PRIVACY POLICY
Last updated July 15, 2021
Thank you for choosing to be part of our community at Nobee Inc. (“Nobee,” “we,” “us,” or “our”). We are committed to protecting the personal information of our users (“you” or “your”) and respecting your right to privacy. This Privacy Policy (“Policy”) summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection, including special information for residents of the State of California and for residents of the United Kingdom and the European Union.
It is our policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and retaining the trust of our customers, business partners, and others who share their personal information with us.
This Policy applies to all Internet sites and mobile applications operated by or on behalf of Nobee and includes Nobee entities worldwide. It also applies to personal information Nobee may otherwise collect: (i) through our products and services; (ii) when you interact with us by means other than Nobee websites or applications, for example, in person, by telephone, or at a real estate showing or training; and (iii) from our customers, distributors, suppliers, vendors, and other business partners (collectively, “Business Partners”).
However, different Nobee Internet sites, apps, products, and services have different purposes and features. If additional or different disclosures are required for a specific Nobee Internet site, app, product, or service, then we will provide those disclosures separately on, or with, the relevant Internet site, app, product, or service. Each such specific privacy disclosure, policy, or statement (“Specific Privacy Statement”) supplements and amends this Policy.
We appreciate that you are trusting us with your personal information and take your privacy very seriously. In this Policy, we seek to explain to you in the clearest way possible what information we collect, how we use it, and what rights you have in relation to this process. We hope you take some time to read through it carefully, as it is important. If you have any questions or concerns about this Policy or our practices with regards to your personal information, please contact us using the contact details provided below.
TABLE OF CONTENTS
1. General Principles
2. Personal Information Collection
3. Use of Personal Information
4. Sharing of Personal Information
5. Social Logins
6. Personal Information Security
7. Third-Party Content
8. Personal Information and Account Access
9. Controls for Do-Not-Track Features
10. Duration of Personal Information Retention
11. Revision Policy
12. Information Regarding Minors
13. Information for California Residents
14. Information for United Kingdom and European Union Residents
15. Contact Information
GENERAL PRINCIPLES
To the extent required by applicable law, whenever Nobee collects personal information, Nobee will complete the following:
· Provide timely and appropriate notice to you about our data practices;
· Collect your personal information only for specified and legitimate purposes, wherein the information we collect will be relevant, adequate, and not excessive for the purposes for which it is collected;
· Process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;
· Take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;
· Not use your personal information for direct marketing purposes without giving you an opportunity to “opt out”; and
· Take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within Nobee.
PERSONAL INFORMATION COLLECTION
Nobee collects the following forms of personal information:
· User-Provided Information
Nobee collects personal information you provide us, which may include: (i) contact information, such as your name, company name, job title, address, e-mail address, and phone number; (ii) additional information about you, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products, demographic information, data collected from surveys, job application data such as background checks, work performance, salary, bonuses, and disciplinary actions; (iii) comments, questions, requests, and orders you may make; (iv) financial information needed to process payments if you make purchases, such as credit card or account information or tax identification number, all of which is stored by Braintree; (v) login information, including, if applicable, social media account information for login purposes, specific information on Nobee’s handling of which can be found in the Social Logins section; and (vi) information about your preferences, such as your preferred methods of communication and product types in which you are interested.
The personal information that we collect depends on the context of your interactions with us and Nobee Internet sites, the choices you make, and the products and features you use. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
· Device-Generated Information
Nobee may collect technical information about your device, such as device type, browser type, IP address, operating system, language preferences, referring URLs, country, location, and device identifier. Nobee may collect information automatically from yoru device and web browser through cookies and similar technologies. This information does not reveal your specific identity, such as your name or contact information, but is primarily needed to maintain the security and operation of Nobee Internet sites and for internal analytics and reporting purposes.
Nobee may collect technical data about your usage of Nobee Internet sites and apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, Nobee promotional emails opened, and dates and times of interactions. Nobee collects this information using cookies and similar technologies.
Nobee may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code.
· Cookies and other Persistent Technology
A “cookie” is a file of information placed on your device when you visit a website. Cookies and similar technologies like web beacons and pixels can enhance your user experience by saving your preferences, personalizing your online experience, and sometimes providing you with advertising which is tailored to your interests.
Nobee Internet sites may use “session cookies.” A session cookie does not identify you personally and expires after you close your browser. For example, when you visit Nobee rental pages, a session cookie may be stored to note which pages you have visited. We can use this information to provide you recommendations of other rentals that may be of interest.
Nobee Internet sites may also use “persistent cookies.” These cookies do not expire when you close your browser. Persistent cookies stay on your computer until you delete them or they expire. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences which can be provided by us automatically, saving you time and effort on future visits. For example, after you attend a rental showing, if you decide to attend another rental showing, some of your information may have been retained and will only need to be confirmed.
