Last updated August 26, 2024
This Privacy Notice
for Naybrs, Inc.
( "we," "us," or
"our" ), describes how and why we might access, collect, store, use, and/or
share ( "process" ) your personal information when you use our services (
"Services" ), including when you:
- Visit our
website
at https://naybrs.com , or any website of ours that links to this Privacy Notice
- Download and
use
our mobile application ( Naybrs) , or any other application of ours that links to this Privacy Notice
- Use
Naybrs .Naybrs is a platform that aims to facilitate closer relationships between individuals in local communities
- Engage with us
in other related ways, including any sales, marketing, or events
Questions or concerns? Reading this Privacy Notice
will help you understand your privacy rights and choices. We are responsible for making decisions
about how your personal information is processed. If you do not agree with our policies and
practices, please do not use our Services. If you still have any
questions or concerns, please contact us at enquiries@naybrs.com
.
SUMMARY OF
KEY POINTS
This
summary provides key points from our Privacy Notice, but you can find out more details about any
of these topics by clicking the link following each key point or by using
our table
of contents below to find the section you are looking
for.
What
personal information do we process? When you visit, use, or navigate our Services, we may
process personal information depending on how you interact with us and the Services, the choices you
make, and the products and features you use. Learn more about personal information you disclose to us.
Do we
process any sensitive personal information? Some of the information may be considered "special" or "sensitive"
in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious
beliefs. We may process sensitive personal information when necessary
with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.
Do we
collect any information from third parties?
We do not collect any information from third parties.
How do we
process your information? We process your information to provide, improve, and administer
our Services, communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your consent. We process your information only
when we have a valid legal reason to do so. Learn more about how we process your information.
In what
situations and with which parties do we share personal
information? We may share information in specific situations and with specific third parties. Learn more about when and with whom we share your personal
information.
How do we
keep your information safe? We have adequate
organizational and technical processes and procedures in
place to protect your personal information. However, no electronic transmission over the internet or
information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee
that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and
improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.
What are
your rights? Depending on where you are located geographically, the applicable privacy law
may mean you have certain rights regarding your personal information. Learn more about your privacy rights.
How do you
exercise your rights? The easiest way to exercise your rights is by visiting
https://naybrs.com/p/data-request
, or by contacting us. We will consider and act upon any request in
accordance with applicable data protection laws.
Want to learn more
about what we do with any information we collect? Review the Privacy Notice in full.
TABLE OF CONTENTS
1. WHAT INFORMATION
DO WE COLLECT?
Personal information you disclose to
us
In
Short: We collect personal
information that you provide to
us.
We collect personal
information that you voluntarily provide to us when you
register on the Services,
express an interest in obtaining information
about us or our products and Services, when you participate in activities on the Services, or
otherwise when you contact us.
Personal
Information Provided by You. The personal information that we collect depends on the
context of your interactions with us and the Services, the choices you make, and the products and
features you use. The personal information we collect may include the following:
-
names
-
phone numbers
-
email addresses
-
mailing addresses
-
passwords
-
contact preferences
-
billing addresses
-
contact or authentication data
Sensitive Information.
When necessary, with your consent or as otherwise permitted by
applicable law, we process the following categories of sensitive information:
-
social security numbers or other government identifiers
Payment
Data. We may collect data necessary to process your payment if you choose to make
purchases, such as your payment instrument number, and the security code associated with your
payment instrument. All payment data is handled and stored by
Stripe
.
You may find their privacy notice link(s) here:
https://stripe.com/en-ca/legal/privacy-center
.
Social
Media Login Data. We may provide you with the option to register with us using your
existing social media account details, like your Facebook, X, or other social media account. If you
choose to register in this way, we will collect certain profile information about you from the
social media provider, as described in the section called " HOW
DO WE HANDLE YOUR SOCIAL LOGINS?
" below.
