The following additional terms also apply to your use of Nebuli’s Products and Services:
Nebuli is an ecosystem of Products and Services that applies Augmented Intelligence algorithms, human-centric design methodologies, behavioural analytics, economic research and other specialist activities to help customers with their digital transformation, digital ethics and specialist business and marketing strategies, both locally and internationally.
Unless stated otherwise, all Products and Services offered by Nebuli are owned and provided by Nebuli Limited (“Nebuli Ltd.”, “Nebuli”, “Company”, “we”, or “us”), Company Number 10622690, a limited company registered in England and Wales with the registered office address: White Collar Factory, 1 Old Street Yard, London, EC1Y 8AF, United Kingdom.
To get in touch, please email us via nebuli.com/contact. We do not use an office telephone number but we can engage with you via online video calls on request.
Your personal and company data is sensitive and entitled to protection. We strongly believe and advocate the principle that your privacy is your power and it is a human right.
Where we mention “Personal Data” it is referring to data about you from which you could be identified – such as your name, your date of birth, your contact details and even your IP address. All rights, titles and interests in your data held by Nebuli and throughout Nebuli’s Products and Services (where relevant) are 100% yours and we NEVER sell, disclose or make your data or information available to anyone without your explicit permission (other than being legally required such as by a court order).
By law, all organisations in the UK are obliged to process your personal data in certain ways and to ensure that you are given an appropriate amount of information about how they use it. You also have various rights to seek information from those organisations about how they are using your data, and to prevent them from processing it unlawfully.
In discharging our responsibilities as the Data Controller, we have Data Processors who deal with your data on behalf of Nebuli. The responsibilities assigned to the Data Processors, as individuals and/or Nebuli as a whole, involve the following:
When we engage a sub-processor, we will ensure that we have a written contract in place with the sub-processor that sets out the same data protection obligations on the third party as are set out in clause 1.8 (or substantially on that sub-processor’s standard terms of business), in particular providing sufficient guarantees to implement appropriate technical and organisational measures to ensure that the processing will meet the requirements of the relevant Data Protection Legislation.
If we appoint a sub-processor, we remain fully liable to you for the performance of the sub-processor’s data protection obligations.
At Nebuli, we strongly believe in being transparent about how and when we collect and use your personal data and/or business data (if you are a business customer) and tell you why we need it, and how we use it.
When you voluntarily supply your personal data to us, for example where you use our Websites to upload or send personal data (by contacting us via our Websites about our Services that we may offer to you, submitting applications for vacancies, or similar activities in which your volunteer data about yourself) contact us by post, telephone, email or SMS, report a problem with any of our Websites or Services, we may collect, store and use the personal data that you disclose to us. The personal data we collect from you may include your title, name, address, email address, company, job title, employment history and phone number – but will depend on precisely what details you volunteer to us as you interact with our Websites and Services.
We may collect, use, store and transfer different kinds of Personal Data to achieve the following:
There are a number of justifiable reasons under the Data Protection Laws that allow Nebuli to collect and process Personal Data. The main avenues we rely on are:
Nebuli’s use of your data for the purposes described above is based on the following legitimate basis:
We will never disclose your personal data to any third party except:
While Nebuli is currently a UK-based company, we operate an international business that serves customers around the world. If we need to transfer any personal data and/or company data outside your country (for example, if our service providers store personal data on servers outside in different locations around the world) we will ensure that appropriate safeguards are in place to keep your data secure, and that effective legal remedies are available for data subjects, or that there is an ‘adequacy decision’ or ‘adequacy regulation’ (as defined in the UK’s Data Protection Act 2018).
If we need to transfer any data, we will comply with our obligations under the relevant Data Protection Laws to provide an adequate level of protection to any personal data and/or company data that is transferred. As a way of guidance, your information may be stored and processed in the US, UK, European Economic Area (the “EEA”) or other countries or jurisdictions outside the US where Nebuli has facilities. We are currently storing data in the UK and the EEA and so, by using our Services, you are permitting and consenting to the transfer of information, including your personal data, outside of the US. By submitting your personal data, you agree to this transfer, storing or processing.
Your data is uploaded and downloaded over a secure connection, your credentials are encrypted and hashed. We never store (or even know) your password. Your personal and/or company data and any Confidential Information you may upload to our Services and Websites is stored securely, and only people you have assigned as members of your team (in addition to any Nebuli team member approved under these terms) can access your data, per the access permissions you assigned to those team members. We expect you to ensure that your team, particularly those you provide Admin access to, have strong passwords, ideally different from their login credentials used in any other (third-party) websites, such as, but not limited to, social network websites and apps.
