1. Introduction
NUDGEIT AG (“NUDGEIT”, “We”) is committed to protecting and respecting your privacy. This policy (together with our Website Terms and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data.
The use of the NUDGEIT website is possible without any need for you to provide personal data; however, if you would like us to contact you or to provide you with services, processing of personal data might be necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we obtain consent from you.
The processing of personal data, such as your name, address, e-mail address, or telephone number always complies with the General Data Protection Regulation (GDPR) and any the country-specific data protection regulations that may apply. By means of this data protection declaration, NUDGEIT sets out the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, individuals are informed about the rights to which they are entitled.
As the data controller, we have implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions might experience security gaps, so absolute protection cannot be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
2. Who Is Responsible for Data Processing and How Can I Contact Them?
In relation to any personal data about you which you provide to us, the data controller is NUDGEIT AG of Rütistrasse 3, 5400 Baden, Switzerland. You reach us at: info@nudgeit.com.
3. Information we may collect from you
a) Information about the collection of Personal Data when you visit our website Anyone may visit the public areas of the NUDGEIT website without disclosing personal data apart from the IP address of your computer. Such information is only requested by NUDGEIT if we need it to provide services to you or to fulfill requests you may have, such as registering, ordering documents, subscribing to a newsletter, registering for an event, etc.
When you use our website for informational purposes, only, and for as long as you do not provide us with any information about you, then we only collect data that is technically necessary for us to show you our website and to ensure its stability and security (legal basis is Art. 6 (1) (f) GDPR). Such data are:
• IP address of the accessing computer.
• Date and time of retrieval.
• URL of the retrieved page. • Status message as to whether the retrieval was successful.
• Transmitted amount of data. • The referrer URL from which the user came to the retrieved page.
• HTTP user agent information (i.e. information about the accessing device, its operating system, and its browser). • Information stored in Cookies we set.
• Log files we have created to be able to describe an event that has occurred during your visit (e.g. acceptance of Terms of Use).
b) Information about the collection of Personal Data when you register on our website
If you want to enjoy content on our website tailored for you, you must register to gain access to a secure area of the website. The content and applications in the secure area are selected according your account settings and access rights.
The Personal Data we collect within the secure area may include the following, depending on what you have provided:• Name and Contact Details (first name, last name, email address, postal address).
• Registration Information (preferences, participation details of an event, food requests, special assistance requests for an event, event ticket prices and payment methods).
• Geographical Data (information about where you are located, such as country, city, postal code).
• Payment Data (payment details such as billing address, payment method and payment status).
• Interests and Preferences (your interests and preferences related to our products and solutions and what you have downloaded from www.nudgeit.com).
The purpose of collecting Personal Data in the secure area is to allow you to influence the content we serve you with by reflecting your own personal needs and preferences. In addition, you enable us to provide you with information on specific topics via your preferred channel (website, email, postal, phone), if you have opted to receive such information. Our objective is to make it easier for you to engage and interact with our products and solution portfolios, receive offerings, and purchase products via the NUDGEIT website.
According to Art. 6(1)(b) GDPR the processing of your data is necessary for fulfilling a contract with us or for carrying out pre-contractual measures, since without this we cannot conclude the contract or take pre-contractual measures.
c) Information about the collection of Personal Data when you email us or fill in a form
When you contact us by e-mail, through a form on our website (such as the registration form to participate in an event, or to download a publication), or through other areas on the website, the information you provide (your e-mail address and, if applicable, your first name and last name, plus information explicitly asked for, or further information you provide us with) will be stored by us to answer your questions, to process transactions that you have requested, to pass on information about NUDGEIT products and solutions (legal basis is Art. 6(1)(b) GDPR).
d) Information about the use of Personal Data when we choose Custom Audiences on third-party sites
We sometimes define Custom Audiences to deliver advertisements to Website Visitors on third-party sites (mainly social media sites, e.g. Facebook, LinkedIn, etc.) based on email addresses that we have collected. For example, on Facebook we use Facebook Custom Audiences and on LinkedIn we use Matched Audiences. On these social media websites, we sometimes can Identify information about you, such as demographic and other information, such as your academic title, industry, or organization, to improve our marketing efforts. You will learn more about these programs under the following links:
• Facebook Custom Audiences
• LinkedIn Matched Audiences
Information we receive from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, analytics providers, search information providers) and may receive information about you from them.
NUDGEIT uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse and allows us to improve the website. For detailed information on the cookies we use and the purposes for which we use them see our Cookies Policy.
4. How we use your information
We use information held about you in the following ways:
• Information you give to us. We use this information
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by e-mail with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, we will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, please tick the relevant box situated on the form on which we collect your data during the sign-up process;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
• Information we collect about you. We use this information• to administer the website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve the website to ensure that content is presented in the most effective manner for you and for your computer;
• to allow you to participate in interactive features of the service, when you choose to do so;• as part of our efforts to keep the website safe and secure;• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of the website about goods or services that may interest you or them.
