Effective date: July 5, 2023
- Personal Data
- Categories of Personal Data We Collect
- Categories of Sources of Personal Data
- Our Commercial or Business Purposes for Collecting Personal Data
- How We Share Your Personal Data
- Tracking Tools, Advertising, and Opt-Out
- Data Security and Retention
- Personal Data of Children
- Other State Law Privacy Rights
- European Union and United Kingdom Data Subject Rights
- Contact Information
If you have any questions related to that Enterprise Customer's settings or privacy practices, please contact such organization. If we process your personal data on behalf of one of our Enterprise Customers and you wish to discontinue such processing, or if you seek to correct, amend, or delete inaccurate personal data, please directly contact the organization on whose behalf we are processing such personal data. We will follow the Enterprise Customer's instructions with regard to the personal data at issue. We will retain such personal data pursuant to our retention policy and will retain it as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
2. Personal Data
Categories of Personal Data We Collect
This chart details the categories of Personal Data that we collect and have collected over the past 12 months:
|Category of Personal Data||Examples of Personal Data We Collect||Categories of Third Parties With Whom We Share this Personal Data|
|Profile or Contact Data||First and last name, Email||Service Providers, Business Partners, Parties You Authorize, Access or Authenticate|
|Identifiers||Account username, including for integrations||Service Providers, Business Partners (Account username only), Parties You Authorize, Access or Authenticate|
|Payment Data||First and last name, Email||Service Providers (specifically our payment processing partner, currently Stripe, Inc.)|
/IP Data | IP address, Device ID, Domain server, Type of device/operating system/browser used to access the Services | Service Providers, Advertising Partners (cookies), Analytics Partners Web Analytics | Web page interactions, Referring webpage/source through which you accessed the Services, Non-identifiable request IDs, Statistics associated with the interaction between device or browser and the Services | Service Providers, Advertising Partners, Analytics Partners Geolocation Data | IP-address-based location information | Service Providers, Advertising Partners, Analytics Partners, Business Partners Other Identifying Information that You Voluntarily Choose to Provide | Identifying information in emails or letters you send us, Information voluntarily provided about your use of Naas, User-provided code, User-provided data and data sets, Data derived from inputs using user code and configurations | Service Providers, Parties You Authorize, Access or Authenticate
Categories of Sources of Personal Data
We collect Personal Data about you from the following categories of sources:
- When you provide such information directly to us.
- When you create an account or use our interactive tools and Services.
- When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
- When you send us an email or otherwise contact us.
- When you use the Services, and such information is collected automatically.
- Through Cookies (defined in the "Tracking Tools, Advertising, and Opt-Out" section below).
- If you use a location-enabled browser, we may receive information about your location and mobile device.
- Vendors: We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. We may use vendors to obtain information to generate leads and create user profiles.
- Advertising Partners: We receive information about you from some of our vendors who assist us with marketing or promotional services related to how you interact with our websites, products, Services, advertisements, or communications. We may receive information about you from third parties, including our strategic partners.
- Social Networks: If you provide your social network account credentials to us or otherwise sign in to the Services through a third-party site or service, some content and/or information in those accounts may be transmitted into your account with us.
Our Commercial or Business Purposes for Collecting Personal Data
- Providing, Customizing and Improving the Services: Creating and managing your account or other user profiles and providing you with the products, services, or information you request. Providing support and assistance for the Services. Improving the Services, including testing, research, internal analytics, and product development. Personalizing the Services, website content, and communications based on your preferences. Doing fraud protection, security and debugging, including preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities. Processing orders or other transactions; billing. Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
- Marketing the Services: Marketing and selling the Services.
- Corresponding with You: Responding to correspondence, contacting you when necessary or requested, and sending you information about Naas or the Services. Sending emails and other communications according to your preferences or that we think will interest you.
- Meeting Legal Requirements and Enforcing Legal Terms: Fulfilling our legal obligations under applicable law, regulation, court order, or other legal process. Resolving disputes, protecting the rights, property, or safety of you, Naas, or another party, and enforcing agreements. Responding to claims that any posting or other content violates third-party rights.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. How We Share Your Personal Data
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a "sale" of your Personal Data. For more information, please refer to the state-specific sections below.
