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BACKGROUND:

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 through Our Nivo mobile application software and Our website (www.nivohub.com) (together the “Platforms” and each a “Platform”).

Nivo is the controller of your personal data when you are using Our Platforms and We respect and value the privacy of everyone who visits or uses any of Our Platforms.

Nivo processes your personal data in order to provide you with the “Services” – our services allow you to contact, communicate and transact with organisations on the Nivo network (we refer to these organisations as our “Clients“) through 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.

Nivo is registered as a data controller with the Information Commissioner’s Office (“ICO“) with registration number: ZA325306.

Please read this Privacy Policy carefully before visiting or using any of Our Platforms and ensure that you understand it.

1. Definitions and Interpretation 

In this Policy, the following terms shall have the following meanings:

Data Protection Laws” means all applicable laws which relate to the processing of personal data and privacy, including: (i) the General Data Protection Regulation (EU) 2016/679 (“GDPR“); (ii) the Data Protection Act 2018; (iii) the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any legally binding guidance and codes of practice issued by the ICO.

“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 michael.common@nivohub.com, or by post at 44 Chapel Lane, Wilmslow, Cheshire, SK9 5HZ.

3. What Does This Policy Cover?

This Privacy Policy applies only to your use of a Platform and explains how We use your personal data.

We will update this Privacy Policy if We make any significant changes affecting how We use your personal data and We will let you know about this change the next time you use any of the Platforms.

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 a number of rights over your personal data under the Data Protection Laws, which this Policy and Our use of personal data have been designed to uphold.

Please click here to read more about your rights

You have the following rights in respect of your personal data.  If you wish to exercise any of your right, please contact Us at info@nivohub.com.

  • Right of access: You can request access to a copy of to the personal data which We hold about you, as well as details about why and how We use it.  You can make a request free of charge;
  • Right to rectification:  You can ask Us to change or complete any personal data We hold about you which is inaccurate or incomplete;
  • Right to be forgotten: You have a 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 paragraph 10 but if you would like Us to delete it sooner, please contact Us using the details in paragraph 14). Please note that there may be situations where We must retain your personal data after a request for erasure where We have a lawful basis for doing so;
  • Right of restriction: You can ask Us to restrict (i.e. prevent) the processing of your personal data where you have objected to Our use of it and We have no lawful basis to continue processing your personal data;
  • Right of data portability:  You can ask Us to provide you or a third party (i.e. to re-use with another service or organisation) with a copy of the personal data which We hold about you in a structured, commonly used, electronic form;
  • Right to object: You can object to Us using your personal data for particular purposes; and
  • Automated decision making: You have a right not to be subjected to automated decision making and profiling in certain situations.

If you have any cause for complaint about Our use of your personal data, please contact Us using the details provided in paragraph 14 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 kinds of personal data do We use?

Depending upon your use of the applicable Platform, We collect and/or process a number of categories of your personal data.

If you have given Us your consent, We will share some of your personal data with Our Clients.  More information about how We share personal data with Clients is set out in paragraph 11.

Please click here for more information about the types of personal data which We use (including personal data which may be shared with Our Clients).

To provide you with the Services, we may process the following personal data:

    • name(s);
    • telephone number(s);
    • date of birth;
    • address(es);
    • 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
    • any other information that you upload or input into the Platform from time to time.

We share the personal data with Our Clients to allow us to deliver the Services through the Platforms.  The personal data which we share for this purpose is set out at: http://www.nivohub.com/what-do-We-share/

Special Category Personal Data

Our Platforms use biometric personal data for authentication purposes, including facial images, fingerprints, and voice recordings.  Biometric personal data is classified as special category personal data and is afforded a higher level of protection under Data Protection Laws.  We will only use special category personal data where you have provided Us with express consent to do so.  You shall be entitled to withdraw your consent at any time by messaging us through the Nivo Support channel.

Log Data

We also collect information when you visit Our website www.nivohub.com.  We collect information that your browser sends whenever you visit Our website (“Log Data”).

Please click here to find out more about Log Data.

The Log Data which We collect includes 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 usage statistics.

In addition, We may use third party services such as Google Analytics that collect, monitor and analyse this data.

6. How do We collect your personal data?

All of the personal data which We use in delivering the Services is obtained:

  • directly from you when you register with Us; and
  • through your use of the relevant Platform.

