The Noble Systems group of companies (“we“, “us” or “our”) are committed to protecting and respecting your privacy.
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, when you visit our website will be processed by us.
For the purposes of the General Data Protection Regulation ((EU) 2016/679) (“GDPR”), the UK Data Protection Act 2018 and any future legislation which updates, revokes, supplements or replaces either of them (the “Data Protection Legislation”), the data controller of the data of citizens of an applicable country shall be as follows: (A) the data controller for personal data about individuals located within countries in the European Economic Area (“EEA”) is Noble Systems Corporation, at its Polish Registered Office at Wielicka 28, Equal Business Park Trzon A, 30-522, Krakow Poland; (B) the data controller for the personal data of citizens of countries within the United Kingdom is Noble Systems UK Limited (company no. 03875607) of 11 Commerce Way, Westinghouse Road, Manchester, Lancs, M17 1HW; and (C) the data controller for the personal data of citizens of all other countries is Noble Systems Corporation at 1200 Ashwood Parkway, Suite 300, Atlanta, Georgia 30338. Contact information for each of the foregoing data controllers is set forth in Section 14 below.
1. Information we collect from you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (known as “anonymous data”).
We may collect, use, store and transfer the following data about you:
- Information you give us. This is information about you that you give us by filling in forms on our website or by corresponding with us by phone, e-mail, tradeshows or otherwise. It includes information you provide when you apply for our services, subscribe to our services or publications, request marketing to be sent to you, enter a competition, promotion or survey, when you report a problem with one of our sites, and when you give us feedback. The information you give us may include your name, your firm or company, your practices, address, e-mail address, phone number, gender, marital status, date of birth, financial and credit card information.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
- Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
- Information we receive from other sources. We may receive personal data about you from various third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers.
We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
2. Uses made of your information
We will only use your personal data when the law allows us to. Most commonly, we will use your personal information
- to carry out our obligations arising from any contracts entered into between you and us or to take steps at your request before entering into any contracts;
- to comply with any legal obligations to which we are subject; or
- where it is necessary for our or a third party’s legitimate interests, including for the purposes of preventing fraud, except where such interests are overridden by your interests or fundamental rights and freedoms.
Generally we do not rely on consent as a legal basis for processing your personal information other than in relation to sending third party direct marketing communications to you via email.
3. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including|
basis of legitimate interest
|To register you as a new customer||Identity and contact details||Performance of a contract with you|
|To process and deliver your order including:||Identity, contact details and financial and credit card information|
|To manage our relationship with you which will include:||Identity, contact details, and marketing preferences|
|To enable you to partake in a prize draw, competition or complete a survey||Identity, contact details and marketing preferences|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||Identity, contact details and technical data such as IP address|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||Identity, contact details, technical data such as IP address, marketing preferences||Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||Technical data such as IP address||Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||Identity, contact details, usage data and marketing preferences||Necessary for our legitimate interests (to develop our products/services and grow our business)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your identity, contact details, usage data, technical data and marketing preferences to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.
You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Noble Systems group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
4. Disclosure of your information
We may have to share your personal information with the third parties set out below, or any other third parties notified to you, for the purposes set out in paragraph 3 above:
- Professional advisers, including lawyers, bankers, auditors and insurers.
- Regulators and other authorities who require reporting of processing activities in certain circumstances.
- Fraud prevention agencies.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
5. International transfers
Many of our group companies and external third parties are based outside the EEA or the UK, so (if you are an individual located in the EEA or a UK citizen) their processing of your personal data will involve a transfer of data outside the EEA or the UK.
Whenever we transfer your personal data out of the EEA or the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- Data that is shared with other companies in the group of companies of which we are a part, is shared pursuant to the terms of a Data Sharing Agreement between those group companies, on the standard model clauses approved by the European Commission or the UK Secretary of State; or
- We may transfer your personal data to a recipient in a country which has been deemed to provide an adequate level of protection for personal data by the European Commission or the UK Secretary of State; or
- Where we use certain service providers, we may use specific contracts approved by the European Commission or the UK Secretary of State, which give personal data the same protection it has in Europe or the UK as applicable.
