Effective as of January 1st 2018, updated on January 23rd 2018.
Privacy Shield Notice
At Nalpeiron, we respect and protect the privacy of both visitors to our web properties and of our customers who use our on-demand licensing platform, analytics platform (www.nalpeiron.com), or the tools and services offered on our website. Generally, you can browse through our website without giving us any information about yourself. When personal information is required to provide services that you request or when you choose to provide us with your personal information, this policy describes how that information is collected and used.
The Federal Trade Commission (FTC) has jurisdiction over Nalpeiron's compliance with the Privacy Shield.
Customer Information Collection and Use
Nalpeiron collects personal information when you register with Nalpeiron for a Nalpeiron account (When you register for our services, we ask for information such as your name, company name and address, site name, phone number, e-mail address and other required information), when you use certain Nalpeiron products or services, when you register to attend a seminar or participate in an online survey, when you ask to be included in an email or other mailing list, other product promotions, or when you submit your information to Nalpeiron for any other reason. From time to time, Nalpeiron receives personal information from business partners and vendors. Nalpeiron only uses such information if it has been collected in accordance with acceptable privacy practices consistent with this policy and applicable laws.
Access to certain Nalpeiron web pages requires a login and a password. The use of those web pages, and the information or programs downloadable from those sites, may be governed by a written agreement between a 3rd party Software Vendor, you and Nalpeiron. Your personal information may be retained by Nalpeiron to verify compliance with the agreement, log software licenses granted, to track software downloaded from those pages, or track usage of other applications available on those pages. For instance, when you pay for our service via Credit Card Nalpeiron uses a third-party intermediary to manage credit card processing. This intermediary is not permitted to store, retain, or use your billing information, except for the sole purpose of credit card processing on Nalpeiron's behalf. Further, Nalpeiron complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland including the onward transfer liability provisions.
Nalpeiron may use the personal information and other information we collect about your use of our service to operate our service and tailor it to your needs, for billing, identification and authentication, to contact you about your use of our service, send you marketing materials (subject to your opt-out option), for research purposes, and to generally improve the content and functionality of our service and our site.
Although Nalpeiron owns all rights to the software, code, databases, and other service applications, you retain all rights to your data. Our service providers may not use your personal information for marketing purposes.
Additional Methods of Information Collection on the Nalpeiron Websites and Services
Access by your system administrator you should be aware that the administrator of your instance of Nalpeiron Services may be able to:
- access information in and about your Nalpeiron Services account;
- disclose, restrict, or access information that you have provided or that is made available to you when using your Nalpeiron Services account, including your Content; and
- control how your Nalpeiron Services account may be accessed or deleted.
Log Files As is true with most web sites, Nalpeiron gathers certain information automatically and stores it in log files. This information includes internet protocol addresses as well as browser, internet service provider, referring/exit pages, operating system, date/time stamp, and click stream data. Occasionally we may connect personal information to data gathered in our log files, as necessary to improve our service to individual customers. Otherwise we mostly use this information with no connection to individual users, to analyze trends, administer our site, or track usage of various features within our site.
Public Forums and Blogs Our site offers publicly-accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at www.nalpeiron.com/contact. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Customer Testimonials/Comments/Reviews From time to time, we post customer testimonials on our site which may contain personal information. We do obtain the customers' consent to post their names along with their testimonials.
Information Collection via Analytics and Licensing Platforms
Nalpeiron provides analytics and licensing services to our customers. As part of this service Nalpeiron collects data (enduser data) at the direction of its customers (the data controllers). In these situations, Nalpeiron performs collection, processing and storage of this information (data processor) under direct and explicit instructions from its customers. Nalpeiron has no direct connection or relationship with the end users whose personal information it processes.
Nalpeiron will not review, share, distribute, or reference any such Customer Data except as we are directed by our customers or as may be required by law. In accordance with the terms of service, Nalpeiron may access enduser data only for the purposes of providing our services to our customers, preventing or addressing service or technical problems, at a customer's request in connection with customer support matters, or as may be required by law.
Children's Personal Information
Nalpeiron does not knowingly allow access or collect any personal information from children. To ensure compliance with the Children's Online Privacy Protection Act, children under the age of 13 should not access this site or provide any personal information to this site. We encourage parents and guardians to supervise and join their children in exploring the Internet and to help us protect their privacy by instructing them not to provide personal information over the Internet without parental permission. Parents should additionally be aware of a growing variety of software capable of filtering online information to reflect their own choices and guidelines. If we become aware that a user is under the age of 13 and has provided personal information to us without prior verifiable parental consent, we will remove such personal information from our records.
EU/Swiss End User Privacy and Data Use
Nalpeiron is the controller of data collected from our customers and processor of data collected by our customers from their customers. In both cases, Nalpeiron processes data according to the Privacy Shield guideline and/or the GDPR as appropriate. If any transfer of data to a third party is required then the third party will also be subject to Privacy Shield or its equivalent and GDPR guidelines. In providing our service we do not own, control or direct the use of the information stored or processed on our platform and do so only at the direction of our clients. In fact, we are largely unaware of what information is actually being stored on our platform and only access such information as authorized by our clients or as required by law. Only our clients are entitled to access, retrieve and direct the use of such information. As such, we are the "data processors" and not the "data controllers" of the information on our platform for purposes of the EU's General Data Protection Regulation (GDPR) and the Swiss Data Protection Act. Our EU or Swiss customers, who control their customer data and send it to Nalpeiron for processing, are the "controllers" of that data.
