Scope and Consent
By visiting our Website, using our Services and/or registering for an account with us, you are accepting the terms of this Privacy Notice and our Terms of Service, and you are consenting to our collection, use, disclosure, retention, and protection of personal information about you and devices you use as described in this Privacy Notice. If you do not provide the information we require, we may not be able to provide all of our Services to you.
“Personal information” is information that can be associated with a specific person and could be used to identify that specific person whether from that data or from that data and other information that we have or are likely to have access to. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, whether in combination with other information or otherwise.
Changes to this Notice
The owner and data controller of your personal information collected, processed, used and stored by the Services and/or the nonda Device(s) is: No NDA Inc., 828 Bryant Street, Palo Alto, CA 94301, USA. We can be contacted by email at: email@example.com
Location of storage and processing of personal information
Your personal information is stored and processed at our headquarters in the USA, unless stated otherwise in the rest of this document.
We collect, process, and retain personal information from you and any devices (including mobile devices) you may use when you: use our Services, register for an account with us, update or add information to your account, provide feedbacks, request support, subscribe to content we offer, or when you otherwise correspond with us regarding our Services. The personal information we collect includes the following:
Personal information you give us when you use our Services or register for an account with us
We may collect information such as your first and last name, home or other physical address, email address, zip code, telephone number, or information about your interactions with us or others, and other information.
Personal information we collect automatically when you use our Services or register for an account with us
Whenever you sign in on your account through the nonda App, we may collect the following information automatically, as collected and sent by the nonda App, and associate such information with your account:
- your location information
- your nonda Devices’ location information
- information about your usage of our Services, including by making use of third party web analysis tools, the frequency and scope of your use of the Services, nonda advertisements that you view or click on, information about the mobile device on which you have installed the nonda App, and the geographic location of the computer system or device that you are using to log into our Services
Personal information we collect using other users’ mobile devices
We collect, and store with your account, detailed location information about your nonda Device(s) as collected and sent via other users’ mobile devices with an installed and activated nonda App; these users will not have access to such information. Likewise, we collect location information about other users’ nonda Device(s) tracked and transmitted to us by the nonda App on your mobile device, when the nonda App is activated on your mobile device.
Personal information from other sources
Social media. You may use social networks or other online services to use our Services. When you do so, we may collect certain personal information made available through your social network account. By associating a social network account with our Services, you agree that we may access and retain that information in accordance with the policies of the social network or other online service and this Privacy Notice. For example, we may be able to access account or profile information that you have provided to the social network or information about your interactions with the social network (such as content viewed by you, content liked by you and information about the advertisements you have been shown or may have clicked on, etc.). You control the personal information you allow us to have access to through the privacy settings on the applicable social media site and the permissions you give us when you grant us access to your personal information retained by the respective social media site about you.
Information through customer service. We may collect the personal information you actively provide to our service personnel if you contact our customer support hotline through our Website and/or nonda App.
Email. We may collect information regarding the effectiveness of our email and other communications with you. For example, we may know if you follow a link in an email we send to you.
Information about a third party. If you give us personal information about someone else, you must do so only with their explicit and prior consent. You have to inform them how we collect, use, disclose, and retain their personal information according to our Privacy Notice.
Use and Retention
We and others acting on our behalf may use the information that we collect or receive to operate our Website and Services, as described below:
Operate and support our website and Services. We use and process your personal information from your registration and usage of our Services (including your location information and your nonda Devices’ location information) to provide you with our object location services. For example, we use such information to help you track and find your nonda Devices which are in reach of your mobile device, to remember the last known location of your nonda devices, and/or to communicate to you the location of your nonda Devices in reach of other users’ mobile devices. We also use the location information of another user which has been tracked by your mobile device to help other users of the Services to find their lost nonda Device(s) by sending anonymous location updates to those other users when the nonda App on your mobile device “finds” their lost nonda Device(s).
Other uses. We may use and process your personal information (including your location information and your nonda Devices’ location information) to provide you with support and handle requests and complaints; to send you updates, notices, and additional information related to the Services; to create anonymous, statistical and aggregated data and reports (i.e., in a form where such data does not enable the identification of a specific user); to comply with any applicable law and assist law enforcement agencies under any applicable law, when we have a good faith belief that our cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures; and to prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services.
