The Noble Systems group of companies (“we“, “us” or “our”) are committed to protecting and respecting your privacy.
This notice sets out the basis on which any personal data that we are responsible for as a “controller”, either because we collect it from you or because it has been provided to us by you or someone else, will be processed, protected, stored and eventually disposed of by us.
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other policies and notices and is not intended to override them.
The term “controller” is defined in the EU Data Protection Legislation (which includes 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 controller of the personal data of individuals in the European Economic Area (“EEA”) is Noble Systems UK Limited (company no. 03875607) of 11 Commerce Way, Westinghouse Road, Manchester, Lancs, M17 1HW. For any data subject in a non EEA country, the data controller of your data is the Noble Systems company with which you have dealings.
Where we receive personal data from another controller of that data, to process on their behalf and in accordance with their instructions, we will usually be the “processor” of that personal data. In those circumstances, the applicable controller is obligated to have issued you with a privacy notice which describes the processing activity we will undertake. Where we are a processor, we will handle the applicable data consistent with our agreements with the applicable controller of that data.
Information We Collect from or about 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 and where the person that it related to cannot be re-identified (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, enter into our systems through use of our services, 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 or services, 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 or use of our services, 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, and your telephone number (unless you withhold this);
- 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 receive from other sources. We may receive personal data about you from various third parties including, for example, your employer, customers, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers.
In each of the situations mentioned above, we will usually collect that information directly from you or from another source for our own purposes, in which case we will be the controller of that information; if we collect or are provided with the data to process on behalf of one of our customers for their purposes, then that customer will usually be the controller and we will be a processor of that data on their behalf.
We do not expect to 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.
Uses Made of your Personal Data
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;
- where we have been provided with your personal data by or on behalf of your employer, to carry out our obligations from any contracts entered into between your employer and us, for your benefit, to take steps at your employer’s 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. Whether we are communicating with you on the basis of your consent or for our legitimate interests, every such communication will give you the opportunity to opt out of receiving similar communications in future.
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 on more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one basis 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 enable your employer (or licensee of our software or services) to use our software or services||Identify, information to establish identify||Necessary to use software or services or performance of the agreements for use of such software or services|
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, applicable cloud/hosted services environment, 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.
If you are an EEA citizen and provide data to Noble Systems UK Limited, we will get your express opt-in consent before we share your personal data with any company outside the Noble Systems UK Limited group for marketing purposes.
Whether the lawful basis for sending them to you is consent or legitimate interests, 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 marketing messages, we will continue to process 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 which allows us to do so, before doing 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.
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.
If you are an EEA citizen, many of our external third parties are based outside the EEA so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it as is available under the Data Protection Legislation, by ensuring at least one of the following safeguards is implemented:
- Data that is shared with other companies in the Noble Systems group of companies, is shared under the terms of a Data Sharing Agreement between those group companies, on the standard model clauses approved by the European Commission; or
- We may transfer your personal data to a country where it has been deemed to provide an adequate level of protection for personal data by the European Commission; or
- Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or
- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield arrangement which requires them to provide similar protection to personal data shared between the Europe and the US.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
This section does not apply to data where we are a data processor under an applicable agreement with a third party that provided your data to us. In those circumstances, that agreement will impose suitable safeguards for international transfers, and the privacy notice from our customer, the controller, will explain what those are.
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 unauthorised 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 anonymise 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.
Your rights as a data subject in the EEA
If you are a data subject in the EEA, protected by the Data Protection Legislation, you may be entitled to the following rights:
- 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 by contacting us at Noble Systems UK Limited, 11 Commerce Way, Westinghouse Road, Manchester, M17 1HW or by email to DPMUK@noblesystems.com.
- You can ask us to rectify any inaccuracies in the personal information that we hold about you.
- To request the erasure of 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 you information unlawfully or where we are required to erase your personal data to comply with local law.
- To 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 which 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.
- 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.
- To request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller.
- Not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
- To 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, 1200 Ashwood Parkway, Suite 300, Atlanta, GA 30338-4747 or by email to DPM@noblesystems.com or by contacting us at Noble Systems UK Limited, 11 Commerce Way, Westinghouse Road, Manchester, M17 1HW or by email to DPMUK@noblesystems.com.
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 policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
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.
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. Nevertheless, any personal information that is processed by us in connection with your cookies is processed in accordance with the Data Protection Legislation.
Privacy Shield Frameworks
Noble Systems’ policies, procedures and practices are designed to maintain compliance with the principles of the EU-U.S. and Swiss-U.S. Privacy Shield frameworks. For more information regarding those applicable requirements, please refer to the U.S. Department of Commerce’s Privacy Shield website.
If you are a data subject in the EEA and have any complaints relating to our privacy notice or our use of your personal data, please contact us at Noble Systems UK Limited, 11 Commerce Way, Westinghouse Road, Manchester, Lancs, M17 1HW or by email to DPMUK@noblesystems.com. 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 www.ico.org.uk.