Effective date: August 1, 2020
This policy applies to information we collect:
Information for California consumers can be found in section 10 “California Consumer Privacy Act.”
We can share the data we collect from you with those outside of Nomad if they are a service provider for Nomad (and have to follow our requirements) or if we’re legally required to share it with those outside of Nomad.
This Policy does not apply to information collected by:
We do not participate in the E.U. - U.S. and Swiss - U.S. Privacy Shield Frameworks and do not comply with the Privacy Shield Principles.
As noted in the Terms of Service, we do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from anyone under age 18, we will delete that information as quickly as possible. If you believe that anyone under the age of 18 may have provided us personal information, please contact us at: email@example.com.
We collect information when you register or open an account, sign in, pay a bill, purchase a Service, call us for support, or give us any type of feedback. We may also get information from other companies or third parties, or when we may use service providers to supplement the Personal Information you give us such as validating your mailing address to help us maintain the accuracy of your data and provide you with better service. We might also collect content or other information that you may provide or create when you interact with our Services.
To create and open an account through the Services, We may require you to provide personal information to identify yourself such as name, email address, password, phone number or federal EIN number.
When purchasing certain Services, you will also be required to provide a credit card number, billing address, phone number or other payment information. No information of this type will be collected unless you have registered for aspects of the Service that require it. Be advised that if we collect payment from you of any kind that we will utilize the services of a third party payment processor to facilitate your payment by credit card.
We may also automatically collect certain usage information when you access our Services ("Usage Data"), such as Internet Protocol address ("IP address") and information derived from your IP address such as your geographic location, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies. We collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services. We also collect IP addresses from users when they log into the Services as part of our log-in and security features. We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data. We may also collect Past transactional behavior conducted by You on the Services, Information about your company such as the name, size and location of your company and your role within the company, and Behavioral or demographic attributes, when tied to personal identifiers.
Nomad may also collect additional information through your dealings with and use of the Services and non-Nomad websites, which does not disclose your specific identity or does not directly relate to an individual. Additional information may include, but is not limited to:
We might also put together additional information with Personal Information, such as gathering geographical location from your IP address and combining all of this with behavioral data about your usage of the Services with your name. If we combine additional information with personal Information, we will treat the combined information as Personal Information.
We might also collect personal information from you if you log into our Services using a Third Party Social Network such as Facebook, Instagram or Snapchat.
Our Services may change over time and we may introduce new features that may collect new or different types of information.
(i) Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to use our paid services, posting material or requesting further services. We may also ask you for information when you report a problem with our Website.
(ii) Account Registration. We may use your name, address, phone number, and email address to register your Nomad Account for certain Services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current. If you set up an administrator account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your Personal Information.
(iii) Records and copies of your correspondence (including e-mail addresses), if you contact us.
(iv) Your responses to surveys that we might ask you to complete for research purposes.
(v) Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
(vi) Your search queries on the Website
(vii) To bill and collect money owed to us by our Customers. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.
(ix) To enforce compliance with our Terms and Conditions and applicable law. This may include developing tools and algorithms that help us prevent violations.
(x) To protect the rights and safety of our Employees, Customers and third parties, as well as our own.
(xi) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms which includes responding to lawful requests by public authorities, including to meet national security or law enforcement requirements.
(xii) To communicate with our Customers about their account and provide customer support.
(xiii) To Let You Know About Other Services. We may use your information to communicate with you about our Services and to give you offers for third party products and services that may be of use to you.
(xiv) To Improve Services and Develop New Services. We may use your information to personalize or customize your experience to develop new features or services, and to improve the overall quality of Nomad ’'s Services.
(xv) Feedback. We may use any information you volunteer provide to us in surveys you answer and combine them with answers from other customers in order for us to better understand our Services and how we may improve them. Of course, answering any survey is optional.
(xvi) To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing any Services that you have requested, provide you with support related to our Services, and to help us protect our Services, which includes taking action against fraud and protect your information.
(xvii) Customer Service and Technical Support. We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to deal with and resolve questions you may have about our Services and to follow up with you about your experience.
