NEBHUB, LLC. Privacy Statement, effective as of JANUARY 1st, 2020
When you use and interact with our Nebhub websites, intranet system, admin system, or other services like Nebhub licensing & hosting services, or otherwise contact us, we may collect, use, share and process information relating to you and/or your customers ("Personal Data"). For the purpose of this Privacy Statement, Nebhub can also be referred to as (“Nebhub, LLC.”, “we”, “us”). Nebhub has established this Privacy Policy to let you know what information we may collect from you and or your customers through your website, intranet, admin system or other services as well as any other interactions with you, and how we may use and share that information.
By using any products or services associated with Nebhub, and/or providing us with Personal Information, you agree to accept the terms of our Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use any of our Nebhub products or services or provide us with any Personal Information. This Privacy Policy applies to information that we collect on the Nebhub website, Nebhub Intranet and Nebhub Admin system and to information which we may collect by other “offline” means, including, without limitation, sales calls, meetings and other business transactions with you.
This Nebhub Privacy Statement (“Privacy Statement") explains our privacy practices for the activities described herein. Please read this Privacy Statement carefully to learn how we collect, use, share, and otherwise process information relating to individuals (“Personal Data”), and to learn about your rights and choices regarding your Personal Data.
1. Responsible NEBHUB entity
Nebhub is the controller of your Personal Data as described in this Privacy Statement, unless specified otherwise.
This Privacy Statement does not apply to the extent we process Personal Data in the role of a processor or service provider on behalf of our customers, including where we offer to our customers various cloud products and services through which our customers (or their affiliates): (i) manage their own websites, intranets and admin systems running on our platforms; (ii) sell or offer their own products and services; (iii) send electronic communications to others; or (iv) otherwise collect, use, share or process Personal Data via our Nebhub products and services.
For detailed privacy information related to a Nebhub customer or a customer affiliate who uses the Nebhub cloud products and services as the controller, please contact our customer directly. We are not responsible for the privacy or data security practices of our customers, which may differ from those explained in this Privacy Statement. For more information, please also see Section 10.3 below.
2. Processing activities covered
This Privacy Statement applies to the processing of Personal Data collected by us when you:
Visit our websites;
Visit our branded social media pages;
Visit our offices;
Receive communications from us, including emails, online meetings, phone calls, texts or fax;
Use our Nebhub products and services as an authorized user (for example, as an employee of one of our customers who provided you with access to our services) where we act as a controller of your Personal Data;
Processing of Personal Data is required for receiving Nebhub products or services.
Our websites, intranet and admin system and services may contain links to other websites, applications, and services maintained by third parties. The information practices of other services, or of social media platforms that host our branded social media pages, are governed by their privacy statements, which you should review to better understand their privacy practices.
3. What Personal Data do we collect?
3.1 Personal Data we collect directly from you
The Personal Data we collect directly from you includes identifiers, professional or employment-related information, financial account information, commercial information, visual information, and internet activity information. We collect such information in the following situations:
If you express an interest in obtaining additional information about our services; request customer support; use our “Contact Us” or similar features; register to use our Nebhub websites, intranet or admin systems; webinars, or download certain content, we may require that you provide to us your contact information, such as your name, job title, company name, address, phone number, email address or username and password;
If you make purchases via our websites, intranets or admin systems, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information;
If you interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails (such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Data (please see the “What device and usage data we process” section, below) using cookies, web beacons, or similar technologies;
If you use and interact with our products and services, we automatically collect information about your device and your usage of our services through log files and other technologies, some of which may qualify as Personal Data (please see the “What device and usage data we process” section, below);
If you communicate with us via a phone call, zoom or gotomeeting, we may record that call;
If you voluntarily submit certain information to our websites, intranets or admin systems and our products and services, such as filling out a form as an example, we collect the information you have provided as part of that request.
If you place an order in our websites or intranet, we only store the last 4 digits of your credit card and use en encrypted key that is provided by your merchant: Ie: Square, Authorize.net, etc. to relate to that payment.