Application Data. If you use our application(s), we also may
collect the following information if you choose to provide us with access or permission:
- Geolocation Information. We may request access or permission to
track location-based information from your mobile device, either continuously or while you are using
our mobile application(s), to provide certain location-based services. If you wish to change our
access or permissions, you may do so in your device's settings.
- Mobile Device Access. We may request access or permission to
certain features from your mobile device, including your mobile device's
camera ,sensors ,and other features. If you wish to change our access or permissions, you may do so in your device's settings.
- Mobile Device Data. We automatically collect device
information (such as your mobile device ID, model, and manufacturer), operating system, version
information and system configuration information, device and application identification numbers,
browser type and version, hardware model Internet service provider and/or mobile carrier, and
Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also
collect information about the phone network associated with your mobile device, your mobile device’s
operating system or platform, the type of mobile device you use, your mobile device’s unique device
ID, and information about the features of our application(s) you accessed.
- Push Notifications. We may request to send you push
notifications regarding your account or certain features of the application(s). If you wish to opt
out from receiving these types of communications, you may turn them off in your device's settings.
This information
is primarily needed to maintain the security and operation of our application(s), for troubleshooting,
and for our internal analytics and reporting purposes.
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.
Information automatically collected
In
Short: Some information — such
as your Internet Protocol (IP) address and/or browser and device characteristics
— is collected automatically when you visit our
Services.
We automatically
collect certain information when you visit, use, or navigate the Services. This information does not
reveal your specific identity (like your name or contact information) but may include device and
usage information, such as your IP address, browser and device characteristics, operating system,
language preferences, referring URLs, device name, country, location, information about how and when
you use our Services, and other technical information. This information is primarily needed to
maintain the security and operation of our Services, and for our internal analytics and reporting
purposes.
Like many
businesses, we also collect information through cookies and similar technologies.
The information we
collect includes:
- Log and
Usage Data. Log and usage data is service-related, diagnostic, usage, and performance
information our servers automatically collect when you access or use our Services and which we
record in log files. Depending on how you interact with us, this log data may include your IP
address, device information, browser type, and settings and information about your activity in
the Services (such as the date/time stamps associated with
your usage, pages and files viewed, searches, and other actions you take such as which features
you use), device event information (such as system activity, error reports (sometimes called
"crash dumps" ), and hardware settings).
- Device
Data. We collect device data such as information about your computer, phone, tablet, or
other device you use to access the Services. Depending on the device used, this device data may
include information such as your IP address (or proxy server), device and application
identification numbers, location, browser type, hardware model, Internet service provider and/or
mobile carrier, operating system, and system configuration information.
- Location
Data. We collect location data such as information about your device's location, which
can be either precise or imprecise. How much information we collect depends on the type and
settings of the device you use to access the Services. For example, we may use GPS and other
technologies to collect geolocation data that tells us your current location (based on your IP
address). You can opt out of allowing us to collect this information either by refusing access
to the information or by disabling your Location setting on your device. However, if you choose
to opt out, you may not be able to use certain aspects of the Services.
Google
API
Our use of
information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
2. HOW DO WE
PROCESS YOUR INFORMATION?
In Short: We process
your information to provide, improve, and administer our Services, communicate
with you, for security and fraud prevention, and to comply with law. We may also
process your information for other purposes with your
consent.
We process
your personal information for a variety of reasons, depending on how you interact with our
Services, including:
- To
facilitate account creation and authentication and otherwise manage user
accounts. We may process your information so you can create and log in to your
account, as well as keep your account in working order.
- To
deliver and facilitate delivery of services to the user. We may process your
information to provide you with the requested service.
- To respond to user inquiries/offer support to
users. We may process your information to respond to your inquiries and
solve any potential issues you might have with the requested service.
- To send administrative information to
you. We may process your information to send you details about our
products and services, changes to our terms and policies, and other similar
information.
- To
fulfill and manage your orders. We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
- To request feedback. We may
process your information when necessary to request feedback and to contact
you about your use of our Services.