• Information we receive from other sources. We may combine this information with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).
5. Disclosure of your information
We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.We may share your information with selected third parties including:
· Business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you.
· Analytics and search engine providers that assist us in the improvement and optimization of the website.
We may disclose your personal information to third parties:
· In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
· If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms or Terms of Service and other agreements; or to protect the rights, property, or safety of NUDGEIT, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6. Data protection provisions about the application and use of LinkedIn
NUDGEIT uses integrated components of LinkedIn on our website.
LinkedIn is a web-based social network that enables users with existing business contacts to connect and to make new business contacts. Over 400 million registered people in more than 200 countries use LinkedIn. Thus, LinkedIn is currently the largest platform for business contacts and one of the most visited websites in the world.
The operating company of LinkedIn is LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, United States of America. For privacy matters outside of the United States of America, LinkedIn Ireland, Privacy Policy Issues, Wilton Plaza, Wilton Place, Dublin 2, Ireland, is responsible.
With each call-up to one of the individual pages of the NUDGEIT website on which a LinkedIn component (LinkedIn plug-in) is integrated, your browser is automatically prompted to download a display of the corresponding LinkedIn plug-in. Further information about the LinkedIn plug-in is available at https://developer.linkedin.com/plugins. The result is that LinkedIn gains knowledge of what page of our website you visit.
If you are logged in at the same time to the LinkedIn website, LinkedIn detects what specific sub-pages of our Internet page you visit. This information is collected through the LinkedIn component and associated with your LinkedIn account. If you click on one of the LinkedIn buttons integrated on our website, then LinkedIn assigns this information to your personal LinkedIn user account and stores the personal data.
LinkedIn receives information via the LinkedIn component when you visit our website if you are logged into LinkedIn at the same time. This occurs regardless of whether you click the LinkedIn button or not. If you wish to prevent the transmission of information to LinkedIn, then you should sign out of LinkedIn using the NUDGEIT website.
LinkedIn provides settings to unsubscribe from e-mail messages, SMS messages and targeted ads, as well as the ability to manage ad settings. LinkedIn also uses affiliates such as Eire, Google Analytics, BlueKai, DoubleClick, Nielsen, Comscore, Eloqua, and Lotame. The setting of such cookies may be denied under https://www.linkedin.com/legal/cookie-policy. The applicable privacy policy for LinkedIn is available under https://www.linkedin.com/legal/privacy-policy. The LinkedIn Cookie Policy is available under https://www.linkedin.com/legal/cookie-policy
7. Data protection provisions about the application and use of Twitter
Twitter is a multilingual, publicly-accessible microblogging service on which users may publish and spread so-called ‘tweets,’ e.g. short messages, which are limited to 280 characters. These short messages are available for everyone, including those who are not logged on to Twitter. The tweets are also displayed to so-called followers of the respective user. Followers are other Twitter users who follow a user’s tweets. Furthermore, Twitter allows you to address a wide audience via hashtags, links or retweets.
The operating company of Twitter is Twitter, Inc., 1355 Market Street, Suite 900, San Francisco, CA 94103, UNITED STATES.
We have integrated a Twitter component in our website. The purpose of the Twitter component is to allow visitors to tweet content from our website and share that content with their followers and the wider digital world. With each call to a page in the NUDGEIT site, your browser is automatically prompted to download a display of the corresponding Twitter component. Further information about the Twitter buttons is available online. The Twitter component tells Twitter what pages you visit on our site.
If you are logged in at the same time on Twitter, Twitter learns what pages you visit on our site. This information is collected through the Twitter component and associated with your Twitter account. If you click on one of the Twitter buttons integrated on our website, then Twitter assigns this information to your personal Twitter user account and stores the personal data.
Twitter receives information via the Twitter component that you visited our website, if you are logged in on Twitter at the time. This occurs regardless of whether you click on the Twitter component or not. If such a transmission of information to Twitter is not desirable, then you can prevent this by logging off from their Twitter account before accessing our website. The applicable data protection provisions of Twitter are available online.
8. Data protection provisions about the application and use of Facebook
NUDGEIT uses integrated components of Facebook on our website.
Facebook is a social network. A social network is a place for social meetings on the Internet, an online community, which usually allows users to communicate with each other and interact in a virtual space. A social network may serve as a platform for the exchange of opinions and experiences or enable the Internet community to provide personal or business-related information. Facebook allows social network users to include the creation of private profiles, upload photos, and network through friend requests.