If you provide us or our service providers with any Personal Data relating to other individuals, you represent that you have the authority to do so, and where required, have obtained the necessary consent, and acknowledge that it may be used in accordance with this Privacy Statement.
3.2 Personal Data we collect from other sources
We also collect information about you from other sources including third parties from whom we may purchase or collect Personal Data and from publicly available information. We may combine this information with Personal Data provided by you. This helps us update, expand, and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. The Personal Data we collect from other sources includes identifiers, professional or employment-related information, education information, commercial information, visual information, internet activity information, and inferences about preferences and behaviors. In particular, we collect such Personal Data from the following sources:
Third party providers of business contact information, including mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of targeted advertising, delivering relevant email content, event promotion and profiling, determining eligibility and verifying contact information; and
Another individual at your organization who may provide us with your business contact information for the purposes of obtaining services; and
Platforms such as GitHub to manage code check-ins and pull requests.
Google Apps like Google Analytics, Google Tag Manager, Etc.
4. What device and usage data do we process?
We use common information-gathering tools, such as tools for collecting usage data, cookies, web beacons, pixels, and similar technologies to automatically collect information that may contain Personal Data as you or your customers navigate our websites, intranets, admin systems, our services, or interact with emails we have sent to you.
4.1 Device and usage data
As is true of most websites, we gather certain information automatically when individual users visit our websites. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server information), device and application information, identification numbers and features, location, browser type, plug-ins, integrations, Internet service provider, mobile carrier, the pages and files viewed, searches, referring website, app or ad, operating system, system configuration information, advertising and language preferences, date and time stamps associated with your usage, and frequency of visits to the websites. This information is used to analyze overall trends, help us provide and improve our websites, offer a tailored experience for website users, and secure and maintain our websites.
In addition, we gather certain information automatically as part of your use of Nebhub websites, intranets, admin system, cloud products and services. This information may include identifiers, commercial information, and internet activity information such as IP address (or proxy server), mobile device number, device and application identification numbers, location, browser type, Internet service provider or mobile carrier, the pages and files viewed, website and webpage interactions including searches and other actions you take, operating system and system configuration information and date and time stamps associated with your usage. This information is used to maintain the security of the services, to provide necessary functionality, to improve performance of the services, to assess and improve customer and user experience of the services, to review compliance with applicable usage terms, to identify future opportunities for development of the services, to assess capacity requirements, to identify customer opportunities, and for the security of Nebhub generally (in addition to the security of our products and services). Some of the device and usage data collected by the services, whether alone or in conjunction with other data, could be personally identifying to you. Please note that this device and usage data is primarily used to identify the uniqueness of each user logging on (as opposed to specific individuals), apart from where it is strictly required to identify an individual for security purposes or as required as part of our provision of the services to our customers.
4.2 Cookies, web beacons and other tracking technologies on our website and in email communications
We use technologies such as web beacons, pixels, tags, and JavaScript, alone or in conjunction with cookies, to gather information about the use of our websites and how people interact with our emails.
When you visit our websites, we, or an authorized third party, may place a cookie on your device that collects information, including Personal Data, about your online activities over time and across different sites. Cookies allow us to track use, infer-browsing preferences, and improve and customize your browsing experience.
We use both session-based and persistent cookies on our websites. Session-based cookies exist only during a single session and disappear from your device when you close your browser or turn off the device. Persistent cookies remain on your device after you close your browser or turn your device off. You can also control the use of cookies on your device, but choosing to disable cookies on your device may limit your ability to use some features on our websites and services.
We also use web beacons and pixels on our websites and in emails. For example, we may place a pixel in marketing emails that notify us when you click on a link in the email. We use these technologies to operate and improve our websites and marketing emails.
The following describes how we use different categories of cookies and similar technologies and your options for managing the data collection settings of these technologies:
Type of Cookies, Description, Managing Settings, Required Cookies
Required cookies are necessary for basic website functionality. Some examples include: session cookies needed to transmit the website, authentication cookies, and security cookies.
If you have chosen to identify yourself to us, we may place on your browser a cookie that allows us to uniquely identify you when you are logged into the websites and to process your online transactions and requests.