Certain countries require your consent to the use of cookies when you visit Nobee Internet sites. If you access a Nobee Internet site for one of these countries, you will be presented with information regarding your options, including the option to accept or reject certain categories of cookies, assuming that the site uses cookies or other persistent technology. You will be able to change these settings on subsequent visits. Please note that you will not be able to opt out of receiving certain cookies that are strictly necessary for the delivery of a service requested by you.
At any time when visiting a Nobee Internet site for one of these countries, clicking on the “Cookie Preferences” link at the bottom of each page allows you to access information on cookies and change your settings. Note that this link will not be present if cookies are utilized by the applicable Nobee Internet site.
Although you are not required to accept cookies when you visit a Nobee Internet site, you may be unable to use all of the functionality of the site if you reject certain cookies. In addition, your browser may allow you to adjust settings to accept or reject cookies, or to alert you when a cookie is placed on your computer.
· Personal Information Collected from Third Parties
Nobee may also obtain personal information from other third-party sources, including publicly and commercially available sources. We may combine the information we receive from our third-party sources with information that we collect from you or your device, as described above.
While you may choose not to provide information that we request, we may not be able to provide you a relevant service or particular feature for a Nobee Internet site, app, or product if the requested information is not provided.
USE OF PERSONAL INFORMATION
Nobee may use your personal information for the following purposes:
· To develop and manage our relationships with you and with our Business Partners
This may include: (i) delivering services or carrying out transactions that you or our Business Partners have requested; (ii) providing information about Nobee products, services, transactions, and advertisements that may be of interest to you; (iii) providing you and our Business Partners with a more consistent experience in interacting with Nobee, including by learning more about you and how you use and interact with Nobee Internet sites, apps, products, and services; and (iv) planning, managing, and performing under our contractual relationships with our Business Partners.
· To address legal issues
This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal processes; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of Nobee Internet sites, apps, products, and services; and (v) protecting Nobee’s rights or property or yours or others’ health, safety, welfare, rights, or property.
· To provide and improve our Internet sites, apps, products, and services
This may include: (i) customizing Nobee Internet sites, apps, products, and services to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting Nobee Internet sites, apps, products, and services; and (iii) developing new Nobee Internet sites, apps, products, and services.
Nobee may also use your personal information for other uses consistent with the context in which the information was collected or with your consent.
Nobee may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product development purposes. Such information will not identify you individually.
SHARING OF PERSONAL INFORMATION
Nobee may process, share, or disclose your information under the following circumstances.
· With other Nobee entitites
Nobee may share your personal information with other Nobee entities, including those in different countries. When we do so, these other Nobee entities will use your information in a manner consistent with this Policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.
· With third party Nobee hires for support services
Nobee may also share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
· With third parties Nobee partners with
In some cases, Nobee may share your personal information with third parties who partner with us to provide products and services to our customers, such as distributors. If so, we will require our Business Partners to use that information in a manner consistent with this Policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.
· With other third parties
Nobee may share your personal information with third parties when we have a good faith belief that such disclosure is necessary: (i) to comply with a law, regulation, court order, or other legal process; (ii) to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of Nobee Internet sites, apps, products, or services; (iii) to protect Nobee rights or property or yours or others’ health, safety, welfare, rights, or property; or (iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
· With Google Maps Platform APIs
Nobee may share your personal information with certain Google Maps Platform APIs, such as Google Maps API or Place API and may obtain and store on your device (“cache”) your location. You may revoke your consent for this such personal information sharing at any time by contacting us using the contact details provided below.
Director of Compliance, Nobee Inc.
· With other users
When you share personal information, such as by posting comments, contributions, or other content, to Nobee Internet sites, apps, products, or services or otherwise interact with public areas of Nobee Internet sites, apps, products, or services, such personal information may be viewed by all users and may be publicly made available outside of Nobee Internet sites, apps, producs, or services in perpetuity. If you interact with other users of Nobee Internet sites, apps, products, and services and register for a Nobee Internet site, app, product, or service through a social network such as Facebook, your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within Nobee Internet sites, apps, products, and services and view your profile.
Nobee may share your personal information with third parties in connection with the sale, purchase, merger, reorganizations, liquidation, or dissolution of Nobee or a Nobee business unit, or under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
Nobee may share your information with your permission or at your request. Nobee may process your data when it is reasonably necessary to achieve our legitimate business interests.
Nobee may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.
SOCIAL LOGINS
Nobee Internet sites, apps, products, and services offer you the ability to register and login using your third-party social media account details, such as your Facebook or Twitter logins. When you choose to do this, Nobee will receive certain profile information about you from your social media provider. This profile information may vary depending on the relevant social media provider, but will frequently include your name, email address, friends list, and profile picture, as well as any other information you choose to make public on the relevant social media platform.
Nobee will use the social media information we receive only for the purposes that are described in this Policy or that are otherwise made clear to you on the relevant Nobee Internet site, app, product, or service.
PERSONAL INFORMATION SECURITY
Your personal information will generally be stored in Nobee databases or databases maintained by our service providers typically in, but not limited to, the United States. Nobee takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within Nobee.