Our use and sharing of your nonda Device location information. The Services are based on a community of all users of the Services sharing location information with us. Whenever a nonda App is activated on a user’s mobile device, we will collect detailed location information about any nonda Device(s) in reach of such mobile device, as collected and sent to us by the mobile device. Any location information we receive about nonda Device(s) located through a nonda App will be stored by us on our cloud server. Such information can be associated by us with the account for which the nonda Device(s) have been registered (by linking the unique nonda Device identifier with the account information), to help you to track your nonda Device(s) in reach of other users’ mobile devices with an activated nonda App. However, your location information will be completely anonymous to other users, unless you actively decide to share these data, e.g., by choosing to share access to your Services’ account with other people, or by using social networks. We will not identify you personally to other users or otherwise make your location information available to any third party in personal identifiable form without your prior consent.
Our use and sharing of aggregated information. We use information about our users’ website activities and usage of our Services in anonymous, statistical or aggregated form, i.e., in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes. We also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, or to our service providers or business partners.
Prevent, detect, mitigate, and investigate fraudulent or illegal activities. We may use the information we collect to prevent, detect, mitigate, and investigate fraud, security breaches, potentially prohibited or illegal activities; and to enforce our Privacy Notice, our Terms of Service or other policies.
Other Contacts. We may contact you through telephone, text, or chat for other purposes, as permitted by law.
We retain your personal information as long as it is necessary and relevant for our operations. In addition, we may retain personal information from closed accounts to comply with national laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service and take other actions permitted or required by applicable national laws. After it is no longer necessary for us to retain your personal information, we dispose of it in a secure manner according to our data retention and deletion policies.
Cookies are small text files that our Services ask to place on your computer’s hard drive and onto your mobile device’s memory. If your browser is set to accept cookies, then your browser adds the text in a small file.
We use cookie technology for various purposes, such as to facilitate your use of our Services, e.g., to remember you when you return to our Website, identify you when you sign in, authenticate your access, enable your use of specific functionalities, keep track of your specified preferences or choices, tailor content to your preferences or geographic region, display personalized browsing history, or provide technical support.
Cookies also enable us to display interest-based advertising on our Website using information you make available to us when you interact with our sites, content, or services. Interest-based ads are displayed to you based on cookies linked to your online activities.
While our Website and nonda App at this time do not recognize automated browser signals regarding tracking mechanisms, such as “do not track” instructions, you can generally express your privacy preferences regarding the use of most cookies and similar technologies through your web browser, as indicated above.
Integration of third party web analysis services and social functionalities
You can change your settings to refuse these third party cookies or to warn you before cookies are placed. However, if you choose not to accept cookies, you may not be able to take advantage of some of our features and services through our Services.
The third parties service includes but not limited to:
- Google Analytics (Google)
- Amplitude Analytics
- Social Plugins and Social Widgets
Controlling your Personal Information
You have the right, at any time, to know whether your personal information has been stored and can consult us to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any of your personal information, as well as to oppose their processing for any and all legitimate reasons. Requests should be sent to us at the contact information set out under the “Questions” section below.
If you request the deletion of your account and your personal information, we will delete such information. However, please note that we may not delete information from our back-up systems.
You may limit and control the information provided to us in a number of ways. You may not be able to use all features of our Sites and Services if you limit the information you share with us. For example, you can choose not to access our Website through your social media account. You may also be able to limit the information provided to us by third party social media providers by altering your privacy settings with those providers.
You have a choice about how we use your personal information to communicate with you, to send you marketing information, how we provide you with customized and relevant advertising, and whether you want to stay signed into your account. For example, you may unsubscribe from promotional emails from us by following the unsubscribe link included in each such email.
You have the right to refuse to accept this Privacy notice if we do not receive other users’ explicit and prior consent when we collect their personal information through your device, and have the right to receive our promise that we will hold you harmless from any claim or liability arising from our use of your device in collecting other users’ personal information.
We may periodically send you free newsletters and e-mails that directly promote our Services. When you receive such promotional communications from us, you will have the opportunity to “opt-out” (either through your Account or by following the unsubscribe instructions provided in the e-mail you receive). We do need to send you certain communications regarding the Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or information about billing).
