YOUR PRIVACY RIGHTS

Effective Date: May 25th, 2018

This Privacy Policy describes NSONE, Inc.’s (hereinafter “NS1,” “we” or “us”) privacy policy, including the types of personal information we gather, how we use it, with whom the information may be shared, what choices are available to you regarding collection, use and distribution of information and our efforts to protect the information you provide to us through our website at ns1.com (the “Website”) and through other services delivered or provided to you by NS1 (collectively, the “Service”). By using the Service, you hereby consent to allow us to process information in accordance with this Policy. Please also refer to our Terms of Service, which are incorporated as if fully recited herein, if you have not already done so. This policy is subject to change. If our information retention or usage practices change, we will let you know by posting the Privacy Policy changes on the Website or otherwise through the Service. Please refer to the “Effective Date” above to see when this Policy was last updated.

Territoriality

Subject to provisions set forth below for EU Residents, regardless of where our servers are located, your personal data will be processed by us in the United States, where data protection and privacy regulations may or may not be to the same level of protection as in other parts of the world. BY VISITING THE SERVICE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND THAT, SUBJECT TO THE PROVISIONS SET FORTH BELOW FOR EU RESIDENTS, U.S. LAW GOVERNS ANY SUCH COLLECTION AND PROCESSING.

Information Collected

We collect two types of information about persons who use the Service: personal information and non-personal information. This information may be collected in a number of ways, including through direct submission, cookies, web beacons and similar data acquisition methods. Although you can disable cookies in your browser or device, that may interfere with the use of the Service.

Personal Information Collected

Personal information is information that would permit us to contact you or serves as a persistent identifier of you within NS1. Personal Information that we may collect includes:

• Name;
• Address;
• Phone number;
• E-mail;
• Username;
• IP address;
• Credit/debit card number (held encrypted through a third-party service);
• Location based information;

Although NS1 may collect credit card information, it is stored in an encrypted manner using a third-party service, and NS1 cannot decrypt that data without a code from our provider.

Non-Personal Information

Non-Personal Information is information about you, other than Personal Information, that may be collected by NS1. It may include non-personal information about how you and your business use the Service, such as browsing habits, information about the referring source of your traffic, your anonymous demographic details, your interactions with the Service and analytics relating to your use of the Service. Further data may be collected to fulfill specific requests. We may collect non-personal data about your business, such as its address, activities, user credentials, and other such data.

Third-Party Collection

Our Service may use third party services to gather and process data about how you use the services. The Service may also use cookies for its own analytics.

Internal Use of Information by NSONE

We accept and gather information in an effort to provide you with the Service. This includes the internal use of your information to tailor the Services to your interests, for fraud prevention, to deliver the Service and to improve Services. Additionally, NS1 may use your information for administration of the Service, such as for communicating with you about the Service and managing support requests and tracking.

Sharing Information with Third-Parties, Consultants, and Affiliates

We will not share your Personal Information with third parties for the purpose of direct marketing such third parties’ products or services. We may, however, share your information with our consultants and affiliates in order for us to provide you with the Service, to improve the Service and to otherwise operate NS1. NS1 may retain third-party consultants to perform analysis on your data and to otherwise provide consulting services to NS1 that may include review of your data. These types of disclosures will be on a confidential basis. NS1 may share your Non-Personal Information, such as analytics data, with our business associates and partners. Such sharing is generally for the purpose of marketing NS1’s own services and to discuss and offer NS1’s services. Further, we may disclose collected information to the extent we believe it necessary to comply with the law, such as in response to a subpoena or court order, to defend a legal claim or otherwise as permitted by applicable law. Additionally, we may transfer your information to successor in interest, which may include but may not be limited to a third-party in the event of an acquisition, sale, merger or bankruptcy.

Access and Control

NS1 may provide you with the ability to access certain Personal Information we have collected about you and your business through a login portal. You may have the ability to edit, update or delete certain data through such a login.

Links and Integration

Our Service may contain links to other services or may be integrated into the websites or services of third-parties. We are not responsible for the privacy practices of such other sites or services. When you leave our Service to visit another website, application or service, please read such third-party’s privacy statements. This Privacy Policy applies solely to information collected by NS1 through the Service.