- To send you marketing and promotional
communications. We may process the personal information you
send to us for our marketing purposes, if this is in accordance with your
marketing preferences. You can opt out of our marketing emails at any time.
For more information, see
" WHAT ARE YOUR PRIVACY RIGHTS? " below.
- To deliver
targeted advertising to you. We may process your information to
develop and display
personalized content and advertising tailored to your interests, location, and more.
- To
protect our Services. We may process your information
as part of our efforts to keep our Services safe and secure,
including fraud monitoring and prevention.
- To identify usage
trends. We may process information about
how you use our Services to better understand how they
are being used so we can improve them.
-
To determine
the effectiveness of our marketing and
promotional campaigns. We may process
your information to better understand how to provide
marketing and promotional campaigns that are most
relevant to you.
-
To save or
protect an individual's vital
interest. We may process your
information when necessary to save or protect an
individual’s vital interest, such as to prevent
harm.
3. WHAT LEGAL
BASES DO WE RELY ON TO PROCESS YOUR
INFORMATION?
In
Short: We only process your
personal information when we believe it is
necessary and we have a valid legal reason (i.e.
,
legal basis) to do so under applicable law, like
with your consent, to comply with laws, to
provide you with services to enter into or fulfill
our contractual obligations, to protect your
rights, or to
fulfill
our legitimate business
interests.
If you
are located in the EU or UK, this
section applies to
you.
The General Data
Protection Regulation (GDPR) and UK GDPR require us
to explain the valid legal bases we rely on in order
to process your personal information. As such, we
may rely on the following legal bases to process
your personal information:
-
Consent. We
may process your information if you have given
us permission (i.e.
, consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
-
Performance of
a Contract. We may process your
personal information when we believe it is
necessary to
fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
- Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
-
Send users information
about special offers and discounts on our
products and services
-
Develop and display
personalized and relevant advertising content for our users
-
Analyze how our Services are used so we can improve them to engage and retain users
-
Support our marketing
activities
-
Diagnose problems
and/or prevent fraudulent activities
-
Understand how our
users use our products and services so we can
improve user experience
-
Legal
Obligations. We may process your
information where we believe it is necessary for
compliance with our legal obligations, such as
to cooperate with a law enforcement body or
regulatory agency, exercise or defend our legal
rights, or disclose your information as evidence
in litigation in which we are involved.
-
Vital
Interests. We may process your
information where we believe it is necessary to
protect your vital interests or the vital
interests of a third party, such as situations
involving potential threats to the safety of any
person.
If you are
located in Canada, this section applies
to you.
We may process your
information if you have given us specific permission
(i.e. ,
express consent) to use your personal information
for a specific purpose, or in situations where your
permission can be inferred (i.e. ,
implied consent). You can withdraw
your consent at any time.
In some exceptional cases,
we may be legally permitted under applicable law to
process your information without your consent,
including, for example:
- If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
-
For investigations and
fraud detection and prevention
-
For business
transactions provided certain conditions are
met
-
If it is contained in a
witness statement and the collection is
necessary to assess, process, or settle an
insurance claim
-
For identifying
injured, ill, or deceased persons and
communicating with next of kin
-
If we have reasonable
grounds to believe an individual has been, is,
or may be victim of financial abuse
-
If it is reasonable to
expect collection and use with consent would
compromise the availability or the accuracy of
the information and the collection is reasonable
for purposes related to investigating a breach
of an agreement or a contravention of the laws
of Canada or a province
-
If disclosure is
required to comply with a subpoena, warrant,
court order, or rules of the court relating to
the production of records
-
If it was produced
by an individual in the course of their
employment, business, or profession and the
collection is consistent with the purposes for
which the information was produced
-
If the collection
is solely for journalistic, artistic, or
literary purposes
-
If the information
is publicly available and is specified by the
regulations
In
Short: We may share
information in specific situations described
in this section and/or with the following
third
parties.
