Ruby IO, Inc., D/B/A/ Nue.io and its affiliates (“Nue.io”, “we”, “our” or “us”) puts great efforts in making sure that the Personal Data (as defined below) processed by us is safe and used properly, and that our data practices are properly communicated to our customers, users and prospects.
- Nue.io User and Customer Data: data relating to the use of our solution or any part thereof (the “Platform”) by customers (or on behalf of customers) (“Customer Users”) or as end users of our Customer Users (“End Users”). This data may include account and activity data relating to individuals who use the Platform as well as data which we analyze, process and manage on our customers’ behalf, in connection with the Platform. Specifically, this is the data contained in e-mails and other communications and content, as well as data submitted by our customers when using the Platform;
- Website and CRM Data: data relating to customers, potential customers and visitors of our websites (Nue.io or any other website in our control, on which this policy is presented), online ads and content, emails or communications under our control (“Websites” and “Visitors” respectively);
- Other Types of Data: Participant Information (as defined below), Applicant Information (as defined below) or any other data or information collected while otherwise interacting with us.
The Website together with the Platform shall be referred to as “the Services”. Customer Users together with End Users shall be referred to as “Users”
- Data Collection and Processing
- Data Uses
- Data Location
- Data Sharing
- Data Location
- Cookies and Tracking Technologies
- Data Security
- Data Subject Rights
- Data Controller/Processor
- Additional Notice and Contact Details
You are not legally required to provide us with any personal data, and may do so (or avoid doing so) at your own free will. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please avoid any interaction with us or use of our Services. If you are a User of the Platform on behalf of any of our customers, we suggest that you contact your account administrator with any questions.
1. Data Collection and Processing
(i) Data from Users and Customers of the Platform: We store and process personal data on behalf of our corporate customers. Our corporate customers use our software-as-a-service products to process personal data at their discretion, including data pertaining to their own customers. Our corporate customers provide information on how they process their customers’ data in their own, separate privacy notices. We support our corporate customers as a data processor but do not know or control their data processing practices.
We also collect and generate the following Personal Data concerning Customer Users of our Platform:
- User account and contact information (e-mail address and, when applicable - hashed password, name, title, team, company, email and phone number (as provided), and additional information and media submitted by Users, their team members or their organization);
- Direct interactions and communications with us (including, in some cases, recordings of your calls and emails with us, e.g., for user enablement, support and training purposes).
(ii) Data automatically collected or generated from the Platform: When you use our Services (including, inter alia, as an End User), we may collect, record or generate certain technical data about you. We do so either independently or with the help of third-party Service Providers (as defined below), including through the use of “cookies” and other technologies (as detailed below).
Such data consists of connectivity, technical and aggregated usage data such as IP addresses and general locations, device data (like type, operating system, device id, browser version, locale and language settings used), date and time stamps of usage, user agent, activity logs, the cookies installed or utilized on such device and the recorded activity (sessions, clicks and other interactions) of Visitors and Users in connection with our Services. In addition, phone calls (e.g., with our customer success or product consultants) may be automatically recorded, tracked and analysed, for purposes including analytics, service-, operations-, and business quality control and improvements, and record-keeping purposes.
(iii) Nue.io Website, CRM and Prospect Data: We collect and generate the following types of Personal Data concerning our Visitors, Participants, customers and prospects –
- Website usage information (connectivity, technical and aggregated usage data, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on the device);
- Customer account information (contact, contractual and billing details concerning our customers, which may also contain the details of their internal focal persons who directly engage with Nue.io concerning their organizational account, e.g., the account administrators, billing contacts and authorized signatories on behalf of the customer; as well as the customer’s needs and preferences, as identified to us or recognized through our engagement with them);
- Data obtained through Analytics Tools: We use analytics tools (e.g., Google Analytics) to collect data about the use of our Website and Services. Analytics tools collect data such as how often Users and Visitors visit or use the Website or Services, which pages they visit and when, and which website, ad or e-mail message brought them there.
- Information concerning our customers and prospects (contact and business details, our communications with such customers and prospects, as well as any needs, preferences, attributes and insights relevant to our potential engagement).
We collect the above categories of data either automatically, through the data subject’s interaction with us or through our Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.
