ABOUT THIS DOCUMENT

This Privacy Notice will help you understand how we collect, use and protect your personal information when you use our websites  (https://nubessom.com – collectively, ‘Our Sites’), our mobile device application (the ‘App’) or if we receive your personal information for recruitment purposes.

WHO WE ARE AND CONTACT DETAILS

Nubessom Consulting (“Nubessom”) is a company registered in Pod Děkankou 6, 140 00 Praha 4-Nusle, Czech Republic.

Nubessom has overall responsibility for the processing of your personal information. This means that we are a ‘data controller’ under the General Data Protection Regulation (also known as the GDPR).  If you have any queries about this Privacy Notice or how we process your personal information, please contact us by email: info@nubessom.com.

WHAT INFORMATION WE COLLECT ABOUT YOU

The personal information we might collect about you includes:

  1. name, date of birth and gender (in case you submit a contact form);
  2. identification document details (in case you submit a contact form);
  3. contact details, including address, telephone number and email address (in case you submit a contact form);
  4. identifiers assigned to your computer or other devices, including your Internet Protocol (IP) address (in case you visit our website and accept our cookie notice).

Furthermore, by using Our Sites and/or our App, Cookies may be stored on your devices. You can find further information on Cookies below, under the title ‘Cookies and Web Beacons’.

Special categories of personal data

Nubessom does not intentionally collect any special categories of personal data (sensitive personal information) via Our Sites or App unless in a specific country we are legally required to do so, for example, for recruitment purposes. Sensitive personal information includes: information revealing racial or ethnic origin; political opinions; religious or philosophical beliefs; trade union membership; the processing of genetic or biometric data for the purpose of uniquely identifying a natural person; information concerning health; information concerning a natural person’s sex life or sexual orientation; and in some cases, social security numbers or financial information.

Security

Nubessom works to protect the confidentiality and security of the information it obtains in the course of its business. Access to such information is limited and policies and procedures are in place, designed to safeguard the information from loss, misuse and improper disclosure.

HOW WE COLLECT INFORMATION ABOUT YOU

Most of the personal information we hold about you is collected directly from you. We do this for example, when you:

  1. visit Our Sites and register to receive information from us or sign up to our newsletter;
  2. download e-books and other information from Our Sites;
  3. contact us directly, either via our call centre, by email or social media;
  4. register with us for recruitment and vacancy updates;
  5. apply for a vacancy on Our Sites;
  6. respond to communications or surveys;
  7. visit Our Sites and apply for a prepaid product;
  8. start an application for a prepaid product but fail to complete it;
  9. make enquiries or raise concerns with our customer service team;
  10. use our App;
  11. accept the use of Cookies.

We will also collect information about you if you get in touch through one of our external partners (for instance, if you apply for a job vacancy using a third party provider, such as a recruitment agency).

In order to understand more about you and to verify your identity, we may supplement and combine the personal information that we collect from you with other categories of data obtained from other sources.

We may change or add to these from time to time and the changes will be updated on our Privacy Notice.

WHAT WE USE YOUR INFORMATION FOR AND REASONS FOR PROCESSING

Using your personal data for marketing

We may also use your personal information to send you newsletters and/or marketing about similar products and services by post, email, text message, and through various digital channels, such as social media platforms, if you have expressly consented to this or as is necessary for our legitimate interests. We consider that it is within our legitimate interests to send you information about our own products and services for marketing purposes.

You can object to receiving marketing from us at any time – please follow the unsubscribe link in our marketing emails or text message; or send us your name, address and date of birth via email to info@nubessom.com.

We also use the personal data you provide to us, information about you provided for third parties (please see “How we collect information about you” for further details), and of individuals who have similar characteristics to you, to enable us to evaluate and predict your behaviour to assist us to provide and improve our products and services.

HOW LONG IS YOUR INFORMATION KEPT?

Nubessom only ever retains personal information for as long as is necessary and we have strict review and retention policies in place to meet these obligations. Unless specifically mentioned otherwise, we keep your personal data (name, address, contact details) for a minimum of 6 years after which time it will be destroyed.

Where you have consented to us using your details for direct marketing, we will keep such data until you notify us otherwise and/or withdraw your consent.

We may retain some of your personal information for a number of purposes, as necessary to allow us to carry our business. The retention periods apply as follows:

  1. For sales purposes:
    Contact details of unsuccessful leads/deals may be stored in line with our Data Retention Policy for consideration for future contacts.
  2. For hiring purposes:
    CVs of unsuccessful candidates may be stored in line with our Data Retention Policy for consideration for future vacancies.