Any information and data we receive and/or collect from you while using our Services, including but not limited to your personal information, your use of our Products and Services, demographic profile, geolocation and IP address. Below is how we may collect your information:
We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Please note that not all of the following types of data will necessarily be collected from you, but this is the full scope of data that we collect:
We may also collect personal data about you when you visit our Websites through the use of technologies such as cookies. The following are examples of data we may collect:
Type of Cookie
Strictly necessary cookies
These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). By using the Website, you agree to our placement of functionality cookie.
These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
We use the collected data described above for several different reasons. Firstly, we use it to ensure that our Websites work properly, serve you well and that you are able to receive the full benefit from them. Second, we use the data to monitor online traffic and audience participation across our Websites, especially our Content. We undertake these activities because we have a legitimate interest in doing so.
As part of our Services, you may occasionally contact us for customer support and/or we may need further details about your company in order to adequately provide you with our Services, both online and offline. Thus, it may be necessary for our team to access your personal and/or company data for the purpose of assistance, and to enable them to carry out the key Services that are necessary. This will only happen with your implied consent to do so, such as during an active conversation between yourself and Nebuli’s team member on our live video calls, face-to-face meetings or where it is necessary to answer a question you have asked them on email or live chat.
Once you have finished working with any of our team members, they will immediately remove their access from your personal and/or company’s databases, cloud accounts or online profile accounts in any of our Websites and Services. We also require our team members to regularly review the list of third-party data which they have accessed and to remove themselves from any persona; and/or company databases, cloud accounts or online profile accounts on our Websites and Services that they are not actively assisting to minimise the risk of any data breach.
Additionally, we recommend that you also have the ability to remove our team members from your personal and/or company’s databases, cloud accounts or online profile accounts on our Websites and Services at any time, so that only those who you have permitted to have access to your data has it.
We may use anonymous data collected from your use and/or access to our Websites and Services for administrative tasks, analytics, advertising and promotional purposes, and we may share such information with other entities (such as service providers) for such purposes. We may also aggregate data to enable research or analysis so that we can better understand and better serve you and others throughout our Websites and Services. For example, we may conduct research on your demographics, user behaviour and psychographics. Although this aggregated data may be based in part on Personal Data, it does not identify you personally.
We may share this type of anonymous data with our selected service providers, our affiliates, agents and current and prospective business partners. We may also use your anonymous data outside of Nebuli to improve third-party marketing or use your data in combination with third-party data to improve your experiences both within and beyond Nebuli’s Services. We may retain your IP address and/or other device-identifying data in order to help us diagnose problems with our servers, to administer our Websites including personalising content or links relevant to your geographic area or device-type, to verify that your account is not being used by others, to gather broad anonymous demographic data (such as the number of visitors from a specific geographic area), to enforce compliance with our General Terms and Conditions of Use for our Websites and/or Services, business contracts or otherwise in order to protect our Services, Customers/Users, or other third parties. We use analytics tools including Google Analytics and/or others. These provide us with information about how our customers and users use and/or access our Websites and Services.
Nebuli may collect personal information or data from third parties if customers/users give permission to those third parties to share such information with others or the data is extracted from publicly accessible sources. Such sources may include:
At Nebuli, our aim is to keep you informed to help you navigate through the murky waters of the ever-evolving post-digital transformation world. Hence, we share as much information as possible throughout our Websites and Services, which may contain hyperlinks to other websites offered by parties other than Nebuli (“third-party websites”). We occasionally share links and content from third-party websites and media outlets that feature Nebuli, our work, opinion pieces and market trends and such third-party websites are provided for your reference and convenience only. Nebuli does not control these third-party websites and is not responsible for their content; nor does Nebuli’s inclusion of hyperlinks to such third-party websites imply any endorsement of the material on such websites or any association with their operators. Nebuli cannot be held responsible or liable for the accuracy of the information contained within the linked third-party websites or for any consequences arising from the use of their information, or for their data collection practices and their access to your private data. It is your responsibility to verify any information contained within the linked third-party websites before relying on them. Please note that the information contained within the linked third-party websites may be changed or updated at any time without any prior notice. Linked third-party websites may contain their own terms and conditions, privacy and cookie policies which we strongly advise you to locate and review.
Unless otherwise specifically stated on our Websites or Services, Nebuli does not endorse any product or service or make any representation regarding the reliability, quality or accuracy of any products, content or services featured in, or linked to, any advertisement appearing on third-party websites.
In the course of assisting you with any of our Services, both of us understand that the other party has disclosed or may disclose business, technical, financial or other confidential, sensitive or proprietary information relating to their business (“Confidential Information”). Confidential Information includes non-public information regarding features, functionality and performance of our Service, non-public information data provided by you to us to enable the provision of our Services (such as, but not limited to, company data, business plans, financials, pitch decks, investor interest information, customer information, market research data, etc), and any other information that, based on the circumstances under which it was disclosed, a reasonable person would believe to be confidential. Both of us agree:
The foregoing provisions will not apply with respect to any information that any of us can prove:
We typically do not collect sensitive or Special Categories of Personal Data about individuals (such as details about an individual’s race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about an individual’s health, and genetic and biometric data), nor do we collect any information about criminal convictions and offences.
