Noble Artificial Intelligence, Inc. ("Noble.AI") seeks to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that Noble.AI obtains from Customers.
The Federal Trade Commission (FTC) has jurisdiction over Noble.AI's privacy statements.
All Noble.AI employees who handle Personal Data are required to comply with the Principles stated in this Policy.
Capitalized terms are defined in Section 14 of this Policy.I. SCOPE
This Policy applies to the processing of Individual Customer Personal Data that Noble.AI receives in the United States concerning Individual Customers. Noble.AI provides products and services to businesses.
This Policy does not cover data from which individual persons cannot be identified or situations in which pseudonyms are used. (The use of pseudonyms involves the replacement of names or other identifiers with substitutes so that identification of individual persons is not possible.)II. RESPONSIBILITIES AND MANAGEMENT
Noble.AI has designated the Security Department to oversee its information security program. The Security Department shall review and approve any material changes to this program as necessary. Any questions, concerns, or comments regarding this Policy also may be directed to email@example.com
Noble.AI will maintain, monitor, test, and upgrade information security policies, practices, and systems to assist in protecting the Personal Data that it collects. Noble.AI personnel will receive training, as applicable, to effectively implement this Policy. Please refer to Section 7 for a discussion of the steps that Noble.AI has undertaken to protect Personal Data.III. COLLECTION AND USE OF PERSONAL DATA
Noble.AI provides various solutions to its Individual Customers who purchase its products. Noble.AI collects Personal Data from Individual Customers when they purchase its products, register with our website, log-in to their account, complete surveys, request information or otherwise communicate with us. For example, Noble.AI individual customers may choose to seek live support or post to a message board.
The Personal Data that we collect may vary based on the Individual Customer's interaction with our website and request for our services. As a general matter, Noble.AI collects the following types of Personal Data from its Individual Customer's: contact information, including, a contact person's name, work email address, work mailing address, work telephone number, title, and company name, as well as payment information (which might include credit card and/or bank account information). Individual customers have the option to log into their accounts online and to request service online, including through a live support option; we will collect information that they choose to provide to us through these portals.
When Individual Customers use our services online, we will collect their IP address and browser type. We may associate IP address and browser type with a specific customer. We also may collect Personal Data from persons who contact us through our website to request additional information; in such a situation, we would collect contact information (as discussed above) and any other information that the person chooses to submit through our website.
The information that we collect from Individual Customers is used for selling the products and services they buy from us, managing transactions, reporting, invoicing, renewals, other operations related to providing services and products to the Individual Customer.
For certain products, Noble.AI serves as a service provider. In our capacity as a service provider, we will receive, store, and/or process Personal Data. In such cases, we are acting as a data processor and will process the personal information on behalf of and under the direction of our partners and/or agents. The information that we collect from our Individual Customers in this capacity is used for managing transactions, reporting, invoicing, renewals, other operations related to providing services to the Individual Customer, and as otherwise requested by our partner and/or agent.
Noble.AI uses Personal Data that it collects directly from its Individual Customers and for its partners indirectly in its role as a service provider for the following business purposes, without limitation:
- maintaining and supporting its products, delivering and providing the requested products/services, and complying with its contractual obligations related thereto (including managing transactions, reporting, invoices, renewals, and other operations related to providing services to a Individual Customer);
- satisfying governmental reporting, tax, and other requirements (e.g., import/export);
- storing and processing data, including Personal Data, in computer databases and servers located in the United States;
- verifying identity (e.g., for online access to accounts);
- as requested by the Individual Customer;
- for other business-related purposes permitted or required under applicable local law and regulation;
- and as otherwise required by law.
Noble.AI will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
For sensitive personal information, Noble.AI will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual.
Noble.AI will provide an individual opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal data, you may opt-out by submitting a written request to firstname.lastname@example.orgIV. DISCLOSURES / ONWARD TRANSFERS OF PERSONAL DATA
Except as otherwise provided herein, Noble.AI discloses Personal Data only to Third Parties who reasonably need to know such data only for the scope of the initial transaction and not for other purposes. Such recipients must agree to abide by confidentiality obligations.
