Privacy Policy for Nisos Clients

Effective Date: February 14, 2022
Last Updated: February 14, 2022

Nisos Holdings Inc. (“Nisos”) is committed to responsible information management practices. As a part of that commitment, this Privacy Policy for Nisos Clients (“Client Privacy Policy”) is intended to provide users of our portal (the “Nisos Portal” or “Portal”) on behalf of a Nisos client (“Client”) with a clear understanding of how we collect information, how we use the information we collect, with whom we disclose such information, and the steps we take that are designed to secure the information we collect.

By using our Portal, you consent to the collection, use and sharing of your information by Nisos in accordance with this Privacy Policy.

It is important for the Portal users to read this Privacy Policy carefully. This Privacy Policy may change over time in coordination with changes to, and/or new or different offerings that we may provide in the future or otherwise make available within the Portal, or for other unforeseeable reasons. We have provided an “effective date” and a last updated so that Portal users can be aware of the Privacy Policy in effect at all times. We encourage all users to occasionally refer to this Privacy Policy so that they can remain aware of our current practices.

In the event that you are a California resident, please refer to the section of this Privacy Policy titled “Notice to California Residents—Your California Privacy Rights” for more information.

In the event that you are a resident and/or citizen of the EEA, please refer to the section of this Privacy Policy titled “Notice to EEA Citizens and Residents Only—Your Rights” for more information.

What Does This Privacy Policy Apply To?

This Privacy Policy describes our privacy practices for information that we collect through the Portal, including any users of the Portal, including when you communicate with us in any way, including by calling or emailing us, participating in an online chat, logging into and/or communicating through the Portal (e.g., via the chat feature) (collectively, “Communications”); and

What information is being collected?

  1. “Personally Identifiable Information”: This category includes information that would allow us to identify you personally. This may include information you provide when engaging with the support and/or sales team, information that you provide when using any interactive features on or through the Portal, information you provide when you report a problem to us, including information such as, contact information, such as names, addresses, e-mail addresses, user credentials, driver’s license information, social security number, passwords, and phone numbers, as well as any other information detailed in the applicable statement of work with the Client on whose behalf the end user accesses the Portal.
  2. Other Information: This category refers to information that does not directly identify a specific individual. For instance, the Portal may track the total number of visitors to the Portal, the number of visitors to a particular page of the Portal, and/or other such technical information. This data may be used to diagnose problems with the Portal, gather demographic, geographic and other information that does not directly identify you to improve our services or marketing efforts, improve our services and product, and for similar purposes. We may also make Personally Identifiable Information anonymous or aggregate such anonymous data so that it becomes Other Information.

How Do We Collect Information?

  1. Voluntarily Provided Information: Nisos may collect information, which may include Personally Identifiable Information, voluntarily provided to us by the user through the Portal. This information may be collected in coordination with a voluntary survey, information or service request, promotional contest, initiation of a support ticket or a request for assistance, uploaded to the Nisos Portal or by similar voluntary methods.
  2. Passive Information Collection: Nisos may also collect information, which may include Personally Identifiable Information, automatically when you visit the Portal. This information may include “traffic” data or IP addresses (an IP address is a number automatically assigned to your computer in order to use the Internet), or other anonymous data. Information may be collected using technologies such as standard server logs, cookies, pixels, and clear GIFs or Web beacons.
  3. When You Contact Us: Personally Identifiable Information may be gathered as a result of a ticket submission or messages sent through the Portal.
  4. Third Party Information: Nisos may collect information, which may include Personally Identifiable Information, from third parties (such as third-party platform providers) and vendors and add it to the other information collected.

How Do We Use Personally Identifiable Information?

Information collected through the Portal is used for the following purposes:

  • To provide you with the services you request;
  • To respond to requests including service ticket requests;
  • To review documents uploaded through the Portal;
  • To address inquiries or issues;
  • To maintain account information;
  • To enhance Portal operations;
  • To enforce agreements, address security hazards, prevent fraud or illegal or improper activities;
  • For administrative purposes;
  • For other legally permissible purposes.