We take steps to ensure that the personal information we collect is accurate and up to date, and that you have the ability to access and make corrections to it. This includes the following: You can see, review and change your personal information by signing in to your account. Please update your personal information immediately if it changes or is inaccurate.
We will honor any statutory right you might have to access, modify or erase your personal information. Where you have a statutory right to request access or request the modification or erasure of your personal information, we can still withhold that access or decline to modify or erase your personal information in some cases in accordance with applicable national laws, but will give you reasons if we do so.
We may disclose your personal information to the following parties and for the following purposes:
Corporate affiliates. We may disclose information to our corporate affiliates for purposes such as providing joint content and services (like registration, transactions, and customer support), performing marketing and helping detect and prevent potentially fraudulent and illegal acts, violations of our Terms of Service, and data security breaches. We may also participate in joint ventures with others and we may disclose information as part of that joint venture.
Partner sites. We may disclose the information we collect to Partner Sites (as defined below) and the owners of those sites. For example, we may share information for the purpose of determining or verifying our economic rights and obligations.
Service providers. We may share your personal information (including your location information and your nonda Devices’ location information) with our third party service providers or affiliates, as authorized by us to collect, process and use your personal information as data processors on our behalf, such as, for instance, cloud based and hosting services, technical service providers, mail carriers, communication agencies and customer support service providers; these parties may be located in countries outside of your jurisdiction, including but not limited to the USA. An updated list of the parties engaged by us for the processing of your personal information may be requested from us at any time. Other than as indicated above, we will not share your personal information with any third parties, unless compelled by law to do so or if you have given your prior consent.
Business transfer/change of ownership. We may disclose information we have collected from you in connection with the sale or merger of our business or the transfer of assets. If we were to merge with or be acquired by another company, we may share information with them in accordance with our privacy standards. Should such an event occur, we will require that the new combined entity follow this Privacy Notice with respect to your personal information.
Law enforcement, legal proceedings, and as authorized by law. We may use and disclose the information we collect to law enforcement or governmental agencies, or authorized third-parties, in response to a verified request relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability. We may disclose your personal information to comply with our legal requirements, enforce our Terms of Service, or protect anyone’s rights, property or safety.
We use administrative, technical, and physical security designed to safeguard personal information in our possession. We cannot guarantee the security of the information that we collect and store. If you believe that information about you has been subject to unauthorized disclosure, please let us know by contacting us at the address as specified in the “Questions” section below.
Other Important Information
California Privacy Rights
California Civil Code Section 1798.83 entitles California users to request information concerning the disclosure of certain personal information to third parties for the third parties’ direct marketing purposes. California users who wish to request further information in compliance with this law may contact us as specified in the “Questions” section below. As of the Effective Date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to such signals or to other mechanisms that provide the ability to exercise choice regarding the collection of personal information regarding your online activities over time and across third party websites or online services.
Our websites are general audience websites and are not directed to children under the age of 13. Our Services are not intended for children under the age of 13. We do not knowingly collect personal information from users in this age group.
Third Party Privacy Practices
This Privacy Notice addresses only the use and disclosure of personal information we collect from you. This Privacy Notice does not apply to information you share with third parties, even if we link to those third parties from the Website. If you disclose your information to others, or if you are directed to a third party website, their privacy notices and practices will apply. We cannot guarantee the privacy or security of your information once you provide it to a third party and we encourage you to evaluate the privacy and security policies of such third party before entering into a transaction and choosing to share your information.
Our services may be offered through third party websites or mobile applications (“Partner Sites”). This Privacy Notice does not apply to Partner Sites, unless otherwise indicated on the Partner Site.
Notwithstanding the forgoing, please note that other parties may collect personally information about your online activities over time and across different websites when you use our Website.
By using our Website and Services, you agree that any dispute arising out of or relating to the use of our Website and Services, or regarding information collected or shared about you, is subject to the Choice of Law, Venue, and Class Action Waiver provisions in our Terms of Service.
You can contact us with questions about our privacy practices or this Privacy Notice by sending us a letter or postcard to:
No NDA Inc.
828 Bryant Street, Palo Alto, CA 94301, USA
This Privacy Notice was posted on July 12, 2016.