We may need to share
your personal information in the following
situations:
- Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
-
When we
use Google Maps Platform APIs. We
may share your information with certain Google
Maps Platform APIs (e.g.
, Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. GPS is accurate to about 20 meters, while Wi-Fi and cell towers help improve accuracy when GPS signals are weak, like indoors. This data helps Google Maps provide directions, but it is not always perfectly precise. We obtain and store on your device ( "cache" ) your location . You may revoke your consent anytime by contacting us at the contact details provided at the end of this document.
- Offer
Wall. Our
application(s) may display a
third-party hosted
"offer wall." Such an offer wall allows third-party advertisers to offer virtual currency, gifts, or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.
5.
WHAT IS OUR STANCE ON THIRD-PARTY
WEBSITES?
In
Short: We are
not responsible for the safety of
any information that you share with
third parties that we may link to or
who advertise on our Services, but
are not affiliated with, our
Services.
The
Services
,
including our offer wall,
may link to third-party websites,
online services, or mobile applications
and/or contain advertisements from third
parties that are not affiliated with us
and which may link to other websites,
services, or applications. Accordingly,
we do not make any guarantee regarding
any such third parties, and we will not
be liable for any loss or damage caused
by the use of such third-party websites,
services, or applications. The inclusion
of a link towards a third-party website,
service, or application does not imply
an endorsement by us. We cannot
guarantee the safety and privacy of data
you provide to any third-party websites.
Any data collected by third parties is
not covered by this Privacy Notice. 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 the Services. You should review the
policies of such third parties and
contact them directly to respond to your
questions.
In
Short: We
may use cookies and other
tracking technologies to collect
and store your
information.
We may
use cookies and similar tracking
technologies (like web beacons and
pixels) to gather information when
you interact with our Services. Some
online tracking technologies help us
maintain the security of our
Services
and your account
, prevent crashes, fix bugs,
save your preferences, and assist
with basic site
functions.
We
also permit third parties and
service providers to use online
tracking technologies on our
Services for analytics and
advertising, including to help
manage and display advertisements,
to tailor advertisements to your
interests, or to send abandoned
shopping cart reminders (depending
on your communication preferences).
The third parties and service
providers use their technology to
provide advertising about products
and services tailored to your
interests which may appear either on
our Services or on other
websites.
To the
extent these online tracking
technologies are deemed to be a
"sale"/"sharing"
(which includes targeted
advertising, as defined under the
applicable laws) under applicable US
state laws, you can opt out of these
online tracking technologies by
submitting a request as described below
under section "
DO
UNITED STATES RESIDENTS HAVE
SPECIFIC PRIVACY
RIGHTS?
"
Specific
information about how we use such
technologies and how you can refuse
certain cookies is set out in our
Cookie Notice
.
Google
Analytics
We may
share your information with Google
Analytics to track and
analyze
the use of the Services. The
Google Analytics Advertising Features
that we may use include:
Remarketing with
Google Analytics
,
Google Display
Network Impressions Reporting
and
Google Analytics
Demographics and Interests Reporting
.
To opt out of being tracked by
Google Analytics across the Services,
visit https://tools.google.com/dlpage/gaoptout.
You
can opt out of Google Analytics
Advertising Features through Ads
Settings and Ad
Settings for mobile apps. Other opt out
means include http://optout.networkadvertising.org/
and http://www.networkadvertising.org/mobile-choice.
For more information on the
privacy practices of Google, please
visit the Google Privacy &
Terms page.
In
Short: If
you choose to register or log in
to our Services using a social
media account, we may have
access to certain information
about
you.
Our
Services offer you the ability to
register and log in using your
third-party social media account
details (like your Facebook or X
logins). Where you choose to do
this, we will receive certain
profile information about you from
your social media provider. The
profile information we receive may
vary depending on the social media
provider concerned, but will often
include your name, email address,
friends list, and profile picture,
as well as other information you
choose to make public on such a
social media platform.