Because required cookies are essential to operate the websites, there is no option to opt out of these cookies.
Functional cookies
Functional cookies enhance functions, performance, and services on the website. Some examples include: cookies used to analyze site traffic, cookies used for market research, and cookies used to display advertising that is not directed to a particular individual.
Functional cookies may also be used to improve how our websites function and to help us provide you with more relevant communications, including marketing communications. These cookies collect information about how our websites are used, including which pages are viewed most often.
We may use our own technology or third-party technology to track and analyze usage information to provide enhanced interactions and more relevant communications, and to track the performance of our advertisements or to track the performance of our Nebhub websites, intranets and admin systems.
For example, we use Google Analytics (“Google Analytics”), a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. You can learn about Google’s privacy practices by going to www.google.com/policies/privacy/partners/.
Google Analytics uses cookies to help us analyze how our websites are used, including the number of visitors, the websites from which visitors have navigated to our websites, and the pages on our websites to which visitors navigate. This information is used by us to improve our websites. We use Google Analytics with restrictions on how Google can process our data enabled. For information on Google’s Restricted Data Processing go to https://privacy.google.com/businesses/rdp/.
Nebhub may also use HTML5 local storage or Flash cookies for the above-mentioned purposes. These technologies differ from browser cookies in the amount and type of data they store, and how they store it.
You can choose to opt out of functional cookies by checking your devices browser and searching how to opt out of cookies or disable cookies.
Advertising cookies
Advertising cookies track activity across websites in order to understand a viewer’s interests, and to direct marketing to them.
We sometimes use cookies delivered by us or by third parties to show you ads for our products that we think may interest you on devices you use and to track the performance of our advertisements. For example, these cookies collect information such as which browser you used when visiting our websites.
Nebhub also contracts with third-party advertising networks that collect IP addresses and other information from web beacons on our websites, from emails and on third-party websites. Advertising networks follow your online activities over time and across different websites or other online services by collecting device and usage data through automated means, including through the use of cookies. These technologies may recognize you across the different devices you use. When we work with third party advertising networks, we require them to restrict their data processing to only what is necessary to provide us with the advertising services we request.
You can choose to opt out of functional cookies by checking your devices browser and searching how to opt out of cookies or disable cookies.
4.3 Notices on behavioral advertising and opt-out for website visitors
As described above, we or one of our authorized partners may place or read cookies on your device when you visit our websites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”).
4.4 Opt-Out from the setting of cookies on your individual browser
You may opt-out from the collection of non-essential device and usage data on your web browser by managing your cookies at the browser or device level. Please note, however, that by blocking or deleting cookies and similar technologies used on our websites, you may not be able to take full advantage of the websites.
While some internet browsers offer a “do not track” or “DNT” option that lets you tell websites that you do not want to have your online activities tracked, these features are not yet uniform and there is no common standard adopted by industry groups, technology companies, or regulators. Therefore, we do not currently commit to responding to browsers’ DNT signals with respect to our websites. Nebhub takes privacy and meaningful choice seriously and will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.
4.5 Social Media Features
Our websites may use social media features, such as the Facebook “like” button, the “Tweet” button and other sharing widgets (“Social Media Features”). Social Media Features may allow you to post information about your activities on our websites or intranets to outside platforms and social networks. Social Media Features may also allow you to like or highlight information we have posted on our website or our branded social media pages. Social Media Features are either hosted by each respective platform or hosted directly on our website. To the extent the Social Media Features are hosted by the platforms themselves, and you click through to these from our websites, the platform may receive information showing that you have visited our websites. If you are logged in to your social media account, it is possible that the respective social media network can link your visit to our websites with your social media profile.
Nebhub also allows you to log in to certain of our websites using sign-in services like Facebook Connect. These services authenticate your identity and provide you the option to share certain Personal Data from these services with us such as your name and email address to pre-populate our sign-up form.
Your interactions with Social Media Features are governed by the privacy policies of the companies providing them.
