Privacy policy
Last Updated: 22/12/2022
- Introduction
1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 NUACOM and its parent company TSFY Ltd. In this policy, “we“, “us“, and “our” refer to NUACOM. For more information about us, see Section 11.
1.3 This privacy policy (“Privacy Policy”), together with our Terms and Conditions and any other documents referred to therein, sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting nuacom.ie or nuacom.com, (“Website”) or using our Solutions and Services, you are accepting and consenting to the practices described in this Privacy Policy.
1.4 For the purpose of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) or any subsequent amendment or replacement or supplementary legislation (together “Data Protection Law”), the data controller is Nuacom Limited of Block B, Maynooth Business Campus, Maynooth, Co. Kildare, Ireland.
1.5 This policy applies where we act as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of processing that personal data.
1.6 We use cookies on our website. Insofar as some cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
1.7 Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via Website.
- How we use your personal data
2.1 In this Section 2 we have set out:
(a) the general categories of personal data that we may process.
(c) the purposes for which we may process personal data; and
(d) the legal bases of the processing.
2.2 We may process data about your use of our website and services (“usage data“). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data (“account data“). The account data may include your name, email address and phone number. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.4 We may process your information included in your personal profile on our website (“profile data“). The profile data may include your name, telephone number, email address, profile pictures, and employment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.5 We may process information that you post for publication on our website or through our services (“publication data“). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
2.6 We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
2.7 We may process information relating to our customer relationships, including customer contact information (“customer relationship data“). The customer relationship data may include your name, your employer, your job title or role, your contact details, and information contained in communications between us and you or your employer. The source of the customer relationship data is you or your employer. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
2.8 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data“). The transaction data may include your contact details, your payment details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.9 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.10 We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.11 We may process the phone calls that we make to us or receive from us (“phone call data”) data. This data may include the phone numbers, date and time of the call, duration of the call, voicemail, an audio call recording of the conversation. The source of this data is you or your employer. This data may be processed for keeping a record of your instructions and to be able to satisfy our contractual obligations towards you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.12 Traffic data about the communications that take place through our platform (such as calls, team chat, video conferencing, SMS,) to enable us to transmit those communications effectively and efficiently.
2.13 Network Monitoring data to enable us to maintain the security and agility of our internal networks.
2.14 Log data about you when they use the Services, Website or Apps including Internet Protocol (“IP”) address, Internet Service Provider (“ISP”), browser type, referring/exit pages, the files viewed on our website (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website;
2.15 Device data about any device including mobile phone number and other information related to mobile devices like operating system and model if you use our Services via our Apps. For other devices information collected by cookies and other similar technologies. We use various technologies to collect information which may include saving cookies to your computers.
2.16 Metadata, which is data created about other data which can include size, formatting and other characteristics of a data item.
2.17 Emails/Communications with us; and
2.18 Billing data, which includes any payment data.
2.19 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.20 We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.21 In addition to the specific purposes for which we may process your personal data set out in this Section 2, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
2.22 Please do not supply any other person’s personal data to us, unless we prompt you to do so.
- Information we collect from third parties
3.1 We may collect the names, email addresses, postal addresses, and city of residence of individuals from third parties to market our products or services to these individuals. This collection of information and marketing is always carried out in compliance with applicable law.
3.2 We may receive personal information about you from other sources, including publicly available databases or third parties from whom we have purchased data, and combine this data with information we already have about you in accordance with applicable laws. This helps us to update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you.
3.3 We may collect personal information about you from other applications you may use if you choose to integrate NUACOM Apps or Services with other Apps or Services.
- Providing your personal data to others
4.1 We may disclose your personal data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes and on the legal bases set out in this policy. Information about our group of companies can be found on our Website.
4.2 We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or establishment, exercising or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4.3 We may disclose your contact details to our suppliers or subcontractors insofar as reasonably necessary for subcontracting the necessary work.