Service Providers: These parties help us provide the Services or perform business functions on our behalf. They include:
- Hosting, technology, and communication providers.
- Security and fraud prevention consultants.
- Support and customer service vendors.
- Payment processors.
Advertising Partners: These parties help us market our services and provide you with other offers that may be of interest to you. They include:
- Ad networks.
- Marketing providers.
Analytics Partners: These parties provide analytics on web traffic or usage of the Services. They include:
- Companies that track how users found or were referred to the Services.
- Companies that track how users interact with the Services.
Business Partners: These parties partner with us in offering various services. They include:
- Companies that we partner with to offer joint promotional offers or opportunities.
- Integration partners.
Parties You Authorize, Access, or Authenticate: Third parties you access through the services. Social media services.
Legal Obligations: We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under "Meeting Legal Requirements and Enforcing Legal Terms" in the "Our Commercial or Business Purposes for Collecting Personal Data" section above.
Business Transfers: All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy, or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data: We may create aggregated, de-identified, or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified, or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build, and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
4. Tracking Tools, Advertising, and Opt-Out
We use the following types of Cookies:
- Essential Cookies: Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
Functional Cookies:** Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time, and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).
- Analytics and Performance Cookies: Analytics and Performance Cookies collect information on how users interact with our Services, including what pages are visited most, as well as other analytical data. We use these details to improve how our Services function and to understand how users interact with them.
- Advertising Cookies: Advertising Cookies are used to deliver relevant advertisements to users both on and off our Services. We analyze what pages you visit on these sites, what products or services you view, and whether you view or click on ads that are shown to you. We may also use a Cookie to learn whether someone who saw an ad later visited and made a purchase on the advertiser's site. Similarly, our partners may use a Cookie to determine whether we've shown an ad and how it performed or provide us with information about how you interact with ads. We may also work with a partner to show you an ad on or off our Services, such as after you have visited a partner's site or application.
5. Data Security and Retention
We take the security of your Personal Data seriously and use appropriate technical and organizational measures to protect your Personal Data against unauthorized or unlawful processing and against accidental loss, destruction, or damage. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the "Contact Information" section below.
We retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. When determining the retention period, we take into account various criteria, such as the type of products and services requested by or provided to you, the nature and length of our relationship with you, possible re-enrollment with our products or services, the impact on the services we provide to you if we delete some information from or about you, mandatory retention periods provided by law and the statute of limitations.
6. Personal Data of Children
The Services are not intended for individuals under the age of 16, and we do not knowingly collect Personal Data from individuals under the age of 16. If we learn that we have collected Personal Data from a child under the age of 16, we will take steps to delete that information as soon as possible. If you believe that a child under the age of 16 may have provided us with Personal Data, please contact us in accordance with the "Contact Information" section below.
7. Other State Law Privacy Rights
California Privacy Rights
Under the California Consumer Privacy Act ("CCPA"), California residents have certain rights regarding the Personal Data collected about them.
Right to Know: California residents have the right to request that we disclose the categories of Personal Data we have collected about them, the categories of sources from which we collected the Personal Data, the purposes for collecting the Personal Data, the categories of Personal Data that we have disclosed, and the categories of third parties with whom we have shared the Personal Data.
Right to Delete: California residents have the right to request the deletion of their Personal Data that we have collected or
Right to Opt-Out of Sale: California residents have the right to opt-out of the sale of their Personal Data. We do not sell Personal Data.
Right to Non-Discrimination: California residents have the right not to receive discriminatory treatment by us for the exercise of their privacy rights conferred by the CCPA.
To exercise your rights under the CCPA, you may submit a verifiable consumer request to us by contacting us using the information provided in the "Contact Information" section below. We will verify your request using the information associated with your account, including your email address. If you do not have an account with us, we may request additional information to verify your identity and fulfill your request.
Nevada Privacy Rights
Nevada residents have the right to opt-out of the sale of their Personal Data. We do not sell Personal Data.
Other State Laws
Email: [email protected]
Mail: NaasAI, Inc. 8 The Green, STE 4000, Dover, DE 19901, United States