(iv) Job Applications and Participants: (A) We may collect information provided to us by job candidates (“Applicants”) when they apply to a position in our super awesome company (directly, through head hunters or through other service providers). Nue.io welcomes all qualified Applicants to apply to any of the open positions by sending us their contact details and CV (“Applicants Information”). (B) If you participate in an event or webinar that we sponsor or participate in (“Participant”), we may receive your Personal Data from you or from the event organizers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or service provides, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn™ and other data services and sources (“Participants Information”).
2. Data Uses
Nue.io processes User and Customer Data, and any Personal Data contained in it, strictly on the customer’s behalf, in accordance with their reasonable instructions. Nue.io may not be aware of the nature of the information and data collected through the Demo created by our Customer Users. Such information may as sensitive under applicable laws.
We use Personal Data as necessary for the performance of our Services; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services, e.g., in understanding how our Services are used, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Services; providing customer service and technical support; and protecting and securing our customers, Users, Visitors, Participants, Applicants, prospects, ourselves and our Services.
We also use Personal Data of Applicants that apply to a position in our company, in order to evaluate their candidacy. We are committed to keep Applicants Information private and use it solely for our internal recruitment purposes (including for identifying Applicants, evaluating their applications, making hiring and employment decisions, background checks on Applicants and contacting Applicants by phone or in writing).
We do not sell your personal information for the intents and purposes of the California Consumer Privacy Act (CCPA) (to the extent applicable).
Specifically, we use the above categories of data for the following purposes:
- To facilitate, operate, and provide our Services;
- To authenticate the identity of Users, and to allow them access to our Services;
- To provide our Visitors, customers and Users with assistance and support;
- To gain a better understanding on how individuals use and interact with our Website and Services, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Services;
- To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Services, and thereby increase your engagement and overall satisfaction with our Services. This includes contextual, behavioural and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
- To contact our Customers, Users and prospects with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section 7 below);
- To facilitate, sponsor and offer certain events, contests and promotions;
- To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
- To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
- To comply with applicable laws and regulations.
3. Data Location
We and our authorized Service Providers (as defined below) maintain, store and process Personal Data in AWS servers in the United States of America. We may also retain your Personal Data in other locations as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law; provided that User and Customer Data may only be processed in such locations as permitted in commercial agreements with the applicable customer.
4. Data Retention
Use and Customer Data
We retain User and Customer Data strictly on our customer’s behalf, in accordance with their reasonable instructions and applicable laws. We may retain User and Customer Data for as long as your organization's account with us is active; as reasonably necessary for us to provide or offer our Services to you and your organization; or as long as we consider necessary for the purposes described herein.
Any Customer may request information regarding the storage and retention of data (“Audit”) by contacting us. Nue.io shall make reasonable efforts to respond to the Audit in a reasonable time and subject to applicable law and to the protection of Nue.io trade secrets.
Unless otherwise agreed in writing with the Customer, after a request from the Customer to delete any data or termination or expiration of the agreement with the Customer, an automated process will begin that permanently deletes the data in accordance with the timelines set forth in the tables below. Once initiated, this process cannot be reversed and data will be permanently deleted.
|Database Backups||30 Days|
|Platform logs||90 Days|
|Communications regarding requests for data deletion||7 Years|
However, some data will not be deleted and shall be kept in an anonymized manner. Some metadata and statistical information concerning the use of the Service are not subject to the deletion procedures in this policy and may be retained by Nue.io. Some data may also be retained on our third-party service providers’ servers until deleted in accordance with their deletion policy.
Other Types of Data
We may retain Visitor and Participant Personal Data for as long as reasonably necessary in order to maintain and expand our relationship and to provide them with our Services.
Notwithstanding the aforementioned, we will also retain Personal Data for as long as is required in order to comply with our legal and contractual obligations, or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), in accordance with our data retention policy.
We may retain Applicants Information submitted to us in connection with a job position, even after the applied position has been filled or closed so we can re-consider Applicants for other positions and opportunities and in case the Applicant is hired, for additional employment and business purposes related to his/her work. If you previously submitted your Applicants Information to Nue.io, and now wish to access it, update it or have it deleted, please contact us at firstname.lastname@example.org.
We retain all other Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at email@example.com.
5. Data Sharing
Legal Compliance: In exceptional circumstances, and except as stipulated otherwise in the commercial agreements with you, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our products and services.
Service Providers: We may engage with selected third-party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session or activity recording services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). For a full list of third parties, please contact us at Privacy@nue.io.