7. How We use your personal data

We will use your personal data for the following purposes
(Click on the headings below for more information):

To provide you with the Services

The Services which We provide allow you to communicate and transact with organisations on the Nivo network. To provide you with these Services, We use your personal data to allow the organisations to identify you and to undertake the transactions you request of them.

We do not share your personal data with Our Clients until you have authorised such sharing through the Platform.  After sharing your personal data with Our Clients, those Clients shall be a separate controller of your personal data (meaning that they are responsible for making decisions about how they handle and use that personal data).  Information about how any of our Clients process your personal data will be set out in that Client’s own privacy policy.

To send you marketing emails

We shall send you marketing information about Our services where you have given Us your consent to do so.  We will use the contact details which you have given to Us to communicate with you.

Where you have given Us consent to receive marketing, you can withdraw consent, and update your marketing preferences by clicking the “unsubscribe” link at the bottom of any marketing email which We send, or by emailing Us at info@nivohub.com.

Market research and product development

We may collect and use information about how you use the Platforms to allow Us to develop and improve Our products and services.

Statistical analysis

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.

Complaints and enquiries

Where you contact Us to make a complaint or enquiry, We shall process your personal data to allow Us to investigate and resolve your issues.  We will hold personal data relating to complaints for a period of 3 years following resolution of your claim for Our records.

Cookies (please see paragraph 13 below)

8. Automated decision making

We shall not use your personal data in any automated processes to make decisions about you or to create a profile about you.

9. Our legal basis for using your personal data

We only use your personal data where that is permitted by the Data Protection Laws which protect your privacy rights. We only use personal data where:

  1. We have your consent (if consent is needed);
  2. We need to use the personal data to comply with Our legal obligations;
  3. We need to use the personal data to perform a contract with you; and/or
  4. it is fair to use the personal data either in Our interests or someone else’s interests, where there is no disadvantage to you – this can include where it is in Our interests to contact you about products or services, market to you, or collaborate with others to improve Our services.

Where We have your consent, you have the right to withdraw it. We will let you know how to do that at the time We gather your consent.

Special Category Personal Data – Special protection is given to certain kinds of personal data that are particularly sensitive. We use biometric personal data to provide Our Services. We will only use this kind of personal data where you have specifically given Us explicit consent to use that personal data.

10. How long do We keep your personal data for?

We will never retain your personal data for any longer than is necessary for the purposes We need to use it.

We will retain your personal data whilst you have an account for Us.  If you inform Us that you wish to close your account with Us, We will delete your personal data within 30 days from the date on which you inform us that you wish to close your account).

In all cases, We may hold your personal data for longer where We are required to do so by law, or where it is necessary to do so for the management of any active or potential legal proceedings.

11. Who We share your personal data with?

Our Clients – When you choose to communicate with an organisation on the Nivo network, you will consent to share your Nivo identity information. The identity information We share once you have consented can be seen here http://www.nivohub.com/what-do-We-share/. This list of information may be updated over time and this will be visible via this link. As you continue conversations with organisations, you may add or update this information. If that occurs, all of the organisations you have consented to engage previously will be notified of the change in details.

Third party suppliers – 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.

Please click here for more information about the third party suppliers which We share your personal data with to allow Us to provide you with the Services.

We may share your personal data with the following third party suppliers:

Onfido – identity verification services (click here for more information)

We utilise identity verification services provided by Onfido whose privacy practices are described in the Onfido Privacy Policy, available for review and download at onfido.com/gb/privacy.

TrueLayer – sharing information about your bank accounts (click here for more information)

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 subject to UK and EU data protection laws and is required to treat your data in accordance with those laws, as well as the Terms of Service and TrueLayer’s Privacy Policy (https://truelayer.com/privacy).

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).