We
will use the information we receive
only for the purposes that are
described in this Privacy Notice or
that are otherwise made clear to you
on the relevant Services. Please
note that we do not control, and are
not responsible for, other uses of
your personal information by your
third-party social media provider.
We recommend that you review their
privacy notice to understand how
they collect, use, and share your
personal information, and how you
can set your privacy preferences on
their sites and apps.
8.
IS YOUR INFORMATION
TRANSFERRED
INTERNATIONALLY?
In
Short: We
may transfer, store, and process
your information in countries
other than your
own.
Our
servers are located in
the
United
States
. If
you are accessing our Services from
outside
the
United
States
, please be
aware that your information may be
transferred to, stored by, and processed by
us in our facilities and in the facilities
of the third parties with whom we may share
your personal information (see "
WHEN
AND WITH WHOM DO WE SHARE YOUR
PERSONAL
INFORMATION?
"
above), in
and
other
countries.
If you
are a resident in the European
Economic Area (EEA), United Kingdom
(UK), or Switzerland, then these
countries may not necessarily have
data protection laws or other
similar laws as comprehensive as
those in your country. However, we
will take all necessary measures to
protect your personal information in
accordance with this Privacy Notice
and applicable law.
European
Commission's Standard Contractual
Clauses:
We
have implemented measures to protect
your personal information, including
by using the European Commission's
Standard Contractual Clauses for
transfers of personal information
between our group companies and
between us and our third-party
providers. These clauses require all
recipients to protect all personal
information that they process
originating from the EEA or UK in
accordance with European data
protection laws and
regulations.
Our
Standard Contractual Clauses can be
provided upon request.
We
have implemented similar appropriate
safeguards with our third-party
service providers and partners and
further details can be provided upon
request.
9.
HOW LONG DO WE KEEP
YOUR
INFORMATION?
In
Short: We
keep your information for as
long as necessary to
fulfill
the purposes outlined in
this Privacy Notice unless
otherwise required by
law.
We
will only keep your personal
information for as long as it is
necessary for the purposes set out
in this Privacy Notice, unless a
longer retention period is required
or permitted by law (such as tax,
accounting, or other legal
requirements).
No purpose in this notice will
require us keeping your personal
information for longer than
the period of time in which users
have an account with us
.
When
we have 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),
then we will securely store your
personal information and isolate it
from any further processing until
deletion is possible.
10.
HOW DO WE KEEP YOUR
INFORMATION
SAFE?
In
Short: We
aim to protect your personal
information through a system of
organizational
and technical security
measures.
We
have implemented appropriate and
reasonable technical and
organizational
security measures designed to
protect the security of any personal
information we process. However,
despite our safeguards and efforts
to secure your information, no
electronic transmission over the
Internet or information storage
technology can be guaranteed to be
100% secure, so we cannot promise or
guarantee that hackers,
cybercriminals, or other
unauthorized
third parties will not be
able to defeat our security and
improperly collect, access, steal,
or modify your information. Although
we will do our best to protect your
personal information, transmission
of personal information to and from
our Services is at your own risk.
You should only access the Services
within a secure environment.
11.
WHAT ARE YOUR
PRIVACY
RIGHTS?
In
Short:
Depending on your state of
residence in the US or in
some regions, such as
the European Economic Area
(EEA), United Kingdom (UK),
Switzerland, and Canada
, you have rights that
allow you greater access to and
control over your personal
information.
You
may review, change, or terminate
your account at any time,
depending on your country,
province, or state of residence.
In
some regions (like
the EEA, UK, Switzerland, and Canada
), you have certain rights under
applicable data protection laws.
These may include the right (i) to
request access and obtain a copy of
your personal information, (ii) to
request rectification or erasure;
(iii) to restrict the processing of
your personal information; (iv) if
applicable, to data portability; and
(v) not to be subject to automated
decision-making. In certain
circumstances, you may also have the
right to object to the processing of
your personal information. You can
make such a request by contacting us
by using the contact details
provided in the section "
HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
"
below.