Nobee maintains reasonable safeguards to protect the confidentiality, security, and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.
THIRD-PARTY CONTENT
Nobee Internet sites, apps, products, and services may contain advertisements from third parties that are not operated by Nobee or affiliated with us and which may link to other websites, online services, or mobile applications. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, apps, or social media platforms, nor any association with their operators. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this Policy, and we are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from Nobee Internet sites, apps, products, and services. To learn about the information collected by these third-party websites, apps, and plugins, please visit their respective privacy policies
PERSONAL INFORMATION AND ACCOUNT ACCESS
If, at any time, you would like to review, update, request, or delete your personal information, you may log into your account settings and update or user account or contact us using the contact details provided below:
Director of Compliance, Nobee Inc.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Service, or comply with applicable legal requirements.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies or to reject cookies. If you choose to remove cookies or to reject cookies, this could affect certain features or services of Nobee Internet sites, apps, products, and services.
You can unsubscribe from Nobee’s marketing email list at any time by accessing your account settings and updating your preferences, clicking on the unsubscribe link in the emails that we send, or by contacting us using the contact details provided below.
Director of Compliance, Nobee Inc.
You will then be removed from the marketing email list. However, Nobee may still communicate with you, for example, to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, Nobee does not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that Nobee must follow in the future, we will inform you about that practice in a revised version of this Policy
DURATION OF PERSONAL INFORMATION RETENTION
Nobee will only keep your personal information for as long as is necessary for the purposes set out in this Policy, unless a longer retention period is required or permitted by law, such as through tax, accounting, or other legal requirements.
When Nobee has no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, for example, because your personal information has been stored in backup archives, we will securely store your personal information and isolate it from any further processing until deletion is possible.
REVISION POLICY
Nobee may revise, update, or otherwise alter this Policy at any time in its sole discretion. The updated version will be indicated by an updated “Last updated” date. The updated version will be effective immediately as soon as it is accessible on Nobee Internet sites, apps, products, and services. If material changes are made to this Policy, we may choose to notify you either by prominently posting a notice of such changes or by directly sending you a notification.
However, you waive any right to receive specific notice of any such change. It is your responsibility to periodically review this Policy to stay informed of updates. You will be subject to, and will be deemed to have been made aware of and to have accepted, the changes in any revised Policy by your continued use of Nobee Internet sites, apps, products, and services after the date the revised Policy is posted.
INFORMATION REGARDING MINORS
Nobee’s platform and services are not intended for minors under 18 years of age. Nobee will not knowingly solicit or collect personal information from or regarding minors under the age of 18, or legal age requirements as specified by local law.
By using Nobee Internet sites, apps, products, and services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of Nobee Internet sites, apps, products, and services.
If Nobee learns that personal information from users less than 18 years of age has been collected, we will deactivate the relevant account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from minors under the age of 18, please contact us using the contact details provided below.
Director of Compliance, Nobee Inc.
INFORMATION FOR CALIFORNIA RESIDENTS
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits users that are residents of the State of California, to request and obtain from us, once a year and free of charge, information about categories of personal information, if any, we disclosure to third parties for direct marketing purposes and the names and addresses of all third parties with whom we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact details provided below.
Director of Compliance, Nobee Inc.
If you are under 18 years of age, are a resident of the State of California, and have a registered account with Nobee Internet sites, apps, products, or services, you have the right to request removal of unwanted data that you publicly post on Nobee Internet sites, apps, products, and services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California.
Director of Compliance, Nobee Inc.
In such cases, Nobee will ensure the data is not publicly displayed on Nobee Internet sites, apps, products, and services. However, please be aware that the data may not be completely or comprehensively removed from all of our systems, such as backups.
INFORMATION FOR UNITED KINGDOM AND EUROPEAN UNION RESIDENTS
Data Protection Officer
+1 (781) 547-9695
Purpose of Personal Data Collection and its Legal Basis
The lawful basis of Nobee’s processing of your personal data will depend on the purposes of the processing. For most personal data processing activities covered by this Policy, the lawful basis is that the processing is necessary for Nobee’s legitimate business interests. Where we process personal data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. When we are required to share personal data with law enforcement agencies of other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location from your mobile device.
If Nobee is relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please not however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Recipients of Personal Information
Recipients of personal information are Nobee, Nobee entities, third parties, and other users as described by the conditions above.
Your Privacy Rights
In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability, right to lodge a complaint with supervisory authorities, and right to object to processing. Most of these rights are not absolute. If you make a request to exercise your rights, we will respond within one month, but have the right to extent this period by two additional months where necessary. If we extent the response period, we will let you know within one month from your request. You can exercise your rights by contacting us using the contact details provided below.
Director of Compliance, Nobee Inc.
If you are a resident of the United Kingdom or the European Union and you believe Nobee is unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority.
CONTACT INFORMATION
If you have questions or comments about this Policy, please contact us using the contact details provided below.
Director of Compliance, Nobee Inc.