Last updated: 5 May 2022
- GENERAL INFORMATION
- WHAT DATA DO WE COLLECT?
- HOW LONG DO WE STORE YOUR DATA?
- HOW DO WE DISCLOSE YOUR DATA?
- HOW DO WE PROTECT YOUR DATA?
- HOW CAN YOU MANAGE YOUR PERSONAL DATA?
1. GENERAL INFORMATION
1.3 Owner of NILG.AI (data controller). NILG.AI is owned and operated by NILG.AI, Lda having a registered address at Rua de Santa Justa 228G 2CEP, Porto, 4200-479, Portugal (“we,” “us,” and “our”).
1.4 Children. NILG.AI is not intended for use by persons under the age of 18. We do not knowingly collect personal data belonging to persons younger than 18 through NILG.AI. If you become aware that such a person has provided us with his or her personal data and you are a parent or a legal guardian of that person, please contact us immediately and we will remove the child’s personal data from our systems.
2. WHAT DATA DO WE COLLECT?
In this section, we explain in detail what personal data we collect from you, for what purposes we use it, what technical data is collected automatically when you use NILG.AI, and how we communicate with you.
2.1 Sources of personal data. We obtain your personal data from the following categories of sources:
- Directly from you. For example, if you submit your personal data when you make a purchase or contact us;
- Directly or indirectly through your activity on NILG.AI. When you use NILG.AI, we automatically collect technical information about your use of NILG.AI by means of cookies and analytics services; and
- From third parties. We may receive information about you from third parties to whom you have previously provided your personal data, if those third parties have a legal basis for disclosing your personal data to us (for example, for payment processing purposes).
- Account. When you register your user account, we collect your full name, email address, phone number, organization and your role in it, and your country. We use the said information to enable you to access and use NILG.AI, process your orders, provide you with the requested services, contact you, if necessary, and maintain our business records. The legal bases on which we rely are ‘performing a contract with you’ and ’pursuing our legitimate interests’ (i.e., operate, analyze, grow, protect, and administer NILG.AI). We will store this data until you delete your user account.
- Orders and Payments. When you place an order on NILG.AI and make a payment, we collect your personal data, such as your full name, organization, email address, VAT number, billing address, payment details (e.g., credit card number, CVV code, expiration month and year, or PayPal details). Your payment data is used to process payments, issue invoices, and maintain our accounting records. The legal bases on which we rely are ‘performing our contractual obligations’ and ‘pursuing our legitimate interests’ (i.e., to administer and protect our business). We keep a part of your payment data that is provided to us by our payment processor for the time period prescribed by law (in Dubai, accounting records must be kept for 10 years). Your credit/debit cards’ details and personal data will NOT be stored, sold, shared, rented or leased to any third parties. We will not pass your debit/credit card details to third parties.
- Enquiries. When you contact us by email, we collect your first name, last name, email address, and any information that you decide to include in your message. We use such data to respond to your enquiries and provide you with the requested information. The legal bases on which we rely are ‘pursuing our legitimate interests’ (i.e., to grow and promote NILG.AI) and ‘your consent’ (for optional personal data). We will store this data until you stop communicating with us.
- Newsletters. When you subscribe to our newsletter, we collect your first name, last name, email address, and organization. We use such data to deliver you the requested newsletter. The legal basis on which we rely is ‘your consent’. We will store this data until you unsubscribe from our newsletter.
2.4 Sensitive data. We do not collect or have access to any special categories of personal data (“sensitive data”) from you, unless you decide, at your own discretion, to provide such data to us. Sensitive data refers to your health, religious and political beliefs, racial origins, membership of a professional or trade association, or sexual orientation.
2.5 Refusal to provide personal data. If you refuse to provide us with your personal data when we ask for it, we may not be able to perform the requested operation and you may not be able to use our services, receive the requested information, or get our response. Please contact us immediately if you think that any personal data that we collect is excessive or not necessary for the intended purpose.
2.6 Collection of analytics data. When you browse NILG.AI, we collect certain technical analytics data collected from you. Such data includes the following information:
- URL addresses from which you access NILG.AI;
- Your device type;
- Your operating system;
- Your browser name and version;
- Your network;
- Approximate geolocation data; and
- Your other online behavior.
2.7 Purposes of analytics data. We use your analytics data to analyze what kind of users access and use NILG.AI, measure your engagement with NILG.AI, see which parts of NILG.AI are interesting to you, what products you buy, improve our content, develop new products and services, and investigate and prevent security issues and abuse. In most cases, such analytics data is non-personal and it does not allow us to identify you as a natural person. However, some of such data like your IP address may be considered personal data and we will make sure that we have the necessary legal basis for processing such data. When we process your analytics data that is personal data, we rely on the ‘legitimate interest’ (i.e., to analyze, improve, and protect NILG.AI) and ‘your consent’ bases.
2.8 Your feedback. If you contact us, we may keep records of any questions, complaints, recommendations, or compliments made by you and the response. Where possible, we will de-identify your personal data (i.e., we will remove all personal data that is not necessary for keeping such records).
2.9 Aggregate and de-identified data. In case your non-personal data is combined with certain elements of your personal data in a way that allows us to identify you, we will handle such aggregate data as personal data. If your personal data is aggregated or de-identified in a way that it can no longer be associated with an identified or identifiable natural person, it will not be considered personal data and we may use it for any legitimate purpose.
2.10 Newsletters. If you opt-in for our newsletter, subscribe to our newsletter, or conclude a service contract with us, we will inform you about our new services, features of NILG.AI, and special offers. You can opt-out from receiving our commercial communication at any time free of charge by clicking on the “unsubscribe” link included in our newsletters or by contacting us directly.