Noble.AI may provide Personal Data to Third Parties that act as agents, consultants, and contractors to perform tasks on behalf of and under our instructions. For example, Noble.AI may store such Personal Data in the facilities operated by Third Parties. Such Third Parties must agree to use such Personal Data only for the purposes for which they have been engaged by Noble.AI
Please be aware that Noble.AI may be required to disclose an individual's personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.V. SENSITIVE DATA
Noble.AI only collects information from its business customers. Noble.AI does not collect Sensitive Data Directly from Individual Data Subjects.VI. DATA INTEGRITY AND SECURITY
Noble.AI uses reasonable efforts to maintain the accuracy and integrity of Personal Data and to update it as appropriate. Noble.AI has implemented physical and technical safeguards to protect Personal Data from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. For example, electronically stored Personal Data is stored on a secure network with firewall protection, and access to Noble.AI's electronic information systems requires user authentication via password or similar means. Noble.AI also employs access restrictions, limiting the scope of employees who have access to Individual Customer Personal Data.
Further, Noble.AI uses secure encryption technology to protect certain categories of personal data. Despite these precautions, no data security safeguards guarantee 100% security all of the time.VII. ACCESSING PERSONAL DATA
Noble.AI personnel may access and use Personal Data only if they are authorized to do so and only for the purpose for which they are authorized.VIII. RIGHT TO ACCESS, CHANGE OR DELETE PERSONAL DATA
Right to Access. Individuals have the right to know, access, confirm accuracy, transfer, change, or delete the personal data about them is held by Noble.AI. This can best be accomplished by working with the company that collected their data and subsequently used Noble.AI to process it. That company can make these data requests and Noble.AI will be happy to work with them to accomplish the goal.IX. CHANGES TO THIS POLICY
This Policy may be amended from time to time in compliance with applicable data protection and privacy laws and principles. We will make employees available of changes to this policy either by posting to our intranet, through email, or other means. We will notify Customers if we make changes that materially affect the way we handle Personal Data previously collected, and we will allow them to choose whether their Personal Data may be used in any materially different manner.X. QUESTIONS OR COMPLAINTS
EU Individual customers may contact Noble.AI with questions or complaints concerning this Policy at the following address:
email@example.comXI. ENFORCEMENT AND DISPUTE RESOLUTION
Noble.AI commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with questions or concerns about the use of their Personal Data should contact us at: firstname.lastname@example.org
Noble.AI commits to cooperate with EU data protection authorities (DPAs) and comply with the advice given by such authorities with regard to human resources data transferred from the EU in the context of the employment relationship.XII. DEFINED TERMS
"Individual Customer" means an Individual customer or client of Noble.AI. The term also shall include any individual agent, representative, of an individual customer of Noble.AI and all employee of Noble.AI where Noble.AI has obtained his or her Personal Data from such Individual Customer as part of its business relationship with Noble.AI.
"Data Subject" means an identified or identifiable natural living person. An identifiable person is one who can be identified, directly or indirectly, by reference to a name, or to one or more factors unique to his or her personal physical, psychological, mental, economic, cultural or social characteristics. For Customers residing in Switzerland, a Data Subject also may include a legal entity.
"Employee" means an employee (whether temporary, permanent, part-time, or contract), former employee, independent contractor, or job applicant of Noble.AI or any of its affiliates or subsidiaries.
"Europe" or "European" refers to a country in the European Union.
"Personal Data" as defined NIST means data that personally identifies or may be used to personally identify a person, including an individual's name in combination with country of birth, marital status, emergency contact, salary information, terms of employment, job qualifications (such as educational degrees earned), address, phone number, email address, user ID, password, and identification numbers. Personal Data does not include data that is de-identified, anonymous, or publicly available. For Switzerland, the term "person" includes both a natural person and a legal entity, regardless of the form of the legal entity.
"Sensitive Data" means Personal Data that discloses a Data Subject's medical or health condition, race or ethnicity, political, religious or philosophical affiliations or opinions, sexual orientation, or trade union membership.
"Third Party" means any individual or entity that is neither Noble.AI nor an Noble.AI employee, agent, contractor, or representative.
v1.1 April 2018
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