We
will consider and act upon any
request in accordance with
applicable data protection laws.
If you
are located in the EEA or UK and you
believe we are unlawfully processing
your personal information, you also
have the right to complain to your
Member
State
data
protection
authority
or UK
data protection
authority.
If you
are located in Switzerland, you may
contact the Federal
Data
Protection
and
Information
Commissioner.
Withdrawing
your consent:
If we are relying on your consent to
process your personal information,
which may be express and/or implied
consent depending on the applicable
law,
you have the right to
withdraw your consent at any time.
You can withdraw your consent at any
time by contacting us by using the
contact details provided in the
section "
HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
"
below
or updating your preferences
.
However,
please note that this will not affect
the lawfulness of the processing before
its withdrawal nor, when
applicable law allows,
will it affect the processing of
your personal information conducted in
reliance on lawful processing grounds
other than consent.
Opting
out of marketing and promotional
communications: You
can unsubscribe from our marketing and
promotional communications at any time
by
clicking on the unsubscribe link in the
emails that we send,
replying
"STOP" or "UNSUBSCRIBE"
to the SMS messages that we send,
or
by contacting us using the details
provided in the section "
HOW
CAN YOU CONTACT US ABOUT THIS
NOTICE?
"
below. You will then be removed
from the marketing lists. However, we
may still communicate with you — for
example, to send you service-related
messages that are necessary for the
administration and use of your account,
to respond to service requests, or for
other non-marketing purposes.
Account
Information
If you would at
any time like to review or change the
information in your account or terminate
your account, you can:
-
Log in to your account settings and update your user account.
-
Contact us using the contact information provided.
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
legal terms and/or comply with
applicable legal
requirements.
Cookies
and similar
technologies:
Most Web browsers are set to accept
cookies by default. If you prefer,
you can usually choose to set your
browser to remove cookies and to
reject cookies. If you choose to
remove cookies or reject cookies,
this could affect certain features
or services of our Services.
You may also opt
out of
interest-based
advertising by
advertisers
on our Services.
If you have
questions or comments about your privacy
rights, you may email us at
enquiries@naybrs.com
.
12.
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, we do 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 we must follow in the
future, we will inform you about
that practice in a revised version
of this Privacy
Notice.
California
law requires us to let you know how we
respond to web browser DNT signals.
Because there currently is not an
industry or legal standard for
recognizing
or
honoring
DNT signals, we do not respond to
them at this time.
13.
DO UNITED STATES
RESIDENTS HAVE
SPECIFIC PRIVACY
RIGHTS?
In
Short: If
you are a resident of
California, Colorado,
Connecticut, Delaware, Florida,
Indiana, Iowa, Kentucky,
Montana, New Hampshire, New
Jersey, Oregon, Tennessee,
Texas, Utah, or Virginia ,
you may have the right to
request access to and receive
details about the personal
information we maintain about
you and how we have processed
it, correct inaccuracies, get a
copy of, or delete your personal
information. You may also have
the right to withdraw your
consent to our processing of
your personal information. These
rights may be limited in some
circumstances by applicable law.
More information is provided
below.
Categories
of Personal Information We
Collect
We
have collected the following
categories of personal information
in the past twelve (12)
months:
| Category | Examples | Collected |
|
A.
Identifiers
|
Contact
details, such as
real name, alias,
postal address,
telephone or mobile
contact number,
unique personal
identifier, online
identifier, Internet
Protocol address,
email address, and
account
name
|
|
|
B.
