectations

  1. Disclosures of your personal data

The above purposes and activities may require us to pass on some of our personal data to the following third parties:

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you and for no other reasons.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

  1. Data security

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Solution, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

Your data are usually not processed or transferred outside the European Union. However, in the event that personal information is transferred outside the European Union, NABLA will ensure that the third country concerned has a level of protection deemed adequate by the European Commission with respect to European regulation (RGPD). When this is not the case, NABLA will ensure that the transfer is carried out in accordance with the Standard Contractual Clauses (SCC) adopted by the European Commission or the supervisory authorities, including the CNIL in France, in order to guarantee the protection of this information.

We do transfer certain Aggregated Data to the USA (however for the avoidance of doubt, such does not contain any personal data) to help us improve our services to you and other users of the Solution.

  1. Data retention

We retain your personal data for as long as we need it for the purposes we have collected it for, such as contracting with you for your use of our Solution. We may retain your personal data for a longer period if you make a complaint under this privacy policy or our terms and conditions, or if we have a reasonable belief that litigation may arise in relation to our relationship with you. We may also be required to retain certain personal data from you to comply with our legal and regulatory requirements.

In some circumstances you can ask us to delete your data: see your legal rights section below for further information.

In some circumstances, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data.

If you would like to exercise any of those rights, please contact us (see contact details in paragraph 3 above) and:

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. How to complain

If you are unhappy with the way in which we have handled your personal data please get in touch with us by sending an email to dpo@nabla.com.

You are also entitled to make a complaint to the Commission Nationale de l’Informatique et des Libertés (“CNIL”) (https://www.cnil.fr/) – however we would appreciate the chance to deal with your concerns before you approach the CNIL so please contact us in the first instance.

  1. Changes to this privacy policy

We keep this privacy policy under regular review and may update it from time to time without notice to you, so please check it regularly. We will however aim to bring any significant changes to your attention.


PART B - NABLA COOKIES POLICY

Date of policy: 20th December 2022

This cookies policy explains how Nabla uses cookies and other tracking technologies on the Solution. This cookies policy is to be read alongside our privacy policy above which explains how we use personal information.

  1. What are web cookies?

Web cookies are small files that are placed on your computer or mobile device by a website when you visit it. They contain details of your browsing history on that website and distinguish you from other users. Cookies send data back to the originating website on each subsequent visit or allow another website or app to recognise the cookie. Cookies are useful because they allow a website or app to recognise a user’s device and, for instance, remember your preferences and generally improve your online user experience. Like most websites and apps, we use cookies.

Although this cookies policy refers to the general term “cookie”, which is the main method used by the Solution to store information, the browser’s local storage space is also used for the same purpose and we may use other tracking technologies through the Solution. As a result, the information included in this cookie policy is likewise applicable to all such tracking technologies that we use.

  1. Why do we use cookies?
  1. What cookies do we use?

The table below provides more information about the cookies and other tracking technologies we use and why.

Name of cookie

Owner

Purpose of the cookie

Duration

Netlify Analytics

Netlify

  • Measure performance of the Website (number of single users, number of pages seen…)

30 days

Mp_*

Mixpanel

  • Analyze Solution usage (which features are being used and how)

1 year

Plausible Analytics

Plausible

  • Analyze Solution usage

24 hours for IP address, without limitation for analytics

  1. Cookie acceptance

By using the Solution you have consented to our use of cookies as updated from time to time. In particular, you consent to cookies being stored on your computer and/or mobile device (unless rejected or disabled by your browser).

You can accept or refuse cookies through your internet browser or through the Solution. The option to do this is usually found in the options, settings or preferences menu of your browser or mobile device. If you access the Solution through different devices, computer profile or browser you will have to tell us your cookies preferences again.

  1. Updating our cookies policy

We may update our use of cookies from time to time and consequently, we may update this policy. We, therefore, recommend that you check this cookies policy regularly.