Effective as of June 11th 2012, updated on February 24th 2014.
Information Collection and Use
In this Policy, “personal information” means information or an information set that identifies or could be used by or on behalf of Nalpeiron to identify an individual, but not including encoded, anonymized, or publically-available data that has not been combined with non-public personal information. Personal information means any information that may be used to identify an individual, including, but not limited to, a first and last name, email address, a company or home, postal or other physical address, other contact information, title, birth date, gender, occupation, industry, personal or product interests, other information when needed to provide a service you requested.
Nalpeiron collects personal information when you register with Nalpeiron for a Nalpeiron account (When You register for the Service, 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. When You pay for the 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.
Nalpeiron may use the personal information and other information We collect about your use of the Service to operate the Service and tailor it to your needs, for billing, identification and authentication, to contact You about your use of the Service, send you marketing materials (subject to your opt-out option), for research purposes, and to generally improve the content and functionality of the Service and the 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.
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.
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 aggregated or anonymized information that does not directly identify you with the third parties described above.
• Customers of Nalpeiron may electronically submit data or information to the Company’s services (“Customer Data”).
• Nalpeiron will not review, share, distribute, or reference any such Customer Data except as provided in the Nalpeiron terms of service, or as may be required by law. In accordance with the terms of service, Nalpeiron may access Customer Data only for the purposes of providing the services, 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.
Cookies and Transparent Gifs
A “cookie” is a small software file stored temporarily (session cookie) or placed on your computer’s hard drive (persistent cookie) - see here for more details:http://en.wikipedia.org/wiki/HTTP_cookie. The general purpose of a cookie is to allow a web server to identify a user’s computer and web browser, and tailor web pages and/or login information to the user’s preferences. Cookies help us promptly display the information You need and other information which We consider to be of interest to You. By gathering and remembering information about your website preferences through cookies We can provide a better web and marketing experience. Cookies don’t give us access to users’ computers, and the information we collect through cookies doesn’t include personal information.
When You visit the Site or use the Service We use “session cookies” to allow us to uniquely identify your browser while You are logged in, and to process your online transactions. We also use “persistent cookies” that only We can read and use, to identify You as a Nalpeiron customer and make it easier for You to log into the Service.
• Essential cookies: Some of the cookies We use are critical to the functionality of our Site. They are used to keep a user logged into the Site and remember relevant information when the user returns to the Site and uses the Service.
• Functional cookies: We also use certain cookies to track users’ activities on the Site, understand their preferences within the Site and improve their user experience.
• Marketing cookies: A third set of cookies is provided by third parties and allows us to deliver customized marketing information to our customers based on their Site usage profile and avoid delivering irrelevant marketing to customers.
• Transparent gifs: Our third-party tracking utility company employs a software technology called clear gifs that helps us better manage content on our Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users.
Unlike cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages. We tie the information gathered by clear gifs to our customers’ personal information, and use them in our HTML-based emails to learn which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and our marketing campaigns. Customers can opt-out of these emails by following the unsubscribe instructions within such marketing emails.
• Click here to learn more about the “Private Browsing” setting and cookie setting in FireFox;
• Click here to learn more about “Incognito” and cookie setting in Chrome;
• Click here to learn more about “InPrivate” and cookie setting in Internet Explorer; or
• Click here to learn more about “Private Browsing” and cookie setting in Safari.
If You want to learn more about cookies, or how to control or delete them, please visit http://www.aboutcookies.org for detailed guidance. If You disable Your web browser’s ability to accept cookies You still will be able to browse our Site, but might not be able to access or take advantage of the many Service features.
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 the Service to individual customers. Otherwise We mostly use this information with no connection to individual users, to analyze trends, administer the Site, or track usage of various features within the 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.
From time to time, We post customer testimonials on the Site which may contain personal information. We do obtain the customers’ consent to post their names along with their testimonials.
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.
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 the Site or used within the Service, 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 safe, secure, and only available to You and to those You authorized access.
Safe Harbor Data Privacy Notice for European Union Web site visitors and clients
Nalpeiron complies with the US – EU and US – Swiss Safe Harbor Frameworks for protecting the privacy of data flowing from the EU and Switzerland to the US, as set forth by the US Department of Commerce. Below We outline our practices for implementing the Safe Harbor Principles, including the type of information to which this notice applies, how We collect, use and retain personal information from EU member countries and Switzerland, and the choices individuals have regarding our use of, and their ability to correct, their personal information.
EU and End User Privacy and Data Use
We frequently enter agreements with our EU customers to provide them our Service, which includes the processing of information relating to our customers’ customers. In providing our Service We do not own, control or direct the use of the information stored or processed on our platform at the direction of our customers, and 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 customers or as required by law. Only You or your customers are entitled to access, retrieve and direct the use of such information. As such, We are only the “data processors” and not the “data controllers” of the information on our platform for purposes of the EU Directive on Data Protection (Directive 95/45/EC) and the Swiss Federal Act on Data Protection. Our EU or Swiss customers, who control their customer data and send it to Nalpeiron for processing, are the “controllers” of that data and are responsible for compliance with the Directive.
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.
Where Nalpeiron collects personal information directly from its EU customers, it informs them about the purpose for which it collects and uses their personal information and how to contact Nalpeiron. By providing your Personal Information, you consent to any transfer and processing in accordance with this Policy.
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 the Directive and relevant data protection legislation in the relevant EU member state 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.
Third-party Data Transfers
We may transfer personal information to our third-party vendors that help us provide the 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. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice, and the service agreements with our customers. Otherwise We may also share personal information as is required or permitted by law.
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 atwww.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 such individual interacts (the data controller). At the request of our customers We remove data within 30 business days.
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.
Data storage, transfer and security
Nalpeiron hosts data with hosting service providers in the United States and UK. The servers on which Personal Information is stored are kept in a controlled environment. While we take reasonable efforts to guard your Personal Information, no security system is impenetrable and due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that information, during transmission through the Internet or while stored on our systems or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers. In addition, we cannot guarantee that any passively-collected Personal Information you choose to store in Websites or SaaS Products are maintained at levels of protection to meet specific needs or obligations you may have relating to that information. Where data is transferred over the Internet as part of a Website or SaaS Product, the data is encrypted using industry standard SSL (HTTPS).
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.
Information we do not share
We do not share Personal Information about you with third parties for their marketing purposes (including direct marketing purposes) without your permission.
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 the Site. We encourage You to periodically review this page for the latest information on our privacy practices. Your continued use of the 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 the Site and Service.