COOKIES AND WEB BEACONS

Our Sites and App use Cookies, Web Beacons and other web technologies such as CAPTCHA’s, as applicable, to improve their performance and to enhance your browsing experience. These technologies will help us track and monitor your engagement and usage of Our Sites and App, to understand more about you, so we can offer you a more personalised browsing experience.

Cookies

We may place small data files on your access device. These data files may be cookies or other local storage provided by your browser or associated applications (collectively, “Cookies”). We use Cookies to recognise you as a customer, customise our services, content and advertising, measure promotional effectiveness, help ensure that your account security is not compromised, mitigate risk and prevent fraud, and to promote trust and safety across our Sites and services.

What Cookies do we use?

The Cookies used by Our Sites or App can be:

  1. Transient (or per-session) Cookies – these only exist for your site visit and are deleted on exit. They recognise you as you move between pages, for example, recording items added to an online shopping basket. These Cookies also help maintain security.
  2. Persistent (or permanent) Cookies – these stay on your machine until expiry or deletion. Many are built with automatic deletion dates to help ensure your hard drive does not get overloaded. These Cookies often store and re-enter your log-in information, so you don’t need to remember membership details.

We use both types of Cookies.

Additionally, Cookies can be first or third party Cookies. First-party Cookies are owned and created by the website you’re viewing. Third-party Cookies are owned and created by an independent company, usually a company providing a service to the website owners. These Cookies collect information relating to the origin of your visit, where you were exposed to Nubessom advertising, what advertising feature you saw, whether you arrived directly or indirectly to Our Sites, the device you used to visit Our Sites or use our App and which downloads you performed. This information is collected via the below third parties:

  1. Google Analytics/Google Ads
  2. Facebook
  3. LinkedIn Ads

How do I disable Cookies?

You are free to decline our Cookies if your browser or browser add-on permits it, unless our Cookies are required to prevent fraud or ensure the security of Our Sites and App. However, declining our Cookies may interfere with your use of Our Site/App and services. To enable or disable cookies, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” facility). Alternatively, an external resource is available at www.allaboutcookies.org/manage-cookies providing specific information about cookies and how to manage them to suit your preferences.

Web Beacons

We use small graphics (also called tracking pixels or clear GIFs – collectively, “Web Beacons”) in Our Sites, App or emails which remain invisible to you but provide us with information about your experience and interaction with Our Sites, App and emails such as which browser has been used, if an email was opened and similar. As part of our effort to track the success of our advertising campaigns, we may at times use visitor identification technology such as these “web beacons” which count visitors who have come to Our Sites after being exposed to a Nubessom banner ad on a third party site. Web Beacons often work in conjunction with Cookies. No personally identifiable or sensitive personal data is collected via Web Beacons.

By navigating on Our Sites or using our App, you agree that we can place Cookie and Web Beacons on your computer or device, as applicable. If you prefer not to receive Cookies or Web Beacons, then you should consult your browsing settings or stop using Our Sites.

YOUR RIGHTS

According to data protection legislation you have the right to:

  1. obtain access to, and copies of, the personal information that we hold about you;
  2. require that we stop processing your personal information if the processing is causing you damage or distress;
  3. ask us not to send you marketing communications;
  4. ask us to erase your personal information;
  5. ask us to restrict our data processing activities;
  6. receive from us the personal information we hold about you which you have provided to us, in a structured, commonly used and machine-readable format, including for the purpose of you transmitting that personal information to another data controller; and
  7. require us to correct the personal information we hold about you if it is incorrect.

Please note that these rights may be limited by data protection legislation, and we may be entitled to refuse requests where exceptions apply.

COMPLAINTS

If you are concerned about an alleged breach of privacy law or any other regulation by Nubessom, please contact us by email at info@nubessom.com.

If you are not satisfied with the way in which Nubessom has resolved your complaint, you have the right to complain to the CNPD or the data protection authority in your country. You can find out more about your rights under data protection legislation from the CNPD’s website.

CHANGES TO THIS PRIVACY NOTICE

We may update this notice from time to time by publishing a new version on Our Sites. You should check this page occasionally to ensure you are happy with any changes. If the changes are substantial, we may notify you of changes to this notice by email.

iIf you have any questions or concerns about this Privacy Notice, please contact us at info@nubessom.com.