We, at nBold, know you care about how your personal information is used and shared, and we take your privacy more than seriously, we make it a core component of our software development and internal processes. By reading the following you’ll learn in detail about our Privacy Policy, but as a general principle, we only use the data that is necessary to the well-functioning of nBold software. We don’t sell, we don’t share, your data from nBold Softwares in an objective of making money, this is not our business model.

In this policy, we lay out: what data we collect and why; how your data is handled; and your rights to your data. We promise we never sell your data: never have, never will.

What we collect and why

Our guiding principle is to collect only what we need. Here’s what that means in concretely:

Identity & access in App

When as an Office 365 Administrator you sign up for nBold, you give consent for the Microsoft Graph to nBold App. This means that all users in your organization are authorized to login (otherwise they are not).

nBold rely 100% on Azure Active Directory for Identity Management. Meaning that we don’t access, collect, or even store any password, and, the personal information nBold relies on, will only be the information declared in Azure Active Directory such as:

• First and last name
• Email address
• Language
• Time Zone
• Applications settings and preferences

We’ll never sell your personal info to third parties, and we won’t use your name or company in marketing statements without your permission either.

Billing information

When you pay for nBold, we ask for your billing information such as credit card or Bank Transfer, and billing address. That’s so we can charge you for service, calculate taxes due, and send you invoices. Your credit card is passed directly to our payment processor and doesn’t ever go through our servers. We store a record of the payment transaction, including the last 4 digits of the credit card number and as-of billing address, for account history, invoicing, and billing support. We store your billing address to calculate any sales tax due in the United States or VAT in the EU, to detect fraudulent credit card transactions, and to print on your invoices.

Geolocation data

We log all access to all accounts by full IP address so that we can always verify no unauthorized access has happened. We keep this login data for as long as your product account is active.

We also log full IP addresses used to sign up a product account. We keep this record forever because they are used to mitigate spammy signups.

Web analytics data — described further in the Website Interactions section — are also tied temporarily to IP addresses to assist with troubleshooting cases. We blind all web analytics data after 30 days.

Website interactions

When you browse our marketing pages or applications, your browser automatically shares certain information such as which operating system and browser version you are using. We track that information, along with the pages you are visiting, page load timing, and which website referred you for statistical purposes like conversion rates. We sometimes track specific link clicks to help inform some design decisions. These web analytics data are tied to your IP address and user account if applicable and you are signed into our Services.

Google Analytics, Hubspot and Linkedin Tracking code are currently used as Third Party Softwares for this purpose.

Cookies and Do Not Track

We do use persistent first-party cookies to store certain preferences, make it easier for you to use our applications, and support some in-house analytics. A cookie is a piece of text stored by your browser to help it remember your login information, site preferences, and more. You can adjust cookie retention settings in your own browser. To learn more about cookies, including how to view which cookies have been set and how to manage and delete them, please visit: www.allaboutcookies.org.

At this time, our sites and applications do not respond to Do Not Track beacons sent by browser plugins.

Voluntary correspondence

When you write nBold with a question or to ask for help, we keep that correspondence, including the email address, so that we have a history of past correspondences to reference if you reach out in the future.

We also store any information you volunteer like surveys. Sometimes when we do customer interviews, we may ask for your permission to record the conversation for future reference or use. We only do so if you give your express consent.

Information we do not collect

We don’t collect any characteristics of protected classifications including age, race, gender, religion, sexual orientation, gender identity, gender expression, or physical and mental abilities or disabilities. You may provide these data voluntarily, such as if you include a pronoun preference in your email signature when writing into our Support team.

We also do not collect any biometric data. The existing picture may be used in the nBold product experience. We do not extract any information from profile pictures: they are for your use alone.

When we access or share your information

Our default practice is to not access your information. The only times we’ll ever access or share your info are:

To provide products or services you’ve requested. We do use some third-party services to run our applications and only to the extent necessary process some or all your personal information via these third parties. You can view the list of third-party services we use at nBold . Having subprocessors means we are using technology to access your data.

