Privacy Policy
As we state in our Laws of Data Protection, we are committed to protecting the privacy of your data. This Privacy Policy explains more specifically what information NuVuw Limited and its Group Companies (together, “NuVuw,” “we” or “us”) collect from Account Holders and End Users (“you”) through NuVuw’s websites and applications, which we refer to collectively as “the Service.” The Service includes the NuVuw Software.
Please note, if you use NuVuw Home Owner, you are both the Account Holder and End User of an NuVuw service account. If you use NuVuw Business, the Account Holder is the Business Customer who has contracted with NuVuw as defined in our NuVuw Business Agreement and the End Users are the individuals whose user accounts are linked to that NuVuw Business account. You can find these and other defined terms used in this policy in our Glossary at the end of this page.
Although significant changes are rare, this policy may be amended as new features, technology, or legal requirements arise, so please check back from time to time. We’ll notify you if we make a significant change and, where required, seek your consent.
What information does NuVuw collect?
We built NuVuw to help you remember and organize your ideas, thoughts, and memories. That means you can input, upload, or store in NuVuw any text, images, and other data that you choose—we refer to that information as “Content”. We also collect and receive the following types of information:
- Basic subscriber information.To open your account and process payments, we collect and receive basic information like your email address and, depending on how you purchase a subscription to NuVuw Home Owner, Trade Professional or NuVuw Small Business (each a “Paid Service”), your billing address and other payment information.
- Usage data.We collect and log data on how you and others access and use NuVuw, for example, the act of creating a note or sharing a note. Usage data may be collected through cookies, and similar technologies. For more information, including how to opt-out, visit our Cookie Information page.
- Location information.We collect the IP address you use to connect to the Service, and — if you choose to share it — your location information from a mobile device.
- Device information.We collect information about the number and type of devices you use to connect to the Service, as well as information about the operating systems on those devices (e.g., iOS, Android, Windows).
We also may link your subscriber information with data we receive from our partners and other third parties to help understand your needs and provide you with a better experience. For example, if you create or log into an NuVuw account using your Facebook or Google Apps credentials via single sign-on, we will have access to certain information such as your name and email address as authorized in your Facebook or Google Apps profile settings.
How does NuVuw use my information?
We have specific rules for how and when we use the information we collect and receive. We describe these below.
What does NuVuw do with my information?
We are committed to protecting the privacy of your information. Below, we describe the ways in which we use the information we collect and receive to provide, maintain, and improve the Service; to provide troubleshooting and Business Customer support; to protect the Service for all our users; to contact you; and to administer NuVuw Business accounts.
- We use a number of technologies to help you get the most out of the Service. Our systems automatically analyse your data to power NuVuw features and to continually improve the Service for you in a way that does not require anyone to look at your Content. This may include, for example:
- Making sure you find what you’re looking for when you search your account.
- Showing you information most relevant to how you are or could be using the Service at a specific time or location.
- Suggesting actions for you to take based on information you’ve stored.
- Suggesting NuVuw service features or products to you that we think will help you get the most out of our Service.
- For NuVuw Business users, recommending people for you to collaborate with.
- To provide troubleshooting and Business Customer support, our Business Customer Support team may need to access your information, such as your account email address and information about the NuVuw application you are using, subject to the protections described below.
- As part of our efforts to protect your account and the functionality of the Service, our systems may analyze the emails you send to and from your NuVuw account and the notes you share to detect spam, malware, or other potential security concerns. If we determine that such material constitutes aTerms of Service or User Guidelines violation, we may block delivery of or unshare the problematic material, much like a spam filter works for your email inbox.
You can take to protect your account, such as using strong passwords, two-step verification, and encryption. - In accordance with your communication preferences, we’ll occasionally contact you to announce new products and features we build for you, share tips for using NuVuw to get more done, make special offers, and provide information about how NuVuw works with products and services from our business partners.
- If you are an End User of an NuVuw Business account, please note that the Account Holder of your NuVuw Business account (such as your employer or organization) may have established its own rules regarding End Users’ access, use, disclosure, or retention of data stored in that account. Also note that while an Administrator of an NuVuw Business account has access to the End User accounts linked to that NuVuw Business account, an Administrator cannot access an End User’s personal NuVuw account.
Would someone at NuVuw ever view my Content?