5. Purposes for which we process Personal Data and the legal bases on which we rely
We collect and process your Personal Data for the following purposes. We rely on authorized legal basis (including but not limited to the (a) performance of a contract or (b) legitimate interest) to collect and process your Personal Data.
Providing our websites, intranet and admin systems and services (including necessary functionality for both): We process your Personal Data to perform our contract with you for the use of our websites, intranets and admin systems and services and to fulfill our obligations under the applicable terms of use and service; if we have not entered into a contract with you, we base the processing of your Personal Data on our legitimate interest to operate and administer our websites and to provide you with content you access and request (e.g., to download content from our websites);
Promoting the security of our websites and services: We process your Personal Data by tracking use of our websites and services, creating aggregated non-personal data, verifying accounts and activity, investigating suspicious activity, and enforcing our terms and policies to the extent it is necessary for our legitimate interest in promoting the safety and security of the services, systems and applications and in protecting our rights and the rights of others;
Managing user registrations: If you have registered for an account with us, we process your Personal Data by managing your user account for the purpose of performing our contract with you according to applicable terms of service;
Handling contact and user support requests: If you fill out a “Contact Me” web form or request user support, or if you contact us by other means including via a phone call or online meeting, we process your Personal Data to perform our contract with you and to the extent it is necessary for our legitimate interest in fulfilling your requests and communicating with you;
Managing payments: If you have provided financial information to us, we process your Personal Data to verify that information and to collect payments to the extent that doing so is necessary to complete a transaction and perform our contract with you;
Developing and improving our websites, intranets and admin systems and services: We process your Personal Data to analyze trends and to track your usage of and interactions with our websites, intranets, admin systems and services to the extent it is necessary for our legitimate interest in developing and improving our websites, intranets, admin systems and services and providing our users with more relevant content and service offerings, or where we seek your valid consent;
Assessing and improving user experience: We process device and usage data as described in Section 4.1 above, which in some cases may be associated with your Personal Data, to analyze trends and assess and improve the overall user experience to the extent it is necessary for our legitimate interest in developing and improving the service offering, or where we seek your valid consent;
Reviewing compliance with applicable usage terms: We process your Personal Data to review compliance with the applicable usage terms in our customer’s contract to the extent that it is in our legitimate interest to ensure adherence to the relevant terms;
Assessing capacity requirements: We process your Personal Data to assess the capacity requirements of our services the extent that it is in our legitimate interest to ensure that we are meeting the necessary capacity requirements of our service offering;
Identifying customer opportunities: We process your Personal Data to assess new potential customer opportunities to the extent that it is in our legitimate interest to ensure that we are meeting the demands of our customers and their users’ experiences;
Recording phone calls or online meetings: We may record phone calls or online meetings for training, quality assurance, and administration of required under applicable law, we will obtain your prior consent or give you the option to object to a call being recorded.
Displaying personalized advertisements and content: We process your Personal Data to conduct marketing research, advertise to you, provide personalized information about us on and off our websites and to provide other personalized content based upon your activities and interests to the extent it is necessary for our legitimate interest.
Sending marketing communications: We will process your Personal Data or device and usage data, which in some cases may be associated with your Personal Data, to send you marketing information, product recommendations and other non-transactional communications (e.g., marketing newsletters, telemarketing calls, SMS, or push notifications) about us and our affiliates and partners, including information about our products, promotions or events as necessary for our legitimate interest in conducting direct marketing.
Complying with legal obligations: We process your Personal Data when cooperating with public and government authorities, courts or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of Personal Data to protect our rights or is necessary for our legitimate interest in protecting against misuse or abuse of our websites, intranets, admin systems or services by protecting personal property or safety, pursuing remedies available to us and limiting our damages, complying with judicial proceedings, court orders or legal processes, respond to lawful requests, or for auditing purposes.