Security

We employ procedural and technical safeguards to secure your personal information against loss, theft, alteration, and unauthorized access, use and disclosure. We also employ security procedures to protect your information from unauthorized access by users inside and outside the company. These measures include password protection, firewalls, encryption and similar methods. Regardless of the precautions taken by NS1, no transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under our control to intercept or access transmissions or private communications unlawfully. While we strive to protect personal information, we cannot ensure or warrant the security of any information you transmit to us.

Children and Privacy

We do not knowingly permit users if they are under 16 years old, and therefore do not request personally identifiable information from anyone under the age of 16. If we become aware that a customer is under the age of 16 and has provided us with personal information without prior verifiable parental consent, we will remove his or her personally identifiable registration information from our files. If you are the parent or guardian of a person under the age of 16 who has provided personally identifiable information to us without your approval, please inform us by contacting us at the e-mail address below.

Cookies

Cookies are small pieces of text used to store information on web browsers. They are used by many websites to store and receive identifiers and other information on devices, such as a handheld phone or computer. Our website and Service use cookies and other similar technologies, in order to provide a better service to you and to generally improve our website and Services. We also may use information to present you with services that are matched to your preferences and to manage and track the effectiveness of our marketing efforts. Third party cookies placed by third-party advertising platforms or networks may collect information about your visits to and actions on certain pages of our website, so they can deliver ads about relevant products to you in the future. We also may include tracking pixels, which are small graphic images, in our marketing communications to determine engagement. These cookies may be set by us or by third parties with whom we have partnered to assist in our marketing efforts. Some portions of our Website are functional without cookies, and you may generally choose whether to accept cookies. Most web browsers are set to accept cookies by default, however, you may be able to delete cookies yourself through your browser's cookie manager. To do so, please follow the instructions provided by your web browser. Please note that disabling cookies will reset your session, disable auto-login, and may adversely affect the availability and functionality of our Website and the services we can provide to you.

California Privacy Rights

California law allows California residents to request information regarding our disclosures in the prior calendar year, if any, of their personally identifiable information to third parties. To make such a request, please contact us at [email protected] with "Request for Privacy Information" in the subject line. Please include enough detail for us to locate your file; at a minimum, your name, email, and username, if any. We will attempt to provide you with the requested information within thirty (30) days of receipt. We reserve our right not to respond to requests sent more than once in a calendar year, or requests submitted to an address other than the one posted in this notice. Please note that this law does not cover all information sharing. Our disclosure only includes information covered by the law.

Contact Information

If you have any questions or suggestions regarding our Privacy Policy, please contact us via e-mail at [email protected].

EU Residents

The remaining portion of this Privacy Policy applies to residents of European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland. If you are a resident of such jurisdiction, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below. For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Company will be the controller of your Personal Data processed in connection with the Services. If there are any conflicts between this section and any other provision of this Privacy Policy, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us at [email protected]

What Personal Data Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services. Information we collect directly from you: We receive Personal Data directly from you when you provide us with such Personal Data, including without limitation the following:

• Name
• Address
• Phone number
• E-mail
• IP address
• Credit/debit card information (held encrypted through a third-party service)
• Location based information

Information we receive from third party sources: Some third parties such as services providers provide us with Personal Data about you, such as the following:

• Account information for third party services: If you interact with a third party service when using our Services, such as if you use a third party service to log-in to our Services, the third party service will send us information about you, if the third party service and your account settings allow such sharing. The information we receive will depend on the policies and your account settings with the third party service.
• Information from our advertising partners: We receive information about you from some of our service providers who assist us with marketing or promotional services related to how you interact with our websites, applications, products, services, advertisements or communications. The information we receive from service providers includes the information set forth below under “Information we automatically collect when you use our Services.”