Personal information
as defined in the
California Customer
Records
statute
|
Name,
contact information,
education,
employment,
employment history,
and financial
information
|
|
|
|
Gender,
age, date of birth,
race and ethnicity,
national origin,
marital status, and
other demographic
data
|
|
|
|
Transaction
information,
purchase history,
financial details,
and payment
information
|
|
|
|
Fingerprints
and
voiceprints
|
|
|
|
Browsing
history, search
history, online
|
|
|
|
Device
location
|
|
|
|
Images
and audio, video or
call recordings
created in
connection with our
business
activities
|
|
|
|
Business
contact details in
order to provide you
our Services at a
business level or
job title, work
history, and
professional
qualifications if
you apply for a job
with
us
|
|
|
|
Student
records and
directory
information
|
|
|
|
Inferences
drawn from any of
the collected
personal information
listed above to
create a profile or
summary about, for
example, an
individual’s
preferences and
characteristics
|
|
|
|
|
|
We only
collect sensitive personal information,
as defined by applicable privacy laws or
the purposes allowed by law or with your
consent. Sensitive personal information
may be used, or disclosed to a service
provider or contractor, for additional,
specified purposes. You may have the
right to limit the use or disclosure of
your sensitive personal information.
We may
also collect other personal information
outside of these categories through
instances where you interact with us in
person, online, or by phone or mail in
the context of:
- Receiving help
through our customer support channels;
- Participation
in customer surveys or contests; and
- Facilitation in
the delivery of our Services and to
respond to your inquiries.
- Category A
-
As long as the user has an account with us
- Category B
-
As long as the user has an account with us
- Category
C - As long as the user has an account with us
- Category
D - As long as the user has an account with us
- Category
E - As long as the user has an account with us
- Category
F - As long as the user has an account with us
- Category
G - As long as the user has an account with us
- Category
H - As long as the user has an account with us
- Category
K -As long as the user has an account with us
- Category
L -As long as the user has an account with us
Sources
of Personal
Information
Learn
more about the sources of
personal information we collect
in
"
WHAT
INFORMATION DO WE
COLLECT?
"
How
We Use and Share
Personal
Information
Learn about
how we use your personal information
in the section, "
HOW
DO WE PROCESS YOUR
INFORMATION?
"
Will
your information be
shared with anyone
else?
We
may disclose your personal
information with our service
providers pursuant to a
written contract between us
and each service provider.
Learn more about how we
disclose personal
information to in the
section,
"
WHEN
AND WITH WHOM DO WE SHARE
YOUR PERSONAL
INFORMATION?
"
We
may use your personal
information for our own
business purposes, such as
for undertaking internal
research for technological
development and
demonstration. This is not
considered to be
"selling"
of your personal
information.
We
have not disclosed, sold, or
shared any personal
information to third parties
for a business or commercial
purpose in the preceding
twelve (12) months. We will
not sell or share personal
information in the future
belonging to website
visitors, users, and other
consumers.
Your
Rights
You
have rights under certain US
state data protection laws.
However, these rights are not
absolute, and in certain cases,
we may decline your request as
permitted by law. These rights
include:
- Right
to know whether or
not we are processing your
personal data
- Right
to access your
personal data
- Right
to
correct inaccuracies
in your personal data
- Right
to request the
deletion of your personal data
- Right
to obtain a copy of
the personal data you previously
shared with us
- Right
to
non-discrimination
for exercising your rights
- Right
to opt out of the
processing of your personal data
if it is used for targeted
advertising
(or sharing as defined under California’s privacy law) , the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ( "profiling" )
Depending
upon the state where you live,
you may also have the following
rights:
- Right
to obtain a list of the
categories of third parties to
which we have disclosed personal
data (as permitted by applicable
law, including
California's and Delaware'sprivacy law)
- Right
to obtain a list of specific
third parties to which we have
disclosed personal data (as
permitted by applicable law,
including Oregon’s privacy
law)
- Right
to limit use and disclosure of
sensitive personal data (as
permitted by applicable law,
including California’s privacy
law)
- Right
to opt out of the collection of
sensitive data and personal data
collected through the operation
of a voice or facial recognition
feature (as permitted by
applicable law, including
Florida’s privacy law)
How
to Exercise Your
Rights
To
exercise these rights, you
can contact us
by visiting
https://naybrs.com/p/data-request
,
by
emailing us at
enquiries@naybrs.com
,
or by
referring to the contact details at
the bottom of this
document.