(xviii) Publishing or Sharing Combined Information from Many Users In a Manner that Would Not Allow You or Any Other Person to be Identified Personally. We may prepare and share information about our customers with third parties, such as advertisers or partners, for research, marketing and/or promotional purposes but only in a way that would not allow you or any other person to be identified. For example, we may share demographic data that describes the percentage of our customers who use one of our services or who use a specific operating system. We or our third party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other person to be identified.
(xix) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.
(xx) To prosecute and defend a court, arbitration, or similar legal proceeding.
(xxi) To provide suggestions to you. This includes adding features that compare Customers’ content or communications, using data to suggest products or services that you may be interested in or that may be relevant to you.
(xxiii) Customer Testimonials. We might at some point upload Customers testimonials on our Services that may contain Personal Information. Before doing so, we will obtain your consent to use your name and testimonial. If you ever desire to delete a testimonial, please contact us at firstname.lastname@example.org.
(xxiv) Respond to Your Requests. Nomad may also use Personal Information in order to respond directly to your information requests.
(xxvi) We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
(ii) To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.
(iii) To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
(iv) To fulfill the purpose for which you provide it.
(v) For any other purpose disclosed by us when you provide the information.
(vi) With your consent.
(viii) Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief that we are required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.
(ix) Protection of Nomad and Others. We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our products' Terms of Service and other agreements; or protect the rights, property, or safety of Nomad, our Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Statement.
(x) Reporting to Credit Bureaus. We may share your information with credit bureaus, consumer reporting agencies, and card associations. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.
(xi) Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you'd like to stop receiving promotional information following any change of control.
(xi) We do not sell or rent Personal Information to unaffiliated third parties for their advertising or marketing lists.
(xii) With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Information may be shared with other third parties.
If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us at: email@example.com.
(a) Blog. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us. If we are unable to remove your information, we will tell you why.
(b) Social media platforms and widgets. Our Websites may include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We might also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them and we encourage you to read them.
(d) Cookies and Similar Tracking Technologies. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
The technologies we use for this automatic data collection may include:
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time.
You shall use the Nomad products and services in the US only or in an alternate designated country with prior written permission from Nomad.
The security of your Personal Information is extremely important to Nomad. We use physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
We provide reasonable and appropriate security measures in connection with securing Personal Information we collect. For example, we:
If a security breach causes an unauthorized intrusion into our system that materially affects you, then Nomad will notify you as soon as possible and later report the action we took in response.
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.
Nomad accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Account passwords are encrypted, which means we cannot see your passwords. We cannot resend forgotten passwords either. We will only reset them.
You may send us an e-mail at firstname.lastname@example.org to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We collect certain categories of personal information when you visit our site, and we use that information for business and commercial purposes. Please refer to the California Consumer Privacy Act to view the categories and purposes for which we may collect personal information.
The purposes for which Nomad and its affiliates collect personal information include, but are not limited to:
The categories of personal information that Nomad may collect include:
The business or commercial purpose for which Nomad may disclose your personal information, include but are not limited to:
Nomad has not sold personal information in the preceding 12 months. Nomad may choose to sell the above categories of personal information for any of the business or commercial purposes listed above in the future. If you would like to opt out of the sale of your personal information in the event Nomad does sell personal information in the future, you can submit an opt-out request by sending an email to email@example.com. Personal information does not include publicly available information made available from federal, state or local records.
The California Consumer Privacy Act (CCPA) provides California residents rights regarding the collection and use of their personal information, subject to certain exceptions. An authorized party may submit requests on your behalf. The authorized party must provide a valid power of attorney, or proof of registration with the California Secretary of State as an authorized agent on your behalf.
Generally, California residents have the following rights:
CCPA applies to California residents only. For purposes of CCPA, a California resident is a person who currently lives in California, or is domiciled in California but is outside of the state for a temporary or transitory purpose. The rights described above do not apply to residents of other U.S. states or persons who reside outside of the United States.