Twilio – sending and receiving SMS messages (click here for more information)

We utilise services provided by Twilio that allow SMS messages to be sent and received around the world from and to multiple international phone numbers. Twilio’s privacy policu can be seen at https://www.twilio.com/legal/privacy

Amazon Web Services (AWS) – hosting services (click here for more information)

AWS is a cloud platform which We use to host and run the infrastructure that supports the Platforms including the databases that contain the data collected and stored as part of the Platforms (where this is not being provided by another Third party supplier). The AWS privacy policy can be seen at https://aws.amazon.com/privacy/

WordPress – website performance reporting and analytics (click here for more information)

WordPress is a content management system that We use to manage the content on Our website nivohub.com. This also provides Us with tools to understand the usage of the website. The privacy policy for WordPress can be seen at https://en-gb.wordpress.org/about/privacy/

Google Analytics – website performance reporting and analytics (click here for more information)

Google Analytics is a web analytics service We use to track and report on website traffic on Our nivohub.com website. Information on how Google uses this data can be seen here https://policies.google.com/technologies/partner-sites?hl=en-GB&gl=uk

Tools for marketing to prospects (click here for more information)

If We collect your data for the purposes of marketing then We use various tools to store and execute marketing activities. For example We use Customer Relationship Management tools to keep a record of data collected and correspondence had and email marketing services to send out marketing content and record how people engaged with that.

Change of ownership – If the ownership of Nivo changes, We shall share your personal data with the new owner of Nivo to ensure that We are still able to provide you with the Services.

Miscellaneous – 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.

12. Transfers outside of the UK

We may need to transfer your personal data outside the UK to service providers, agents, subcontractors and regulatory authorities in countries where data protection laws may not provide the same level of protection as those in the European Economic Area (“EEA“), such as the USA.

Please click here for more details.

We may need to transfer your personal data to territories that are outside the EEA. We will only transfer your personal data outside the EEA where either:

  1. The transfer is to a country which the EU Commission has decided ensures an adequate level of protection for your personal data, or
  2. We have put in place Our own measures to ensure adequate security as required by data protection law. These measures include ensuring that your personal data is kept safe by carrying out strict security checks on Our overseas partners and suppliers, backed by strong contractual undertakings approved by the relevant regulators such as the EU style model clauses.  Some US providers may also be certified under the EU-US Privacy Shield which confirms they have appropriate measures in place to ensure the protection of your data.

13. Cookies

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.

We use cookies solely to gather information on IP addresses, to analyse trends, administer the website, track your movements on our website and gather broad demographic information for aggregate use.

We are allowed to store cookies on your device if they are strictly necessary for the operation of Our sites. For all other types of cookies We need your permission.

We ask you for consent to use cookies (where consent is required).  You can at any time change or withdraw your consent by adjusting the settings on your device’s browser. You can find guidance on how to do this at www.AboutCookies.org.uk.

If you choose to disable all cookies then some features of our website will not work as expected.

Please click here for more information about the Cookies which We use.

We use the following categories of cookies on Our website:

Strictly necessary: These are cookies which are essential for certain features of our website to work. These cookies do not record identifiable personal information and We do not need your consent to place these cookies on your device. Without these cookies We will be unable to provide all or part of Our Services to you.

Performance monitoring: We use these cookies to collect details on an anonymous basis about how you use Our websites. This information may be used to help Us improve Our websites and understand how effective Our adverts are. In some cases we use trusted third parties to collect this information for Us but they only use the information for the purposes explained.

Functionality: These cookies are used to provide services or remember your settings.  These cookies are aimed at enhancing your user experience by remembering your preferences. The information these cookies collect is anonymous and does not enable us to track your browsing activity on other websites.

Marketing: These cookies are used by trusted third parties to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. Information contained in these cookies is anonymous and doesn’t contain your personal data. To find out more about cookies used for targeting and advertising follow www.youronlinechoices.com and www.networkadvertising.org or contact us for further information about the trusted third parties we use.

14. Data Security

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.

Please click here for information about the steps which We take to secure your personal data.

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; and
  • ensuring your data is encrypted.

15. What Happens If Our Business Changes Hands?

We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.

In the event that any of your data is to be transferred in such a manner, you will 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.  If you wish to exercise any of your rights over your personal data in the event of such a transfer, you must contact Us in the manner set out in paragraph 4 of this Privacy Policy.

16. Contacting Us

If you have any questions about the applicable Platform or this Privacy Policy, please contact Us through the Nivo Support channel in the App, by email at info@nivohub.com, or by post at 44 Chapel Lane, Wilmslow, Cheshire, SK9 5HZ. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you.

17. Changes to Our Privacy Policy

We may change this Privacy Policy from time to time (for example, if the law changes). We recommend that you check this page regularly to keep up-to-date.

If We make any material changes to the manner in which We process and use your personal data, We may contact you to let you know about the change.

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