The operating company of Facebook is Facebook, Inc., 1 Hacker Way, Menlo Park, CA 94025, United States. If a person lives outside of the United States or Canada, the controller is the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland.
NUDGEIT has integrated a Facebook component into our website. When you visit a page on the site, the Facebook plug-in makes Facebook aware of the visit. You can read an overview of Facebook plug-ins online.
If you are logged in at the same time on Facebook, Facebook detects what pages you visit. This information is collected through the Facebook plug-in. If you click on one of the Facebook buttons integrated into our website, e.g. the “Like” button, or if you submit a comment, Facebook matches this information with your personal Facebook user account and stores the personal data.
Facebook always receives, through the Facebook plug-in, information about your visits to our website if you are logged in at the same time to Facebook during that visit. This occurs regardless of whether you click on the Facebook component or not. If you do not want this data to be sent to Facebook, then you can prevent this by logging off from your Facebook account before you visit our website.
The data protection guideline published by Facebook provides information about the collection, processing and use of personal data by Facebook. In addition, it explains what setting options Facebook offers to protect your privacy. In addition, different configuration options are made available to stop data transmission to Facebook.
9. Data protection provisions about the application and use of YouTube
NUDGEIT uses integrated components of YouTube on our website. YouTube allows us to share videos about our products and other topics with you without charge.
The operating company of YouTube is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, UNITED STATES. The YouTube, LLC is a subsidiary of Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043-1351, UNITED STATES.
Calls to website pages where YouTube is integrated prompts the transmission of information to YouTube. You can find information about YouTube online.
If you are logged in on YouTube when you visit our website, YouTube recognizes visits to pages with the integrated YouTube component and records that information, which is collected by YouTube and Google and associated with your YouTube account, if you are logged into YouTube at the time. This occurs regardless of whether you click on a YouTube video or not. If you do not want to share this information with YouTube and Google, you should sign out of your YouTube account before accessing our website. YouTube’s data protection provisions provide information about the collection, processing and use of personal data by YouTube and Google.
10. Storage of Your Personal Data
a) Retention of Your Personal Data
To offer you the best customer experience, we store the Personal Data provided by you during your interactions with NUDGEIT.
We delete data after the storage is no longer required. For tracking information acquired through our Newsletters see below (“Newsletter Tracking”), we may need to keep data beyond that period if statutory retention rules require us to do so. In such scenarios, we will restrict the processing to what is needed to fulfill the statutory retention rules. For data retention in the context of our use of Google Analytics see below (“Google Analytics”).
Personal Data provided to NUDGEIT by you online may be linked to information passed on to NUDGEIT when services or products are ordered.
b) Where we store your personal data
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA”). Where we transfer data outside of the EEA we always ensure that we comply with EU Data Protection legislation including ensuring that your data is handled by Safe-Harbour Certified providers. The data may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services. By submitting your personal data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy.
All information you provide to us is stored on our secure servers. Any payment transactions are encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
c) Deletion of Your Personal Data
NUDGEIT will provide you with information about what Personal Data of yours we store. You can get information about your stored data at any time free of charge, and you may at any time assert your right to correct incorrect information, or to delete your data. If you wish to do so, please contact our Data Protection Officer at info@nudgeit.com.
d) Security Measures we Apply When Holding Your Data
Taking into account the current state of computer technology, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and severity for the rights and freedoms of natural persons NUDGEIT makes appropriate effort to protect Personal Data against accidental and illegal destruction and loss. NUDGEIT endeavors to ensure that Personal Data is used in a proper manner and to protect it from unauthorized access,use, or disclosure. We use a combination of process, technology and physical security controls to help protect personal information from unauthorized access, use, or disclosure.
Access to personal information is restricted to those employees, contractors, and agents of NUDGEIT who need to know such data to perform their assigned functions and develop or improve our products and services.
11. Your rights as a Data Subject
You have the right to access according to Art. 15 GDPR, rectification according to Art. 16 GDPR, erasure according to Art. 17 GDPR, restriction of processing according to Art. 18 GDPR, and – if applicable – data portability according to Art. 20 GDPR.
Where we use your Personal Data based on Art. 6(1)(f) GDPR you further have the right to object against our use of your Personal Data. We shall no longer process such Personal Data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms. If you want to exercise your right to object in such a scenario, please contact us at: info@nudgeit.com.
Where we process your Personal Data on the basis of your consent you can revoke that consent at any time. The revocation does not affect the legality of the processing carried out on the basis of the consent prior to the revocation. If you want to withdraw your consent, please contact us at: info@nudgeit.com.
For your safety and ours, we may need to authenticate your identity before fulfilling your request.
Furthermore, if applicable on you, there is also a right to lodge a complaint with an appropriate data privacy regulatory authority (Article 77 GDPR).
