NOLUMA PRIVACY STATEMENT
We know you are concerned about your privacy, and Noluma International, LLC and its affiliates (“Noluma”) are too, and we want you to be familiar with how we collect, use and disclose information. This Privacy Statement describes Noluma practices in connection with information that we collect through the website or mobile application owned and controlled by Noluma from which you are accessing this Privacy Statement (respectively, the “Site” and the “App”), as well as offline where notice is legally required. By providing Personal Information to Noluma, you agree to the terms and conditions of this Privacy Statement.
This Privacy Statement does not apply to personal information collected for employment-related purposes, which are addressed by a separate privacy notice.
Noluma is committed to working with you to obtain a fair and rapid resolution of any questions or concerns you might have regarding this Privacy Statement or our collection or use of your personal information Please contact us at email@example.com if you have questions.
WHAT WE MEAN BY “PERSONAL INFORMATION”
“Personal Information” is information that identifies you as an individual, or that can be used to identify you when combined with other available information about you. We collect Personal Information when you interact with us online and participate in various opportunities that we provide. We may combine Personal Information that we collect about you with Personal Information you provide to Noluma through other sources, such as product registrations, inquiries or marketing events. We will use the combined Personal Information in accordance with this Privacy Statement for as long as it is combined.
Information You Provide Voluntarily: • Name • Postal address (including billing and shipping addresses) • Telephone or fax number • Email address • Credit and debit card number • Vendor Tax ID numbers • National ID numbers such as Social Security Numbers • Financial information when you apply for credit • Purchase history • Biometric information when it is necessary for you to obtain access to a location (for example) • Demographic information and other information provided by you. Information we collect automatically: IP Address, Browser information Information collected through cookies: Pixel tags and other technologies
HOW WE COLLECT PERSONAL INFORMATION FROM AND ABOUT YOU
Noluma collects Personal Information when you interact with us online or participate in various opportunities that we provide, for example:
- When you visit our website or social media accounts, or use our App or participate in one of our blogs or forums
- When you have, or create an online user account with us
- When you register for subscriptions, join our technology forum or otherwise authorize us to communicate with you
- When you contact us for additional information
- When you raise a complaint or question, for example to our Hotline or our Information email address
- When you participate in a contest, promotion, sweepstakes, survey or other promotion
- When you create a business account with us
- When you order a product or service
- When you register your purchase of a Noluma product, submit a warranty card, or otherwise communicate with us regarding a product or service
- When we conduct market research, meet you at a trade show or other event
- When you provide your personal details to our Investor Relations team
- When you visit one of our locations and must establish your identity to gain access
- Through your browser
- Using cookies
HOW WE USE YOUR PERSONAL INFORMATION
Noluma uses your Personal Information for basic purposes:
To fulfil your requests;
To complete purchase or selling contracts;
To operate our business;
To improve your online experience; and
To comply with legal obligations.
PURPOSES WITHIN THE FRAMEWORK OF A LEGITIMATE INTEREST ON OUR PART OR OF THIRD PARTIES
Your data shall only be processed to the extent that you do not have any overriding interests against such processing such as in particular for the following purposes:
- When the processing is necessary for our legitimate interests to enhance our services, campaigns and website.
- To enable Noluma business purposes, such as data analysis, audits, researching and developing new products, enhancing Noluma’s website, improving Noluma services, developing marketing events, identifying usage trends and determining the effectiveness of Noluma’s promotional campaigns.
- To secure access to our systems and facilities.
- Noluma uses IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, administering the Site and presenting content that is tailored to your country.
PURPOSES WITHIN THE FRAMEWORK OF YOUR CONSENT
- We may use your data with your consent. You have the right to withdraw your consent at any time by contacting firstname.lastname@example.org
- Send you marketing communications that we believe may be of interest to you, including information about trade shows, when you have opted-in to receive such communications.
PURPOSES WITHIN THE FRAMEWORK OF COMPLIANCE WITH A LEGAL OBLIGATION
If possible, we will use anonymized data for these purposes, but in the event we use or combine it with Personal Information we will treat it in accordance with this Privacy Statement for as long as it contains Personal Information.