How Long Do We Retain Information?

We retain relevant Personally Identifiable Information related to your use of the Portal and/or your business relationship with us pursuant to applicable federal and state rules and regulations and so long as retaining said Personally Identifiable Information is necessary including, but not limited to, the duration of time that you utilize our Portal, the duration for which any amounts owed to Nisos are due by you, and a reasonable period after termination of any business relationship via signed release and/or communications between Nisos and You.

We only retain your data for as long as it is necessary in connection with the relevant processing activity associated with the Portal. To determine the appropriate retention period for personal data collected in connection with the Portal, we consider the amount, nature, and sensitivity of the 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 requirements. Our website servers are located in the United States. For additional information, please contact us at privacy@nisos.com.

Nisos’ Practices.

As a security company, we are keenly aware of the need to protect your data. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, including personal data, collected on or through the Portal, we take reasonable and appropriate technical and organizational measures that are designed to protect your data from exigencies such as loss, misuse, unauthorized access, disclosure, alteration and destruction. In addition, we limit access to your data accordingly.

To What Extent Do We Disclose Your Information to Third Parties?

Nisos may share your information in the following situations:

  1. Service Providers: We may share your information, including Personally Identifiable Information, with third parties or affiliates to assist in our business operations (e.g., to process payments, store data, provided maintenance to the Nisos Portal, deliver information, and perform other similar functions), or to provide the services you have requested.
  2. Business Transfers: We may share your information, including Personally Identifiable Information, as part, of or in connection with, a merger, acquisition, assignment, as part of debt financing, the sale of company assets, or in any similar transaction, or to the extent as may be required in the unlikely event of insolvency bankruptcy, or a receivership.

How is Personally Identifiable Information Secured?

We employ safeguards designed to help preserve our Portal’s user’s security and privacy and to help prevent the misuse of any Personally Identifiable Information. These safeguards are consistent with industry standards. In addition to other procedural safeguards, we use security software (SSL, or Secure Sockets Layer, technology) and firewalls to protect your information.

Unfortunately, no data transmission over the Internet or any wireless network can be absolutely secure. As a result, while we strive to protect your Personally Identifiable Information, we can make no representations or warranties regarding the security of any data exchanged through the Portal. There are potential security risks beyond our control. With this in mind, by using the Portal you acknowledge that you are transmitting data through the Portal at your own risk.

Your Choices

You may opt out of receiving future promotional communications from us by following the instructions within a promotional communication you received from us. To learn more about your choices regarding receiving promotional emails or other communications, please email us at privacy@nisos.com.

Protection of Nisos: You agree that we, our agents, and independent contractors, may disclose your information, including Personally Identifiable Information, to the extent that we, our agents, and independent contractors, in our sole discretion, believe doing so may be appropriate, including but not limited to when it may be legally required, necessary to comply with laws, or in response to lawful requests or legal process. We may also share such information where we believe it may limit our liability in an actual or potential lawsuit, or where otherwise necessary to protect our rights, interests and/or property (including, without limitation, to enforce our agreements), or the rights, interests and/or property of our agents, independent contractors, customers, and others. This may include release of your Personally Identifiable Information if there is an unpaid balance on your account; you hereby authorize us, our agents, or our independent contractors to refer your Personally Identifiable Information to a collection agency and the unpaid balance may be reported to a credit agency, which may damage your credit.

Cookie Usage

We may use certain functional cookies on your computer to provide the Portal functionality. You may block or delete cookies and control data collection through your web browser settings. However, adjusting your browser preferences will prevent you from accessing the Portal. We use cookies to remember who you are while you use the Portal. We do not use cookies to collect personally identifiable information about you or track your behavior.

We use cookies to remember who you are and your preferences while using the Portal. Our cookies do not contain any of your personal information and only take up about one thousandth of the space of a single image from a typical digital camera.