There are certain activities, information, and circumstances involving the collection, use, processing, sale, or disclosure of personal information that are exempt or excluded from CCPA. CCPA exemptions and exclusions include, but are not limited to:
GLBA: The CCPA does not apply to personal information collected, processed, sold or disclosed pursuant to Gramm-Leach-Bliley Act and its implementing regulations (GLBA). GLBA is the federal law that regulates the collection, disclosure, and safeguarding of individuals' nonpublic personal information who obtain financial products or services primarily for personal, family, or household purposes from a financial institution. For example, if you are a California resident and you have a personal financial product with us, such as a personal credit card, the CCPA rights do not apply to the personal information associated with that account. There are other types of personal information that are not covered by the rights and limitations in the CCPA.
Fair Credit Reporting Act: CCPA does not apply to any activity involving the collection, maintenance, disclosure, sale, communication, or use of any personal information bearing on an individual's credit worthiness, credit standing, credit capacity, character, general reputation, personal characteristics, or mode of living by a consumer reporting agency, user or furnisher of consumer reports as defined under the Fair Credit Reporting Act.
Business-to-Business Relationships: Until January 1, 2021, CCPA access and deletion requests do not apply to personal information that (1) reflects written or verbal communications or transactions between Nomad and you, and (2) was collected while you were acting in the capacity of an employee, owner, officer, director, or contractor of a company, in the context of Nomad's business relationship with that company. For these purposes, a company includes sole proprietors, partnerships, non-profits, and government entities.
Employment Related Activity: Until January 1, 2021, CCPA access, opt out, and deletion requests do not apply to personal information that is (1) collected about you in the course of acting as a former or current job applicant, employee, owner, director, officer, or contractor of Nomad, and (2) used solely in the context of that role. This exemption also applies to personal information of others collected in the course of your acting in one of these roles, if it is your emergency contact information or necessary to administer your benefits.
You will not receive a confirmation to a request to opt-out. Consistent with applicable law, we will opt you out of sales at your request.
You will receive a response to your verified request within 45 days of submission, unless we notify you prior to the 45 days that the delivery date of response will be extended by an additional 45 days. Along with the response to the verified request, you will receive a copy of certain information Nomad has collected on you during the 12 months immediately preceding the date of your verified request. This will include any information provided in your verified consumer request form. Nomad is not obligated to provide a response more than twice in a 12-month period; this period begins upon your submission of the verified consumer request.
Consistent with applicable law, we will delete your personal information in response to your request.
Other third-party businesses may collect information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and app usage, and how you interact with our properties and ads in order to provide you with relevant ads across the Internet and for other analytics purposes, and may sell that information to other businesses for advertising and other purposes. By visiting here www.privacyrights.info or optout.privacyrights.info, you can opt out from sales of this type of personal information by businesses that participate in the opt out tool.
Verifiable Requests for Copy, Deletion, and Right to Know. Subject to certain exceptions, California consumers have the right to make the following requests, at no charge, up to twice every 12 months:
Deletion: the right to request deletion of their personal information that we have collected about you, subject to certain exemptions, and to have such personal information deleted.
Right to Know: the right to request that we disclose certain information about how we have handled your personal information in the prior 12 months, including the:
Submitting Requests. You can submit a deletion or right-to-know request by emailing us at firstname.lastname@example.org; we will respond to verifiable requests received from California consumers as required by law. Account holders may also submit requests in their account by going to the Help menu and using any of our customer support channels. We also ask you for additional information necessary to verify or process your request. We may also carry out checks, including with third party identity verification services, to verify your identity before taking any action with your personal information. We will respond substantively to your verifiable requests within 45 days, unless additional time (up to 45 additional days) is needed, in which case we will let you know.
Incentives and Discrimination. The CCPA prohibits discrimination against California consumers for exercising their rights under the CCPA and imposes requirements on any financial incentives offered to California consumers related to their personal information. Businesses may offer different prices, rates, or quality of goods or services if the difference is reasonably related to the value of the consumer’s data.
If you have any complaints regarding our compliance with this policy, you should first contact Nomad. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your personal information in accordance with this policy.
Last Updated: August 1, 2020