- In any case, where we use providers based in the US or other countries outside of the UK or the EEA, we only transfer personal data to them where we are satisfied that they are able to provide a level of protection to personal data that is consistent with our obligations for such data.
Please contact us (or the applicable data controller within the Noble Systems group of companies as provided in Section 14 below, noting that this may itself involve the overseas processing of your personal data) if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
However, the transmission of information via the internet is never 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.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Your rights
If you are an individual located in the UK or the EEA, then under the Data Protection Legislation you may be entitled to exercise the following rights by contacting us (using the contact information in Section 14 below which are relevant to your location or the part of our business that you are dealing with):
- Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time.
- You can ask us to rectify any inaccuracies in the personal information that we hold about you.
- You can ask for us to erase personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
- You can object to our processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information that override your rights and freedoms and therefore this right to object.
- You can also seek to restrict our processing of your personal data (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- You can ask for a copy of your personal data from us in a commonly used and machine-readable format or (in some limited circumstances) ask us to transmit your personal data to another data controller.
- You have the right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
- You can access information held about you. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Any data subject, even located outside of the EEA, can in any case exercise any of the above rights at any time by contacting us at Noble Systems at the applicable address or email address as provided in Section 14 below.
9. Your rights as a California citizen
This section applies to your personal data that you provide to us is you are a California citizen and the California Consumer Protection Act (“CCPA”) applies to such data:
- We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
- In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:
- Category A: Identifiers.
- Category B: California Customer Records personal information categories.
- Category C: Protected classification characteristics under California or federal law.
- Category I: Professional or employment-related information.
- We disclose your personal information for a business purpose to the following categories of third parties: our affiliates; our service providers; and third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.
- In the preceding twelve (12) months, we have not sold any personal information.
- Under the California Consumer Protection Act (CCPA) you may be entitled to request we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you: (i) The categories of personal information we collected about you; (ii) The categories of sources for the personal information we collected about you; (iii) Our business or commercial purpose for collecting or selling that personal information; (iv) The categories of third parties with whom we share that personal information; (v) The specific pieces of personal information we collected about you (also called a data portability request); and (vi) If we sold or disclosed your personal information for a business purpose (which would be provided in two separate lists disclosing (1) sales, identifying the personal information categories that each category of recipient purchased; and (2) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- 1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- 2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- 3. Debug products to identify and repair errors that impair existing intended functionality.
- 4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- 5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 ).
- 6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- 7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- 8. Comply with a legal obligation.
- 9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above under the CCPA, please submit a verifiable consumer request to us by either:
- Calling us at 888-866-2538
- Emailing us at or by email to DPM@noblesystems.com.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
10. Links to and from our site
Our site may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy notices and that we do not accept any responsibility or liability for these notices or the processing that happens on those sites. Please check those notices before you submit any personal data to such websites.
11. Changes to your personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
12. Changes to our privacy notice
Any changes we make to our privacy notice in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy notice.
Cookies, in conjunction with our web server’s log files, allow us to calculate the aggregate number of people visiting our website and which parts of the site are most popular. This helps us gather feedback in order to constantly improve our website and better serve our customers. Cookies do not allow us to gather any personal information about you, and we do not generally store any personal information that you provided to us in your cookies.
|Citizen/Data Subject Location||Data Controller||Address||Email Address|
|European Economic Area||Noble Systems Corporation (Polish Registered Office)|
Equal Business Park Trzon A, 30-522
|United Kingdom||Noble Systems UK Limited||11 Commerce Way Westinghouse Road Manchester, Lancs, M17 1HW||DPMUK@noblesys.com|
|Rest of the World||Noble Systems Corporation|
1200 Ashwood Parkway Suite 300
Atlanta, Georgia 30338
If you are located in the UK, you also have the right to make a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues. Further information can be found at https://ico.org.uk/
If you are located in the EEA, you also have the right to make a complaint to the Urzad Ochrony Danych Osobowych (UODO), the Polish supervisory authority for data protection issues. Further information can be found at https://uodo.gov.pl/en.