If for any legal reason we do need to process sensitive personal data, it is with the consent of the individuals involved and their Data controllers, for example, a healthcare authority who hired Nebuli for specialist Services.
We may obtain the following sensitive data for legitimate purposes, where necessary:
Furthermore, we do not collect Child data or any information from individuals under the age of 13, we may occasionally receive details about children attending performances and other events we host with their parents or guardians (e.g., school events and presentations, galas, and technology exhibits).
Our Websites are not directed at children under the age of 13 (each “Child” together “Children”) and we do not knowingly collect personal data about Children via our Websites – unless such websites were designed to serve educational organisations and institutions as part of our educational Services. Furthermore, we may occasionally receive details about children attending educational events with their parents or guardians hosted by Nebuli or a partner institution (such as, school events, presentations, and technology exhibitions – collectively “Educational Events”). We will explicitly state if such Websites and/or Educational Events serve children under the age of 13 and further data precautions shall be applied. If you believe we have collected personal data about your Child, you may contact us at [email protected] and request that we cease processing data about your Child.
We will hold your personal data on our systems only for as long as required to provide you with the Services you have requested or to perform the purpose for which that data was collected.
For example, we are bound to retain Services contracts made between us and our customers as they act as a record moving forwards, equally, we need to retain profile information users create via our Websites so we know which profiles are attached to which companies. In contrast, any conversations or correspondence you have with us over video calls, email or through our live chat software will be retained while the matter is ongoing, but once our conversation ends we may delete the record of that conversation.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this data indefinitely without further notice to you.
We may also retain your Personal Data for a longer period than usual in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances you can ask us to delete your data: see clause 8 ‘Your Rights’ below for further information.
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. We will inform you and provide you with an explanation as to how the processing for the new purpose is compatible with the original purpose, where we deem it necessary.
If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
As the owner of your data (i.e. the “Data Subject”), you have a number of rights in relation to your personal data and below is how you can exercise them:
You may have heard of this right being described as a “Subject Access Request” where you may, at any time, request access to the personal data that we hold which relates to you.
This right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. Please note that it is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us using our contact page at: nebuli.com/contact and telling us that you are making a Subject Access Request. You do not need to fill in any specific forms to make this kind of request.
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right.
You can exercise this right at any time by writing to us using our contact page at: nebuli.com/contact and telling us that you are making a request to have your personal data rectified and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not need to fill in any specific forms to make this kind of request.
You may have heard of this right being described as the “Right to be Forgotten” where you may, at any time, ask us to erase personal data if you do not believe that we need to continue retaining it.
Please note that we are not always obliged to erase personal data when asked to do so. If for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to erase, we will tell you what that reason is at the time we respond to your request.
You can exercise this right at any time by writing to us using our contact page at: nebuli.com/contact and telling us that you are making a request to have your personal data erased and on what basis you are making that request. You do not need to fill in any specific forms to make this kind of request.
You may also ask us to stop processing your personal data:
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us using our contact page at: nebuli.com/contact and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not need to fill in any specific forms to make this kind of request.
This is your right to request that we move, copy or transfer your personal data. If you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party you may write to us and ask us to provide it to you in a commonly used machine-readable format.
This is your right to object to our use of your personal data including where we use it for our legitimate interests. In relation to automated decision making and profiling, you also have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Where we send you e-mail marketing communications or any other regulated electronic messages, you have the right to opt-out at any time. You can do this by using the ‘unsubscribe’ link that appears in the footer of each communication (or the equivalent mechanism in those communications).
Alternatively, if for any reason you cannot use those links, or if you would prefer to contact us directly – you can unsubscribe by writing to us at [email protected] and telling us which communications you would like us to stop sending you.
To make enquiries, exercise any of your rights set out above, or withdraw your consent to the processing of your data (where consent is our legal basis for processing your data), please contact us via this email address: [email protected] When you write to us making a request to exercise your rights we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information then we may delay actioning your request until you have provided us with additional information (and where this is the case we will tell you).
If you are not satisfied with the way a complaint you make in relation to your data is handled by us, you may be able to refer your complaint to the relevant data protection authority. For the UK, this is the Information Commissioner’s Office (ICO). The ICO’s contact details can be found on their website at https://ico.org.uk/.
Please note that it is important that any personal data that we hold about you is accurate and current. It is your responsibility to keep us informed if your personal data changes during the period for which we hold it.
Please also see our General Terms and Conditions which sets out the terms, disclaimers, and limitations of liability governing your use of Nebuli’s Websites and Services.
Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
This Agreement will be governed by and interpreted according to the law of England and Wales. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the English and Welsh courts.