6. Who do we share Personal Data with?
We may share your Personal Data as follows:
Service Providers: With our contracted service providers, who provide services such as IT and system administration and hosting, credit card processing, research and analytics, marketing, customer support and data enrichment for the purposes and pursuant to the legal bases described above:
Admark
Affirm
Authorize.net
Braintree
Fedex
Google
Moneris
MX Merchant
Payeezy
Paypal
Quickbooks
Rackspace
SAGE
SofteBizz
Square
Stripe
Synchrony Financial
United States Postal Service
UPS
USA ePay
Affiliates: If you use our websites, intranets, admin systems and services to register in a form, we may share your Personal Data with the affiliate. in such instances, our affiliate will process the relevant Personal Data as a separate controller and will provide you with further information on the processing of your Personal Data, where required. A list of affiliate companies currently within the Nebhub corporate group is listed above.
Customers With Whom You Are Affiliated: If you use our services as an authorized user, we may share your Personal Data with your affiliated customer responsible for your access to the services to the extent this is necessary for verifying accounts and activity, investigating suspicious activity, or enforcing our terms and policies;
Third party networks and websites: With third-party social media networks, advertising networks and websites, so that Nebhub can market and advertise on third party platforms and websites;
Third Party Partners: Specifically in relation to the website, we may share your Personal Data with our third party partners who may contact you regarding their products or services;
Nebhub Family Affiliates: With affiliates within the Nebhub corporate group and companies that we acquire in the future after they are made part of the Nebhub corporate group, to the extent such sharing of data is necessary to fulfill a request you have submitted via our websites, intranet or admin systems for customer support, marketing, technical operations and account management purposes. A list of companies currently within the Nebhub Corporate group is listed above. Further, due to the nature of our relationship with our social enterprise organization, Nebhub, we may share Personal Data between Nebhub and Admark, Inc. for the business or organizational purposes of both or either; and
Third Parties Involved in a Corporate Transaction: If we are involved in a merger, reorganization, dissolution or other fundamental corporate change, or sell a website or business unit, or if all or a portion of our business, assets or stock are acquired by a third party. In accordance with applicable laws, we will use reasonable efforts to notify you of any transfer of Personal Data to an unaffiliated third party.
We may also share anonymous or de-identified usage data with Nebhub’s service providers for the purpose of helping Nebhub in such analysis and improvements. Additionally, Nebhub may share such anonymous or de-identified usage data on an aggregate basis in the normal course of operating our business; for example, we may share information publicly to show trends about the general use of our services.
7. International transfer of Personal Data
Your Personal Data may be collected, transferred to and stored by us in the United States and by our affiliates and third-parties that are based in other countries.
Therefore, your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the EEA. We ensure that the recipient of your Personal Data offers an adequate level of protection and security, for instance by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses or an alternative mechanism for the transfer of data as approved by the European Commission (Art. 46 GDPR) or other applicable regulator. Where required by applicable law, we will only share, transfer or store your Personal Data outside of your jurisdiction with your prior consent.
8. Children
Our websites are not directed at children. We do not knowingly collect Personal Data from children under the age of 16 unless (a) we have obtained consent from a parent or guardian, (b) such collection is subject to a separate agreement with us or (c) the visit by a child under the age of 16 is unsolicited or incidental. If you are a parent or guardian and believe your child has provided us with Personal Data without your consent, please contact us by using the information in the “Contacting us” section below and we will take steps to delete their Personal Data from our systems.
9. How long do we keep your Personal Data?
We may retain your Personal Data for a period of time consistent with the original purpose of collection or as long as required to fulfill our legal obligations.
10. Your rights relating to your Personal Data
10.1 Your rights
You may have certain rights relating to your Personal Data, subject to local data protection laws. Depending on the applicable laws these rights may include the right to:
Access your Personal Data held by us;
Know more about how we processed your Personal Data;
Rectify inaccurate Personal Data and, taking into account the purpose of processing the Personal Data, ensure it is complete;
Erase or delete your Personal Data (also referred to as the right to be forgotten), to the extent permitted by applicable data protection laws;
Transfer your Personal Data to another controller, to the extent possible (right to data portability);
If you’re under the age of 16, opt in to certain disclosures of your Personal Data to third parties;
Not be discriminated against for exercising your rights described above;
Not be subject to a decision based solely on automated processing, including profiling, which produces legal effects ("Automated Decision-Making"). Automated Decision-Making currently does not take place on our websites or in our services; and
Withdraw your consent at any time (to the extent we base processing on consent), without affecting the lawfulness of the processing based on such consent before its withdrawal.