To help you troubleshoot or squash a software bug. If at any point we need to access your account to help you with a Support case, we will ask for your consent before proceeding.

To investigate, prevent, or take action regarding restricted uses. Accessing a customer’s account when investigating potential abuse is a measure of last resort. We have an obligation to protect the privacy and safety of both our customers and the people reporting issues to us. We do our best to balance those responsibilities throughout the process. If we do discover you are using our products for a restricted purpose, we will report the incident to the appropriate authorities.

In the future This may be also to comply with local law if we have demanded by local authorities. This never happened yet. But if it’s happening, you’ll be warned.

Location of Site and Data

Our products and other web properties are operated in the Microsoft Azure Datacenter with data located in France. If you are located in the European Union or elsewhere outside of France, please be aware that any information you provide to us will be transferred to France. By using our App, participating in any of our services and/or providing us with your information, you consent to this transfer.

Your Rights With Respect to Your Information

At nBold, we apply the same data rights to all customers, regardless of their location. Currently some of the most privacy-forward regulations in place are the European Union’s General Data Protection Regulation (“GDPR”). nBold recognizes all of the rights granted in this regulation, except as limited by applicable law. These rights include:

• Right to Know. You have the right to know what personal information is collected, used, shared, or sold. We outline both the categories and specific bits of data we collect, as well as how they are used, in this privacy policy.
• Right of Access. This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security, and processing of that information.
• Right to Correction. You have the right to request correction of your personal information.
• Right to Erasure / “To be Forgotten”. This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, all our service providers. Fulfillment of some data deletion requests may prevent you from using nBold services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
• Right to Complain. You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority. To identify your specific authority or find out more about this right, EU individuals should go to https://edpb.europa.eu/about-edpb/board/members_en.
• Right to Restrict Processing. This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of personal information. (Again: we never have and never will sell your personal data).
• Right to Object. You have the right, in certain situations, to object to how or why your personal information is processed.
• Right to Portability. You have the right to receive the personal information we have about you and the right to transmit it to another party.
• Right to not be subject to Automated Decision-Making. You have the right to object and prevent any decision that could have a legal, or similarly significant, effect on you from being made solely based on automated processes. This right is limited, however, if the decision is necessary for performance of any contract between you and us, is allowed by applicable law, or is based on your explicit consent.

Many of these rights can be exercised in product itself or through the communication users receive (unsubscribe).

In any case you do any Subject Access Request (SAR), we engage to answer in no more than 30 days.

For requests to delete personal information or know what personal information has been collected, we will first verify your identity using a combination of at least two pieces of information already collected including your user email address. If an authorized agent is corresponding on your behalf, we will first need written consent with a signature from the account holder before proceeding.

If you are in the EU, you can identify your specific authority to file a complaint or find out more about GDPR, at https://edpb.europa.eu/about-edpb/board/members_en.

If you have questions about exercising these rights or need assistance, please contact us at privacy@nbold.com.

How we secure your data

Security principle is infused from code phase, to network to everyday operations.

All data is encrypted via SSL/TLS when transmitted from our servers to your browser. The database backups are also encrypted.

The development is following the best practices from the OWASP Security Design Principles and include different testing and security audit such as JavaScript Standard Style, ESLint Security Plugin,  NPM Audit, GitHub Security Alerts, etc. For more information about how we keep your information secure, please review our security overview.

When do we delete your data

When you stop using the nBold App : the data is kept no more than 6 months.

On you request: you can request any personal data deletion in sending an enquiry at privacy@nbold.com

Changes & questions

We may update this policy as needed to comply with relevant regulations and reflect any new practices. Whenever we make a significant change to our policies, we will also announce to customers and publicly.

Have any questions, comments, or concerns about this privacy policy, your data, or your rights with respect to your information? Please get in touch by emailing us at privacy@nbold.com and we’ll be happy to answer them!

 

SalesTim – Gion Invest SASU

Registration No: 851 891 655, RCS Paris

Address: 231 rue Saint-Honoré, 75001 Paris