Nivo Solutions Limited (CRN: 10744928) understands that your privacy is important to you and that you care about how your personal data is used and shared online (including our website www.nivohub.com), through our Nivo mobile application software (the “Platforms” and each a “Platform”).
We respect and value the privacy of everyone who visits or uses any of our Platforms.
The Platforms will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Data Protection Laws” means (i) all applicable law about the processing of personal data and privacy, and (ii) the Data Protection Act 1998, the EU Data Protection Directive 95/46/EC, the Regulation of Investigatory Powers Act 2000, the Telecommunications (Lawful Business Practice) (Interception of Communications) Regulations 2000 (SI 2000/2699), the Electronic Communications Data Protection Directive 2002/58/EC, the Privacy and Electronic Communications (EC Directive) Regulations 2003 including if applicable legally binding guidance and codes of practice issued by the Information Commissioner; and (iii) to the extent that it relates to processing of personal data and privacy, any Laws that come into force which amend, supersede or replace existing Laws including the General Data Protection Regulation (“GDPR”), the (LED Law Enforcement Directive (Directive (EU) 2016/680) and any applicable national implementing Laws as amended from time to time including the Data Protection Act 2018 (subject to Royal Assent).
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via The applicable Platform. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Laws; and
“We/Us/Our” means Nivo Solutions Limited (CRN:), a limited company registered in England under company number 10744928, whose registered office is at 44 Chapel Lane, Wilmslow, Cheshire, England, SK9 5HZ
2. Information About Us
Each Platform is owned and operated by Us.
Our Data Protection Representative is Michael Common, and can be contacted by email at email@example.com, or by post at 44 Chapel Lane, Wilmslow, Cheshire, SK9 5HZ.
3. What Does This Policy Cover?
The applicable Platform may contain links to other websites. Please note that We have no control over how your data is collected, stored, or used by other websites or software applications, and We advise you to check the privacy policies of any such websites or software platforms before providing any data to them.
4. Your Rights
As a data subject, you have the following rights under the GDPR, which this Policy and Our use of personal data have been designed to uphold:
The right to be informed about Our collection and use of personal data;
The right of access to the personal data We hold about you (see clause 12);
The right to rectification if any personal data We hold about you is inaccurate or incomplete (please contact Us using the details in clause 13);
The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you (We only hold your personal data for a limited time, as explained in clause 6 but if you would like Us to delete it sooner, please contact Us using the details in clause 13);
The right to restrict (i.e. prevent) the processing of your personal data;
The right to data portability (obtaining a copy of your personal data to re-use with another service or organisation);
The right to object to Us using your personal data for particular purposes; and
Rights with respect to automated decision making and profiling.
If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in clause 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office.
For further information about your rights, please contact the Information Commissioner’s Office or your local Citizens Advice Bureau.
5. What Data Do We Collect?
Depending upon your use of the applicable Platform, We may collect and/or process some or all of the following personal and non-personal data:
- telephone number(s);
- date of birth;
- social media usernames;
- email addresses;
- data on the identity and verification process that you have been through;
- your financial information (including account transaction information);
- a copy of your photo identity document and a video selfie with associated data to determine authenticity;
- notes relevant to your identity; and
- all other information that you upload or input into the Platform from time to time.
5.1 Log Data
When using our website www.nivohub.com, like many websites, we collect information that your browser sends whenever you visit our Site (“Log Data”).
This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages and other statistics.
In addition, we may use third party services such as Google Analytics that collect, monitor and analyze this data
Cookies are files with small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer’s hard drive.
Like many websites, we use “cookies” to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website www.nivohub.com.
6. How Do We Use Your Data?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Laws at all times. For more details on security see clause 7, below.
Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
- supplying Our services to you (please note that We require your personal data in order to enter into a contract with you);
- personalising and tailoring Our services for you; or
- any combination of the above.
You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for the following periods (or its retention will be determined on the following bases):
We will retain your data for as long as you have a Nivo account setup
7. How and Where Do We Store Your Data?
We only keep your personal data for as long as We need to in order to use it as described above in clause 6, and/or for as long as We have your permission to keep it.
Your data will only be stored within the European Economic Area (the “EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through the applicable Platform.
Steps We take to secure and protect your data include:
ensuring your data is always behind 2-factor (or better) authentication
vetting all institutions that come into our network to ensure we are engaging appropriate representatives of those institutions
ensuring your data is encrypted
8. Do We Share Your Data?
We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payments, authentication and identification of you, and to obtain further information about you. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
We may compile statistics about the use of the applicable Platform including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
We use a tool provided by TrueLayer Limited (www.truelayer.com) (“TrueLayer”) that allows you to send information on your payment accounts to us and other service providers.
In order to use our services, you will be asked to enter your payment account details with TrueLayer and agree to their Terms of Service. The Terms of Service set out the terms on which you agree to TrueLayer accessing information on your payment accounts for the purposes of transmitting that information to us.
TrueLayer is authorised by the UK Financial Conduct Authority under the Payment Services Regulations 2017 to provide account information services and payment initiation services (Firm Reference Number: 793171 ).”
9. What Happens If Our Business Changes Hands?
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. When contacted you will not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
Without prejudice to your rights under the Data Protection Laws, when you submit personal data via the applicable Platform, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details).
You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (the “TPS”), the Corporate Telephone Preference Service (the “CTPS”), and the Mailing Preference Service (the “MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. Your Right to Withhold Information
You may access certain areas of the applicable Platform without providing any data at all. However, to use all features and functions available on the applicable Platform you may be required to submit or allow for the collection of certain data.
12. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Depending on the applicable Data Protection Laws, a fee may be payable. Please contact Us for more details at firstname.lastname@example.org, or using the contact details below in clause 13.
13. Contacting Us