10.2 How to exercise your rights
To exercise your rights, please contact us by using at info@nebhub.com. Your personal data may be processed in responding to these rights. We try to respond to all legitimate requests within one month unless otherwise required by law, and will contact you if we need additional information from you in order to honor your request or verify your identity. Occasionally it may take us longer than a month, taking into account the complexity and number of requests we receive. If you are an employee of a Nebhub customer, we recommend you contact your employer’s system administrator for assistance in correcting or updating your information.
Some registered users may update their user settings, profiles, organization settings and event registrations by logging into their accounts and editing their settings or profiles.
To update your billing information, discontinue your account or request return or deletion of your Personal Data and other information associated with your account, please contact us at info@nebhub.com.
10.3 Your rights relating to customer data
As described above, we may also process Personal Data submitted by or for a customer to our Nebhub websites, intranets, admin systems or products and services. To this end, if not stated otherwise in this Privacy Statement or in a separate disclosure, we process such Personal Data as a processor on behalf of our customer (and its affiliates) who is the controller of the Personal Data. We are not responsible for and have no control over the privacy and data security practices of our customers, which may differ from those explained in this Privacy Statement.
10.4 Your preferences for email marketing communications
If we process your Personal Data for the purpose of sending you marketing communications, you may manage your receipt by unsubscribing to our newsletter or email marketing campaigns at the bottom of the marketing campaign.
11. How we secure your Personal Data
We take appropriate precautions including organizational, technical, and physical measures to help safeguard against accidental or unlawful destruction, loss, alteration, and unauthorized disclosure of, or access to, the Personal Data we process or use.
While we follow generally accepted standards to protect Personal Data, no method of storage or transmission is 100% secure. You are solely responsible for protecting your password, limiting access to your devices and signing out of websites after your sessions. If you have any questions about the security of our websites, intranets or admin systems, please contact us at info@nebhub.com
12. Changes to this Privacy Statement
We will update this Privacy Statement from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. If we do, we will update the “effective date” at the top. If we make a material update, we may provide you with notice prior to the update taking effect, such as by posting a conspicuous notice on our website or by contacting you directly, or where required under applicable law and feasible, seek your consent to these changes.
We encourage you to periodically review this Privacy Statement to stay informed about our collection, processing and sharing of your Personal Data.
13. Contacting us
To exercise your rights regarding your Personal Data, or if you have questions regarding this Privacy Statement or our privacy practices please fill out this form, email us at info@nebhub.com, call us at 1-305-595-4388, or write to us at:
Nebhub, LLC.
8724 sw 72nd st #410
33173
14. Additional Disclosures for California Residents
The California Consumer Privacy Act requires businesses to disclose whether they sell Personal Data. As a business covered by the CCPA, we do not sell Personal Data. We may share Personal Data with third parties or allow them to collect Personal Data from our sites or Services if those third parties are authorized service providers or business partners who have agreed to our contractual limitations as to their retention, use, and disclosure of such Personal Data, or if you use Nebhub sites or Services to interact with third parties or direct us to disclose your Personal Data to third parties.
California law requires that we detail the categories of Personal Data that we disclose for certain “business purposes,” such as to service providers that assist us with securing our services or marketing our products, and to such other entities as described in Sections 5 and 6 of this Privacy Statement. We disclose the following categories of Personal Data for our business purposes:
Identifiers;
Commercial information;
Internet activity information;
Financial information;
Professional and employment-related information;
Education information; and
Inferences drawn from any of the above information categories.
California law grants state residents certain rights, including the rights to access specific types of Personal Data, to learn how we process Personal Data, to request deletion of Personal Data, and not to be denied goods or services for exercising these rights.
If you are a California resident under the age of 18 and have registered for an account with us, you may ask us to remove content or information that you have posted to our website(s), intranets or admin systems. Please note that your request does not ensure complete or comprehensive removal of the content or information, because, for example, some of your content may have been reposted by another user.