To the extent applicable, our Service Providers shall each be deemed as a ‘data processor’ or ‘service provider’ in circumstances where Nue.io assumes the role of ‘data controller’; and where Nue.io acts as the ‘data processor’ or ‘service provider’ for our customer, the Service Provider shall be deemed as our ‘sub-processor’ or ‘service provider’ (as further described in Section 10 below).
Accordingly, these Service Providers may have access to data concerning Users, Visitors, Participants, customers and/or prospects; Service Providers access to data shall depend on each of their specific roles and purposes in facilitating and enhancing our Services. Service Providers may only use the data for such limited purposes as determined in our agreements with them. In addition, Service Providers may only have access to User and Customer Data if we have expressly listed them in our Sub-Processor List.
Sharing Personal Data with End Users: User and Customer Data is shared and available to the End Users as part of the Demo created by the applicable customer. This means that the End Users of such customer may access the User and Customer Data that was uploaded and used in the Demo, and will be able to monitor, and possibly process and analyse the Personal Data contained therein.
Please note that Nue.io is not responsible for and does not control any disclosure, use or monitoring by or on behalf of the customers, that itself acts as the ‘data controller’ of such data (as further described in Section 10 below).
Protecting Rights and Safety: We may share Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Nue.io, any of our Users or customers, or any members of the general public.
For the avoidance of doubt, Nue.io may share data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
6. Cookies and Tracking Technologies
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We may use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services’ features and tools.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Services.
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
We may engage in service and promotional communications, through e-mail, phone, SMS and notifications.
Service Communications: We may contact you with important information regarding our Services. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, log-in attempts or password reset notices, etc. Customer Users may also send notifications, messages and other updates to End Users regarding their or the End Users use of the Services. Please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
Promotional Communications: We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable, as our customer, User, Participant or prospect. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or email), through the Services, or through our marketing campaigns on any other sites or platforms.
if you do not wish to receive such promotional communications, you may notify Nue.io at any time by sending an e-mail to: privacy@Nue.io, or by following the “unsubscribe”, “stop”, “opt-out” or “change email preferences” instructions contained in the promotional communications you receive.
8. Data Security
We and our hosting services implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information.
However, although we make efforts to protect your privacy, we cannot guarantee that our Sites, Platform or Services will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
To learn more, please visit privacy@Nue.io.
9. Data Subject Rights
Individuals may have rights concerning their Personal Data. If you wish to exercise your privacy rights under any applicable law, such as the right to request access to, and rectification or erasure of your Personal Data held with Nue.io, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at privacy@Nue.io.
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request), in accordance with Section 4 above.
We may redact from the data which we will make available to you, any personal data related to others.
If you would like to make any requests or queries regarding Personal Data that we process on our customer’s behalf, please contact the administrator of such customer’s account directly. For example, if you are our customer’s End User or prospect, or if you are a Customer User, and wish to access, correct, or delete data processed by Nue.io on behalf of our customer, please direct your request to the relevant customer (who is the “data controller” of such data – see Section 10 below). Note that if you do contact us, we may share your communications with our customer; and that we may also share the contact details of the account administrator with individuals who sent us such a request or query relating to this account.
10. Data Controller/Processor
Certain data protection laws and regulations, such as the GDPR or the CCPA, typically distinguish between two main roles for parties processing Personal Data: the “data controller” (or under the CCPA, “business”), who determines the purposes and means of processing; and the “data processor” (or under the CCPA, “service provider”), who processes the data on behalf of the data controller (or business). Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Nue.io is the “data processor” or ‘service provider’ of Customer Data, which we process on behalf of our customer (who is the “data controller” of such data); and our Service Providers who process such User and Customer Data on our behalf are the “sub-processors” of such data.
Accordingly, Nue.io processes User and Customer Data strictly in accordance with such customer’s reasonable instructions and commercial agreements with such customer. The customer, as controller of such data, will be responsible for meeting any legal requirements applicable to data controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
For the avoidance of doubt, each customer is solely responsible for providing adequate notice to its End Users, customers and any other individual whose data may be contained in User and Customer Data – including sufficient reference to the processing of their Personal Data via the Services, and any other information necessary to comply with all applicable privacy and data protection laws; and to obtain all approvals and consents from such individuals as required under such laws.
11. Additional Notices
Our Services are not designed to attract children under the age of 18: We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 18 is using the Sites, Platform and/or Services, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such a child. If you believe that we might have any such data, please contact us by e-mail at firstname.lastname@example.org.
Effective Date: December 6, 2021