12. To What Extent Is There Automated Decision-Making?
We generally do not use any automated decision-making pursuant to Article 22 GDPR. If we use this procedure in individual cases, we will inform you of this separately, as long as this is a legal requirement.
13. Changes to our privacy policy
Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy.
14. Your Personal Data in NUDGEIT Marketing and Promotion Activities
a) General
In addition to the processing of your Personal Data for purchasing reasons, we may use your information for the following marketing purposes (legal basis is Art. 6(1)(f) GDPR):
• Sending interest-related newsletters • Inviting you to attend events and webinars • Informing you about the latest product and software releases, product recommendations, market trends/insights and promotions • Inviting you to participate in surveys in order to help us to improve our communication and communication platforms • Provide you with emails containing updates about technical developments and similar information.
Sometimes, we may ask you for your consent with respect to our marketing and promotional endeavors (legal basis then is Art. 6(1)(a) GDPR).
b) Opting-out from Our Communications
You can always unsubscribe from any or all NUDGEIT marketing or promotional communications by clicking the ‘Unsubscribe’ link in the communication Your request will be processed immediately. You then will automatically be unsubscribed from all further informative communications such as events, webinars, products and solutions, product release highlights etc. (except if you limit your opting-out to specific categories of messages). You can also object against such use of your Personal Data by contacting us at: info@nudgeit.com.
Where we process your Personal Data on the basis of your consent you can revoke that consent at any time. The revocation does not affect the legality of the processing carried out on the basis of the consent prior to the revocation. If you want to withdraw your consent, please contact us at: info@nudgeit.com.
You can always change your preferences by clicking ‘Manage my Preferences’ in any marketing communication you receive.
c) Newsletter Tracking
When sending out newsletters we use so-called web beacons or tracking pixels. A web beacon or a tracking pixel is a one-pixel image file embedded within the newsletter message, served to you from a remote server when you open the newsletter message. We use these to evaluate your user behavior. For this, the data mentioned in the section “Areas of the NUDGEIT Website” and the following information are linked to your e-mail address and an individual ID: (i) email delivered or not; (ii) email opened or not; (iii) timestamps; (iv) links clicked; (v) content viewed. This data is used to create a user profile to better align the newsletter with your interests. This data will also be linked to your activities on our website. We use this data to what extent our offerings are of interest to you.
The information collected in this way will be stored by us as long as you have subscribed to the newsletter. Once you log out, it will be stored statistically and anonymously.
You have the possibility to opt-out from such tracking at any time, if so inform us at info@nudgeit.com or use other methods we provide within the newsletter email.
15. Google Analytics
To constantly improve and optimize our NUDGEIT product and service offerings, we use web tracking technologies. For this we use Google Analytics, a Web analytics tool offered by Google Inc. (“Google”, www.google.com) that provides statistics and tracks web traffic.
Google Analytics requires the placing of “cookies” on the device from which you access the web pages. These cookies enable us to analyze the use of our web pages by you. In addition, for the purpose of identifying trends and improving our online offer, usage data such as the page last visited, the browser used, date, time, etc. are being evaluated. The information generated by the cookie about the use of the web pages are usually transmitted to a Google server in the USA and stored there. Google has submitted to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US Framework.
NUDGEIT uses Google’s services by enabling the IP anonymization feature. This leads to Google storing the user’s IP address only in a shortened format, resulting in anonymization / masking. The anonymization or masking of the IP takes place after the IP addresses arrive in the Google Analytics data collection network, but before any storage or processing of the data takes place. For more information, see: IP Anonymization in Google Analytics.
On behalf of NUDGEIT, Google uses the information obtained from cookies to evaluate the use of the web pages by you, to compile reports on web page activity and to provide other services related to web page activity and internet usage to NUDGEIT. This is our legitimate interest in data processing. The legal basis for the use of Google Analytics is Article 6(1)(f) GDPR.
In addition, data submitted to Google via the Google Analytics service is linked by Google with third-party cookies associated with visits to other websites, such as when an advertiser uses their Google Analytics data to create more relevant ads or would like to more accurately analyze their traffic. More about this can be found under the explanatory page about Google Analytics provided by Google.
You can prevent the cookie generated information (including your IP address) from being collected, transmitted to Google and processed by Google by downloading and installing this browser plug-in (effective only for the device on which you install the browser plug-in): (not for mobile devices).
You can also prevent the placing of cookies on your device by changing the settings in your browser software.
Additional information about the third-party provider:
• Third-party company and address: Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001
· Terms of Use: http://www.google.com/analytics/terms/de.html
• Information about Data Protection provided by Google (overview): http://www.google.com/intl/de/analytics/learn/privacy.html
• Google Privacy Policy: http://www.google.de/intl/de/policies/privacy
16. Contact
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to info@nudgeit.com