You have control over who sees your Content. We limit the use of your Content to make sure that no one at NuVuw can view it unless you expressly give us permission or it’s necessary to comply with our legal obligations. Specifically:
- To help refine or improve the technology, we may ask you for permission to review portions of your Content. For example, if a new feature suggests related notes that are relevant to your Content, we may give you an opportunity to provide us feedback on how well the feature is performing along with a sample of the Content in question, so we can make sure this feature provides appropriately tailored suggestions. Such access to your Content is done only with your express permission and is subject to strict confidentiality rules and data access controls. Choosing to give us such permission is completely voluntary.
- If you contact our Business Customer Support team for help with specific pieces of Content in your account, we may ask for your temporary permission to look at your Content. This permission terminates when the issue is resolved.
- If we become aware of a potential violation of our aTerms of Service or User Guidelines, we may suspend or close your account until the problematic material is removed. Under such a circumstance, we would only look at the Content in your account if you give us consent or if necessary to comply with our legal obligations, including to protect the safety of you or any other person.
To test and improve our product offerings for our users, we use aggregated data that does not contain any personal information, does not identify any person, and cannot be connected to any specific user. This policy is not intended to apply to such anonymized/de-identified data.
How does NuVuw share or disclose my information?
NuVuw is not in the business of selling or renting your information. Here are instances when we may disclose your information — and then only the minimum information necessary:
- We share your information with Service Providers who process data on our behalf, such as credit card processors and Business Customer management systems. For example, these Service Providers help us:
- Operate, develop, and improve the features and functionality of the Service
- Complete your payment transactions
- Fulfill your sales and support requests
- Communicate with you as described elsewhere in this policy
We require these providers to agree to strict data protection requirements in keeping with our privacy policy standards, the European Union’s General Data Protection Regulation (“GDPR”), and our commitments under our EU-US Privacy Shield and Swiss-US Privacy Shield certifications as discussed below..
We do not share your information with any third parties for their own advertising purposes.
- Your Content is private unless you decide you want to share it. You may choose to share using public links or through any of the Service’s features that allow you to share or collaborate on Content (“Collaboration Features”). If you choose to share, we may need to take steps to facilitate your collaboration.
- In the event of a merger, sale, or reorganization of all or part of our business, information covered by this policy may be transferred in connection with that deal.
- As described on ourCookie Information page, we contract with third-party advertising networks in order to deliver relevant NuVuw advertisements to you across the Internet and to manage our communications with you. We do not use your Content for these purposes. In addition, we may share with partners or Service Providers a hashed identifier to serve you relevant NuVuw ads when you visit partners’ and providers’ websites, applications or platforms. We may, for instance, participate in the Google Adwords Remarketing, Twitter Tailored Audience and Facebook Custom Audience To learn more about the privacy controls that Google, Twitter and Facebook offer and honor for those respective services, please visit here for Google, here for Twitter, and here for Facebook. You may opt out of certain ad targeting and retargeting services by visiting the Digital Advertising Alliance’s opt-out page, or the Network Advertising Initiative’s opt-out page.
- We also may share information about you with third parties whenever you consent to or direct such sharing. This includes, for example, if you connect your NuVuw account with a third-party app in our App Center.
How does NuVuw respond to legal requests for my information?
We vigilantly protect the privacy of your account. We will not disclose your information to law enforcement or other governmental authorities unless we believe it is required to comply with warrants, court orders, subpoenas, or other lawful government requests. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards of due process.
We narrowly interpret all information requests, and we only disclose Content in your account that is specifically responsive to a government warrant or where you have provided your explicit consent. We will notify you if we believe we are compelled to comply with a third party’s legal demand for your information, and we routinely push back on government orders to delay user notice that we view as overly broad. In addition, in rare cases, we may share your information as necessary to investigate or take action regarding illegal activities, suspected fraud, or potential threats against persons, property or the systems on which we operate the Service, or as otherwise necessary to comply with our legal obligations.
How can I manage my information stored in NuVuw?
Consistent with our first law of data protection—your data is yours—in most cases, you can manage your information simply by logging into your account and editing your information directly within the NuVuw service.
However, if you prefer, you can contact us at compliance@NuVuw.com to ask us to provide access to, correct, update, or delete your personal information. Please note that we may ask you for proof of account ownership and/or identity before fulfilling your request. We will comply with such requests to the extent required by applicable law or the US-Swiss Privacy Shield and US-EU Privacy Shield.