Where Nalpeiron collects personal information directly from its EU customers, it informs them about the purpose for which it collects the data and the uses of their personal information. We have no direct relationship with our customers' customers whose personal data we may process and store. Nalpeiron's customers are responsible for complying with GDPR data controller regulations and any relevant data protection legislation in EU member states before sending personal data to Nalpeiron for processing. We work with our customers to help them provide notice to their customers concerning the purpose for which personal information is collected and used. Contact information is provided on our website and at the end of this document
As the processors of personal information on behalf of our European customers, we follow their instructions with respect to the information they control. In doing so we implement appropriate technical, physical and administrative measures against unauthorized processing of such information and against loss, destruction of, or damage to, personal information.
Nalpeiron acknowledges that you have a right to access, correct and delete your personal information. If you are a client's customer and wish to no longer be contacted by one of our clients then please contact that client directly. If you are a client's customer and wish to delete, correct, amend or view your personal data, you should contact our client directly. If you are one of our clients or otherwise feel that you need to contact Nalpeiron you may do so using the contact information on our website or at the end of this document. If you contact Nalpeiron with such a request we will respond within a reasonable time frame (30 business days or less).
Compliance with Laws and Law Enforcement Requests; Protection of Our Rights
We may disclose your Information (including your Personal Information) to a third party if (a) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and terms of service, (c) to protect the security or integrity of Nalpeiron's products and services, (d) to protect Nalpeiron, our customers or the public from harm or illegal activities, or (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Aggregated or Anonymized Data
We may also share anonymized information that does not identify you with the third parties described above.
We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes) without your permission. Further, except as described in this Policy, Nalpeiron will not give, sell, rent or loan any personal information to any third party. We may disclose such information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service, or as otherwise required by law. Nalpeiron may also provide non-personal, summary or group statistics about our customers, sales, traffic patterns, and related site information to reputable third-party vendors, but these statistics will include no personal information.
Third-party Data Transfers
We may transfer personal information to our third-party vendors that help us provide our service, subject to appropriate confidentiality restrictions. Such transfers are limited to the purposes for which personal data has been transferred to us from our customers. The Privacy Shield principles specify conditions for all onward transfers of personal data from the EU. Nalpeiron complies with these principles as well as our service agreements we have with our customers. Otherwise we may also share personal information as is required or permitted by law.
Protection of Information
Nalpeiron is committed to ensuring the security of your personal information. We take every precaution to protect the confidentiality and security of the personal information placed on our site or used within our services, by employing technological, physical and administrative security safeguards, such as firewalls and carefully-developed security procedures. For example, when you enter sensitive information (such as login credentials and all your activity on our Service platform) we encrypt the transmission of that information using secure socket layer technology (SSL). These technologies, procedures and other measures help ensure that your data is secure by design and by default.
Access and Review of Data
Residents of the EU and Switzerland whose personal information Nalpeiron controls may request access and the opportunity to correct, amend, or delete that information. If you are our customer and would like to gain access to, or request deletion of information we have collected as "data controllers", please contact us at firstname.lastname@example.org or via www.nalpeiron.com/contact. We will respond to such queries within 30 business days. Nalpeiron has no direct relationship with its customers' customers whose personal data it processes. An individual seeking access, or who would like to correct, amend, or delete inaccurate data should direct his query to the Nalpeiron customer with whom they interact (the data controller).
Nalpeiron will retain personal information we process on behalf of our customers for as long as needed to provide Service to our customers, subject to our compliance with this policy. We retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. All data storage is subject to our normal terms of service.
California Privacy Rights
Nalpeiron qualifies for the alternative option; it provides you with details on how you may either opt-out or opt-in to the use of your personal information by third parties for direct marketing purposes. Therefore, we are not required to maintain or disclose a list of the third parties that received your personal information for marketing purposes during the preceding year.
If We make any material changes to this Policy we will notify you by posting a notice on our site. We encourage you to periodically review this page for the latest information on our privacy practices. Your continued use of our site or service constitutes your agreement to be bound by such changes to this Policy. Your only remedy, if you do not accept the terms of this Policy, is to discontinue use of our site and service.
Complaints and Arbitration
If after reading this privacy statement you have complaints or concerns about Nalpeiron's disclosure, collection or use of your private data or its compliance with Privacy Shield please contact Nalpeiron at
or via mail at
General Counsel Nalpeiron, Inc. 2225 E. Bayshore Road, Suite 200 Palo Alto, CA 94303
If, after contacting us, you believe that your request has not been sufficiently addressed please contact our US based third party dispute resolution provider, the American Arbitration Association, at http://go.adr.org/privacyshield.html. This service is provided free of charge. Note that under certain circumstances (fully explained at the Privacy Shield website https://www.privacyshield.gov) you may invoke binding arbitration when other dispute resolution methods have failed.