Under
certain US state data protection
laws, you can designate an
authorized
agent to make a request
on your behalf. We may deny a
request from an
authorized
agent that does not
submit proof that they have been
validly
authorized
to act on your behalf in
accordance with applicable
laws.
Request
Verification
Upon
receiving your request, we will
need to verify your identity to
determine you are the same
person about whom we have the
information in our system. We
will only use personal
information provided in your
request to verify your identity
or authority to make the
request. However, if we cannot
verify your identity from the
information already maintained
by us, we may request that you
provide additional information
for the purposes of verifying
your identity and for security
or fraud-prevention
purposes.
If
you submit the request through
an
authorized
agent, we may need to
collect additional information
to verify your identity before
processing your request and the
agent will need to provide a
written and signed permission
from you to submit such request
on your behalf.
Appeals
Under
certain US state data protection
laws, if we decline to take
action regarding your request,
you may appeal our decision by
emailing us at
enquiries@naybrs.com
.
We will inform you in writing of
any action taken or not taken in
response to the appeal,
including a written explanation
of the reasons for the
decisions. If your appeal is
denied, you may submit a
complaint to your state attorney
general.
Financial
Incentives
The
law permits financial
incentives or a price or
service difference if it is
reasonably related to the
value of the consumer’s
data. A business must be
able to explain how the
financial incentive or price
or service difference is
reasonably related to the
value of the consumer’s
data. The explanation must
include:
- a
good-faith estimate of
the value of the
consumer’s data that
forms the basis for
offering the financial
incentive or price or
service difference;
and
- a
description of the
method the business used
to calculate the value
of the consumer’s
data.
We
may decide to offer
a
"bona fide loyalty
program"
under Colorado law
, or
a
"financial incentive"
under California law
(e.g.
,
price or service
difference) in exchange for
the retention, sale, or
sharing of a consumer’s
personal information.
If
we decide to offer a
financial incentive, we will
notify you of such financial
incentive and explain the
price difference, as well as
material terms of the
financial incentive or price
of service difference,
including the categories of
personal information that
are implicated by the
financial incentive or price
or service
difference.
Under
California law, the value of
your personal information to us
is related to the value of the
free or discounted products or
services, or other benefits that
you obtain or that are provided
as part of the applicable
program, less the expense
related to offering those
products, services, and benefits
to program
participants.
If
you choose to participate in
the financial incentive you
can withdraw from the
financial incentive at any
time
by
emailing
us at
enquiries@naybrs.com
,
or by
referring to the contact details at
the bottom of this
document.
California
"Shine The Light"
Law
California
Civil Code Section 1798.83, also
known as the
"Shine The Light"
law, permits our users
who are California residents to
request and obtain from us, once
a year and free of charge,
information about categories of
personal information (if any) we
disclosed to third parties for
direct marketing purposes and
the names and addresses of all
third parties with which 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 by using the
contact details provided in the
section
"
HOW
CAN YOU CONTACT US ABOUT
THIS
NOTICE?
"
14.
DO WE MAKE
UPDATES TO
THIS
NOTICE?
In
Short: Yes,
we will update this
notice as necessary to
stay compliant with
relevant
laws.
We
may update this Privacy
Notice from time to time.
The updated version will be
indicated by an updated
"Revised"
date at the top of
this Privacy Notice. If we
make material changes to
this Privacy Notice, we may
notify you either by
prominently posting a notice
of such changes or by
directly sending you a
notification. We encourage
you to review this Privacy
Notice frequently to be
informed of how we are
protecting your
information.
15.
HOW CAN YOU
CONTACT US
ABOUT THIS
NOTICE?
If
you have questions or
comments about this notice,
you may
email us at
enquiries@naybrs.com
or
contact
us by post
at:
16.
HOW CAN YOU
REVIEW,
UPDATE, OR
DELETE THE
DATA WE
COLLECT FROM
YOU?