2.11 Transactional notices. If we have your email address and it is necessary to do so, we may send you important informational messages, such as order confirmations and updates, requests for more information, payment receipts, invoices, and other technical or administrative emails. Please note that such messages are sent on an “if-needed” basis and they do not fall within the scope of commercial communication that may require your prior consent. You cannot opt-out from service-related notices.
3. HOW LONG DO WE STORE YOUR DATA?
In this section, we explain for how long we keep your data in our systems and how we delete it.
3.3 Storage as required by law. When we are obliged by law to store your personal data for a certain period of time (e.g., for keeping accounting records), we will store your personal data for the time period stipulated by the applicable law and delete the personal data as soon as the required retention period expires.
4. HOW DO WE DISCLOSE YOUR DATA?
In this section, you can find information about third parties that may have access to your personal data.
4.1 Disclosure to data processors. We keep your personal data in strict confidentiality. However, if necessary for the intended purpose of your personal data, we will disclose your personal data to entities that provide services on our behalf (our data processors). Your personal data may be shared with entities that provide technical support services to us, such as hosting, payment processing, and email distribution services. We do not sell your personal data to third parties and do not intend to do so in the future. The disclosure of your personal data is limited to the situations when it is required for the following purposes:
- Ensuring the proper operation of NILG.AI;
- Delivering you the requested services;
- Processing your payments;
- Responding to your enquiries;
- Pursuing our legitimate interests;
- Enforcing our rights, preventing fraud, and security purposes;
- Carrying out our contractual obligations;
- Law enforcement purposes; or
- If you provide your prior consent to such a disclosure.
- Our web hosting service providers Namecheap and Amazon Web Services located in the United States;
- Our business management service provider Thinkific located in Canada;
- Our marketing and newsletter service providers ActiveCampaign and Mailchimp located in the United States;
- Our cloud service provider Google located in the United States;
- Our accounting and invoicing service provider Moloni and Bluefile located in Portugal;
- Our analytics service provider Google Analytics;
- Our technical support and marketing service provider Hubspot located in the United States;
- Our payment service providers Stripe and PayPal located in the United States and Moloni located in Portugal;
- Our scheduling service provider Calendly located in the United States;
- Our time logging service provider Toggl located in Estonia; and
- Our independent contractors and consultants.
4.3 International transfers. Some of our data processors may be based outside the country where you reside. For example, if you reside in the UK or a country belonging to the European Economic Area (EEA), we may need to transfer your personal data outside the UK or the EEA. In case it is necessary to make such a transfer, we will make sure that the country in which our data processor is located guarantees an adequate level of protection for your personal data or we conclude an agreement with it that ensures such protection (e.g., a data processing agreement based pre-approved Standard Contractual Clauses).
4.4 Disclosure of non-personal data. Your non-personal data may be disclosed to third parties for any purpose as it does not identify you as a natural person. For example, we may share it with prospects or partners for business or research purposes, for improving NILG.AI, responding to lawful requests from public authorities or developing new products and services.
4.5 Legal requests. If requested by a public authority, we will disclose information about the users of NILG.AI to the extent necessary for pursuing a public interest objective, such as national security or law enforcement.
4.6 Subsidiaries. We may disclose your personal data to our group of companies, if it is necessary for th purpose for which your personal data is provided.
5. HOW DO WE PROTECT YOUR DATA?
Here you can find information on how we protect your data against breaches.
5.1 Security measures. We implement technical and organizational information security measures that protect your personal data from loss, misuse, unauthorized access and disclosure. The security measures taken by us include proper authentication, secured networks, strong passwords, limited access to your personal data by our staff, anonymisation of personal data (when possible), limitation of login attempts, and carefully selected data processors.
5.2 Security breaches. Although we put our best efforts to protect your personal data, given the nature of communication and information processing technology and the Internet, we cannot be liable for any unlawful destruction, loss, use, copying, modification, leakage, and falsification of your personal data caused by circumstances that are beyond our reasonable control. In case a serious breach occurs, we will take reasonable measures to mitigate the breach, as required by the applicable law. Our liability for any security breach will be limited to the highest extent permitted by the applicable law.
6. HOW CAN YOU MANAGE YOUR PERSONAL DATA?
Here you can find detailed information about the rights that you have with regard to your personal data and how to exercise those rights.
6.1 The list of your rights. You have the right to control how we process your personal data. Subject to any exemptions provided by law, you have the following rights:
- Right of access: you can get a copy of your personal data that we store in our systems and a list of purposes for which your personal data is processed;
- Right to rectification: you can rectify inaccurate personal data that we hold about you;
- Right to erasure (‘right to be forgotten’): you can ask us to erase your personal data from our systems;
- Right to restriction: you can ask us to restrict the processing of your personal data;
- Right to data portability: you can ask us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format and move that personal data to another processor;
- Right to object: you can ask us to stop processing your personal data;
- Right to withdraw consent: you have the right to withdraw your consent, if you have provided one; or
- Right to complaint: you can submit your complaint regarding our processing of your personal data.
6.3 Complaints. If you would like to launch a complaint about the way in which we handle your personal data, we kindly ask you to contact us first and express your concerns. After you contact us, we will investigate your complaint and provide you with our response as soon as possible (no later than 30 days). If you are not satisfied with the outcome of your complaint, you have the right to lodge a complaint with your local data protection authority.
Postal address: NILG.AI, Lda, Rua de Santa Justa 228G 2CEP, Porto, 4200-479, Portugal