A Note for our European Users about our Data Processing Grounds and Data Access Rights
The European Union’s GDPR requires that we provide notice in a specific way to our European users about their privacy rights. We process Account Holder or End User personal information on one of three grounds, depending on the circumstances: (i) your affirmative consent, in which case you will have the right to withdraw consent at any time; (ii) contractual necessity; or (iii) our legitimate interest in providing the Service. In addition, we are required to list the data access right available to all users in a specific way.
How long does NuVuw store my information?
NuVuw’s mission is to help you remember everything important in your life. In order to do that, we make the Content you store in NuVuw readily accessible to you, until you make the decision to delete it.
If you delete your Content and then sync, it will no longer be accessible to you or others who may access the Service. The NuVuw service’s back-up systems may retain residual copies of your deleted Content for up to one year due to the nature of those systems’ operations.
NuVuw provides you with features that allow you to communicate and collaborate with other users. Please note that deleting your copy of these communications (such as messages) won’t delete copies existing in the accounts of people you were interacting with.
For users who are inactive for extended periods of time, we may close your account to satisfy our obligations under applicable law, and in accordance with our data retention policy. If that happens, we will try to notify you before taking any action.
What happens if I want to stop using NuVuw?
As described above, you can delete your Content at any time, and you can stop using the NuVuw service at any time. And as we promise in our third law of data protection, your data is portable. You can export your stored data at any time.
What happens if NuVuw closes my account?
If NuVuw deactivates your account due to a TOS violation, then you may contact us to request deletion of your Content, and we will evaluate such requests on a case by case basis, pursuant to our legal obligations.
Where does NuVuw store my information?
When you use NuVuw Software on your computing device, such as by using one of our downloadable applications, some of your data will be stored locally on that device.
When you sync your computing device with the Service, that data will be replicated on servers maintained in the EU. This means that if you store information in or submit data to the NuVuw website or NuVuw Software and sync such NuVuw Software with the NuVuw service, you acknowledge your personal information will be transmitted to, hosted, and accessed in the United States.
Data privacy laws or regulations in your home country may differ from, or be more protective than, those in the United Kingdom. We will collect, store, and use your personal information in accordance with this Privacy Policy and applicable laws, wherever it is processed.
Which NuVuw company is my data controller?
Your data controller is NuVuw Limited in England unless you reside in Malta where your your data controller is Malta-based NuVuw Limited.
How does NuVuw comply with data transfer rules?
If you are a resident of the European Economic Area (“EEA”) or Switzerland, please note that we use standard contractual clauses approved by the European Commission to transfer your personal Information from the EEA or Switzerland to the United States and other countries.
In addition, NuVuw Limited has certified its compliance with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from EU member countries and Switzerland.
How can I contact NuVuw?
NuVuw welcomes your feedback regarding this Privacy Policy. If you have questions, comments or concerns about this Policy, please contact us by email at privacy@NuVuw.com or postal mail at:
NUVUW LIMITED
20-22 Wenlock Road
London N1 7GU
Attention: Privacy Team
GLOSSARY
- Account Holdermeans the person or entity who has contracted with NuVuw as either an individual Home Owner user or as a Business Customer as defined in our NuVuw Business Agreement.
- Collaboration Featuresmeans any of the Service’s features that allow you to share or collaborate on Content.
- Contentmeans the text, images, and other data you choose to input, upload, and store in NuVuw.
- End Usermeans the individual who uses an account on the NuVuw service.
- NuVuw(or sometimes “we” or “us”) means NuVuw Limited and its affiliated companies that also act as data controllers:
- NuVuw Servicemeans the NuVuw Software (as defined below) and other products, services and websites hosted or made available by NuVuw, including our downloadable applications and Help & Learning pages.
- NuVuw Softwaremeans the software hosted on NuVuw’s servers and the software we make available to be deployed by you or a third party to enable capturing of Content originating outside the Service, such as NuVuw software applications for compatible computing devices that enable access and use of the Service through such device
- Group Companiesmeans NuVuw Limited and its wholly owned subsidiaries, which include NuVuw Limited in Malta.
- Paid Servicemeans NuVuw Home Owner, Trade Professional, NuVuw for Small Business, and any other NuVuw offering for which we collect payment (in the form of currency or NuVuw Credits).