Information we automatically collect when you use our Services: Some Personal Data is automatically collected when you use our Services, such as the following:

How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information
• Transaction information (e.g. transaction amount, date and time such transaction occurred)
• Cookies and other tracking technologies (e.g. web beacons, pixel tags, SDKs, etc.) -- For more information, please see our cookie policy above.
• Location information (e.g. IP address, zip code)
• Log data (e.g. access times, hardware and software information)

How Do We Use Your Personal Data? We process Personal Data to operate, improve, understand and personalize our Services. For example, we use Personal Data to:

• Create and manage user profiles
• Communicate with you about the Services
• Process orders
• Contact you about Service announcements, updates or offers
• Provide support and assistance for the Services
• Personalize website content and communications based on your preferences
• Meet contract or legal obligations
• Respond to user inquiries
• Fulfill user requests
• Comply with our legal or contractual obligations
• Resolve disputes
• Protect against or deter fraudulent, illegal or harmful actions
• Enforce our Terms of Service

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our agreement to provide services to you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.

• Name
• Address
• Phone number
• E-mail
• IP address
• Credit/debit card information (held encrypted through a third-party service)
• Location based information

Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties.

• Name
• Address
• Phone number
• E-mail
• IP address
• Device identifiers
• Web browser information
• Page view statistics
• Browsing history
• Usage information

  Examples of these legitimate interests include:

• Operation and improvement of our business, products and services
• Marketing of our products and services
• Provision of customer support
• Protection from fraud or security threats
• Compliance with legal obligations
• Completion of corporate transactions

Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.

Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

How and With Whom Do We Share Your Data? We share Personal Data with vendors, third party service providers and agents who work on our behalf and provide us with services related to the purposes described in this Privacy Policy or our Terms of Service. These parties include:

• Payment processors
• Fraud prevention service providers
• Ad networks
• Analytics service providers
• Staff augmentation and contract personnel
• Hosting service providers
• Co-location service providers
• Telecommunications service providers

We also share Personal Data when necessary to complete a transaction initiated or authorized by you or provide you with a product or service you have requested. In addition to those set forth above, these parties also include:

• Other users (where you post information publicly or as otherwise necessary to effect a transaction initiated or authorized by you through the Services)
• Social media services (if you interact with them through your use of the Services)
• Third party business partners who you access through the Services
• Other parties authorized by you

We also share information with third parties when you have given us consent to do so (as indicated at the point such information is collected).

We also share Personal Data when we believe it is necessary to:

• Comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies
• Protect us, our business or our users, for example to enforce our terms of service, prevent spam or other unwanted communications and investigate or protect against fraud
• Maintain the security of our products and services

Last, we share Personal Data with our affiliates or other members of our corporate family. Furthermore, if we choose to buy or sell assets, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party, and we would share Personal Data with the party that is acquiring our assets. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Information as set forth in this policy.

How Long Do We Retain Your Personal Data? We retain Personal Data about you for as long as you have an open account with us and for up to 36 months after you close your account. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

What Security Measures Do We Use? We seek to protect Personal Data using appropriate technical and organizational measures based on the type of Personal Data and applicable processing activity.

Personal Data of Children: As noted above, we do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at [email protected]

What Rights Do You Have Regarding Your Personal Data? You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email [email protected] Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

• Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. To submit a request, please email [email protected]
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. To submit a request to correct or supplement any such Personal Data, please email [email protected]
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
• Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Right to File Complaint: You have the right to lodge a complaint about Company’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Transfers of Personal Data: The Services are hosted and operated in the United States (“U.S.”) through Company and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Company in the U.S. and will be hosted on U.S. servers, and you authorize Company to transfer, store and process your information to and in the U.S., and possibly other countries. You hereby consent to the transfer of your data to the U.S. pursuant to binding corporate rules for data protection that align with the GDPR’s requirements.

What If You Have Questions Regarding Your Personal Data? If you have any questions about this section or our data practices generally, please contact us using the following information:

Name: General Counsel Physical address: 55 Broad Street, 19th Fl, New York, New York 10004 55 Broad Street, 19th Fl, New York, New York 10004 Email address for contact: [email protected] Designated representative and contact information: General Manager, NS1 UK Physical address: 21-22 Old Steine, Brighton UK BN11EL Email address for contact: [email protected]