WHO WE SHARE YOUR PERSONAL INFORMATION WITH, AND WHY
Except to the extent necessary to fulfill our business obligations as described in this Privacy Statement, or to accomplish a disclosure requested or authorized by you based on your express advance consent, we do not sell, transfer, or otherwise disclose the personal information we collect from and about you. We share your personal information as necessary to complete any transaction that you have requested or authorized. In addition, we share Personal Information among Noluma affiliates and subsidiaries and with vendors or agents working on our behalf for the purposes described in this statement.
YOUR CHOICES REGARDING NOLUMA’S USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION
Noluma gives you choices regarding Noluma’s use and disclosure of your Personal Information for marketing purposes and we will only use your Personal Information for marketing purposes with your prior consent.
SUBJECT ACCESS REQUESTS
If you would like to review, correct, update, suppress, delete or otherwise limit Noluma’s use of your Personal Information that has been previously provided to Noluma, you may contact Noluma at info@Noluma.com
RAISING A COMPLAINT
Noluma is committed to resolving complaints about our collection or use of your personal information. Individuals with inquiries or complaints regarding our Privacy Statement are encouraged to first contact Noluma at email@example.com.
You may also contact the Data Protection Authority / Supervisory Authority in the country of your habitual residence or place of work. A list from the International Conference of Data Protection & Privacy Commissioners can be found here: https://icdppc.org/participation-in-the-conference/list-of-accredited-members/.
OTHER IMPORTANT PRIVACY INFORMATION
For your security Noluma uses reasonable organizational, technical and administrative measures to protect Personal Information under Noluma control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with Noluma is no longer secure (for example,if you feel that the security of any account you might have with Noluma has been compromised), please immediately notify Noluma of the problem by contacting Noluma in accordance with the “Contacting Noluma” section below.
We will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Statement, to perform a service you have requested, or for which you have given consent, or such longer retention period as is required for our business purposes and applicable law.
CROSS BORDER TRANSFERS
Your Personal Information may be stored and processed in any country where we have facilities or where we have engaged a service provider, and by using Noluma’s Site or App you consent to the transfer of information to countries outside of your country of residence, including to the United States, which may have different data protection rules than in your country. Such transfers are governed by internal Controller to Controller contracts between Noluma legal entities, and through Data Transfer agreements with nonaffiliated third parties.
TRANSFERS OF EU PERSONAL DATA TO THE UNITED STATES
When required, transfers of EU personal data to the U.S. are also protected by Noluma through Privacy Shield certification, or by its use of EU Standard Contractual Clauses when transferring EU personal data to entities and individuals who do not have Privacy Shield certification or a similar EU-compliant data transfer mechanism already in place.
Unless legally required, we ask that you not send Noluma, and you not disclose, any sensitive Personal Information -- information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sex life or sexual orientation -- on or through the Site or App or otherwise to Noluma.
USE OF SITE BY CHILDREN
Noluma is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities. Noluma does not target the Site or the App to children less than thirteen (13) years of age or collect information from children for the purpose of selling products or services. Noluma may participate in select educational programs such as in science and environmental awareness in support of schools and communities.
Your “IP Address” is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in Noluma server log files whenever a user visits the Site.
Noluma uses IP Addresses to monitor site usage and enhance your online experience. When you visit or leave our Services (including our plugins or cookies or similar technology on the sites of others), we receive the URL of both the site you came from and the one you go to next. We also get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device, that device may send us data about your location. Most devices allow you to prevent location data from being sent to us and we honor your settings.
UPDATES TO THIS PRIVACY STATEMENT
We may change or update this Privacy Statement. Please take a look at the revision date on this page to see when this Privacy Statement was last revised. Any changes to this Privacy Statement will become effective when we post the revised Privacy Statement on the Site or App. Your use of the Site or App following these changes means that you accept the revised Privacy Statement.
If you have any questions or requests about this Privacy Statement, please contact Noluma at firstname.lastname@example.org or please write to the following address: Noluma Inquiry Management Center 1007 N Market Street Wilmington, DE 19898 Toll-free: 800-441-9481 E-mail: email@example.com
When contacting, please include the name and the address to which you would like us to respond.
Last revised: June 22, 2018