4.4 Financial transactions relating to our website and services may be handled by our payment services providers. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
4.5 We may disclose your enquiry data to one or more of those selected third-party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market, and sell you the relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party will supply you with a copy of its own privacy policy, which will govern that third party’s use of your personal data.
4.6 In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for establishing, exercising, or defending legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
- International transfers of your personal data
5.1 Section 5 provides information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
5.5 We take all reasonable steps to protect information received from you from accidental or unlawful destruction, loss, alteration, and unauthorized disclosure or access. We have put in place appropriate physical, technical and administrative measures to safeguard and secure your information, and we make use of privacy-enhancing technologies such as encryption. If you have any questions about the security of your personal information, you can contact us VIA email: dataprotection@nuacom.com.
5.6 We will take all steps reasonably necessary to ensure that your Personal Data is treated securely and following this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your Personal Data and other personal information.
- Retaining and deleting personal data
6.1 We will retain your personal data as follows:
We retain the Personal Information you provide us as long as we consider it potentially useful in contacting you about the Subscription Service or our other services or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information. We will delete this information from the servers at an earlier date if you so request, as described in “Opting Out and Unsubscribing” below. If you provide information to our customers as part of their use of the Subscription Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Subscription Service, then we will provide the customer with access to all information stored for the customer by the Subscription Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the Subscription Service.
We will retain your Personal Data with “HubSpot CRM” service that will provide the safest and most stable data protection.
- Amendments
7.1 We may update this policy from time to time by publishing a new version on our website.
7.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
- Your rights
8.1 In this Section 8, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
8.2 Your principal rights under data protection law are:
(a) the right to access.
(b) the right to rectification.
(c) the right to erasure.
(d) the right to restrict processing.
(e) the right to object to processing.
(f) the right to data portability.
(g) the right to complain to a supervisory authority; and
(h) the right to withdraw consent.
8.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. You can access your personal data by logging into your account through our Website.
8.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
8.5 In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal or contractual obligation; or for the establishment, exercise or defence of legal claims.
8.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
8.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
8.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
8.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
8.10 To the extent that the legal basis for our processing of your personal data is:
(a) consent; or
(b) that the processing is necessary for the performance of a contract to which you are a “Party” or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
8.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
8.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
8.13 You may exercise any of your rights in relation to your personal data by written notice to us, in addition to the other methods specified in this Section 8.
- Disclosure of your Personal Data
9.1 Business Transactions
If we are involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
9.2 Law enforcement
Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
9.3 Other legal requirements
We may disclose your Personal Data in the good faith belief that such action is necessary to:
(a) Comply with legal obligations.
(b) Protect and defend our rights or property.
(c) Prevent or investigate possible wrongdoing in connection with the Website and Services.
(d) Protect your personal safety, the Website, or the public.
(e) Protect against legal liability.
- Links to other websites
10.1 Our Website and Services materials may contain links to other websites we do not operate. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Policy of every site you visit.
10.2 We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
- Children’s Privacy
11.1 NUACOM does not provide products or services that are designed for use by children under the age of 16 or knowingly collect personal information from or about children under the age of 16. If you believe that a child under the age of 16 has disclosed personal information to NUACOM, please contact dataprotection@nuacom.com.
- Complaints
12.1 If you have any complaints about our use of your personal data, please contact us as set out at the end of this Privacy Policy or contact our supervisory authority in Ireland:
Data Protection Commission at, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland.
- Our details
13.1 This website is owned and operated by TSFY Limited T/A NUACOM
13.2 We are registered in Ireland with Dublin CRO, registration number 471291, and our registered office address is: Block B, Maynooth Business Campus, Maynooth, Co. Kildare, Ireland.
13.3 You can contact us:
(a) by post, to the postal address given above.
(b) using our Website contact form.
(c) by telephone, on the contact number published on our website; or
(d) by email, using the following email address: dataprotection@nuacom.com.
