Naitive

Privacy Policy

This privacy policy sets out how Naitive Technologies Ltd collects, uses and protects your personal data through your use of this website.

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us at privacy@naitive.com

Personal data means any information about an individual from which that person can be identified.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

· Identity Data e.g. first name, last name, any previous names, username or similar identifier, marital status, title, date of birth and gender

· Contact Data e.g. geographic address, email address and telephone numbers

· Technical Data e.g. internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, device ID and other technology on the devices you use to access this website

· Usage Data e.g. information about how you interact with and use our website, products and services

· Marketing and Communications Data e.g. your preferences in receiving marketing from us and our third parties and your communication preferences

We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as it does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to calculate the percentage of users accessing a specific website feature in order to analyse general trends in how users are interacting with our website to help improve the website and our service offering.

We use different methods to collect data from and about you including through:

· Your interactions with us: you may give us your personal data by filling in online forms or by corresponding with us by post, phone, email or otherwise

· Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further details.

· Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources

· Technical Data is collected from the following parties: analytics providers; advertising networks; and search information providers, and

· Identity and Contact Data is collected from publicly available sources

Data protection law requires us to have a legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:

· Performance of a contract with you: Where we need to perform the contract we are about to enter into or have entered into with you.

· Legitimate interests: We may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

· Legal obligation: We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to. We will identify the relevant legal obligation when we rely on this legal basis.

· Consent: We rely on consent only where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter.

We have set out below, in a table format, a description of all the ways we plan to use the various categories of your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Use	Type of data	Legal basis [and retention period]
To manage our relationship with you which will include: (a) notifying you about changes to our terms or privacy policy (b) dealing with your requests, complaints and queries	(a) Identity (b) Contact (c) Profile (d) Marketing and communications	(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with you
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)	(a) Identity (b) Contact (c) Technical	(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) (b) Necessary to comply with a legal obligation
To deliver relevant website content and online advertisements to you and measure or understand the effectiveness of the advertising we serve to you	(a) Identity (b) Contact (c) Profile (d) Usage (e) Marketing and communications (f) Technical	Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, customer relationships and experiences and to measure the effectiveness of our communications and marketing	(a) Technical (b) Usage	Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To send you relevant marketing communications and make personalized suggestions and recommendations to you about goods or services that may be of interest to you based on your Profile Data	(a) Identity (b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications	Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and grow our business) OR Consent, having obtained your prior consent to receiving direct marketing communications
To carry out market research through your voluntary participation in surveys		Necessary for our legitimate interests (to study how customers use our products/services and to help us improve and develop our products and services).

During the registration process on our website when your personal data is collected, you will be asked to indicate your preferences for receiving direct marketing communications from us.

We may also analyze your Identity, Contact, Technical, Usage and Profile Data to form a view which products, services and offers may be of interest to you so that we can then send you relevant marketing communications.

You can ask to stop sending you marketing communications at any time.

We will not share your personal data with any third party for their own direct marketing purposes.

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for a period after they cease being customers for regulatory and tax purposes.

In some circumstances we will anonymize 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 information indefinitely without further notice to you.

You have a number of rights under data protection laws in relation to your personal data. You have the right to: request access to your personal data to check that we are lawfully processing it: request correction of the personal data that we hold about you; request erasure of your personal data in certain circumstances; object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) as the legal basis for that particular use of your data (including carrying out profiling based on our legitimate interests); you also have the absolute right to object any time to the processing of your personal data for direct marketing purposes; request the transfer of your personal data to you or to a third party; withdraw consent at any time where we are relying on consent to process your personal data; request restriction of processing of your personal data. If you wish to exercise any of the rights set out above please contact us at privacy@naitive.com

You have the right to make a complaint at any time to your national regulator for data protection issues, for example, the Information Commissioner’s Office (ICO) in the UK (www.ico.org.uk). Please contact us in the first instance.

We keep our Privacy Policy under regular review and may amend it from time to time. Please check our Privacy Policy every time you wish to use our site. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us, for example a new address or email address.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.