These cookies all fall into the “strictly necessary” category of the EU Cookie legislation. This is information that is necessary in order to provide the Portal. They have a limited duration, and you may delete them at any time. Deleting them may impair your ability use our services. The next time you use our system, we will place new cookies on your system.

Contact Us

If you have any inquiries regarding our Privacy Policy, you may email us at: privacy@nisos.com

Individuals with Disabilities
If you have a disability and need access to our privacy policy in a different format, please:

Email us at: privacy@nisos.com

Notice to California Residents – Your California Privacy Rights

This section of the Privacy Policy applies solely to visitors, users, and others who are residents of the State of California (“consumers”). For purposes of this section of the Privacy Policy only, the terms defined in the California Consumer Privacy Act of 2018, as amended (“CCPA”) have the same meaning when used in this section of the Privacy Policy.

For example, when used in this section of the Privacy Policy only, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include information exempted from scope of the CCPA (such as information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act, the Gramm-Leach-Bliley Act, the California Financial Information Privacy Act, or the Driver’s Privacy Protection Act of 1994) or information exempted from the CCPA’s definition of “personal information” (such as publicly available information or consumer information that is deidentified or aggregated).

  • Sale or Sharing of Personal Information
    We do not, and will not, sell Personal Information to any third-party. We also do not, and will not, share any Personal Information with third-parties for the third-parties’ marketing purposes.
  • Notice of Collection of Personal Information
    We collect personal information when a consumer uses, visits or communicates through the Portal on behalf of Client. We may collect the following types of personal information:

     

    • identifiers such as your SSID or IP address;
    • personal information, such as your name, email address, or phone numbers;
    • commercial information, which we may requiring to assist you with requests made through the Portal and/or otherwise provide the Portal to you;
    • internet or other electronic network activity information;
    • professional information, if you choose to provide this information through the Portal.
  • Right to Know About Personal Information Collected, Disclosed, or Sold.
    Consumers have the right to request that we disclose to that consumer or his or her authorized agent:
    1. The categories of Personal Information that we have collected about that consumer;
    2. The categories of sources from which the Personal Information was collected;
    3. The business or commercial purpose for collecting or selling Personal Information;
    4. The categories of third parties with whom we share Personal Information;
    5. The specific pieces of personal information we collected about that consumer.

For each of these items, the timeframe covered by Nisos’ response will be for the 12 months preceding the receipt of the request; provided that, given the new inception of the Portal, Nisos may not have information for the entire previous twelve (12) month period.

Consumers may submit a verifiable request for this information by emailing privacy@nisos.com. When submitting a Right to Know request, please state that you are making a Right to Know request and specify whether you are requesting disclosure of specific pieces of personal information about the consumer or categories of personal information or both. Please also provide the consumer’s full name, address, telephone number, email address, account number, date of last service, cost of last service, service address, and IP address(es). We will use that information to attempt to verify the consumer’s identity by comparing the information provided to the information collected and/or maintained by us. If you are an authorized agent of a consumer or the parent/legal guardian of a minor consumer, please also provide your full name and contact information including name, address, telephone number and email address. Within 10 days of our receipt of the Right to Know request, we will provide a response that includes information about our process to verify the consumer’s identity and when the consumer or his or her agent should expect a further response.

  • Right to Access Personal Information and Request Deletion of Personal Information
    Consumers, or their authorized agent, have the right to access any Personal Information made available through the Portal and to request that we delete any Personal Information about the consumer that we have collected or that we maintain. California consumers may submit a verifiable request for this information by emailing privacy@nisos.com. When submitting a Right to Deletion request, please state that you are making a Right to Deletion request and provide the consumer’s full name, address, telephone number, email address, account number, date of last service, cost of last service, service address, and IP address(es) so that we may attempt to verify the consumer’s identity by comparing the information you provide to the information collected and/or maintained by us. If you are an authorized agent of a consumer nor the parent/legal guardian of a minor consumer, please also provide your full name and contact information including name, address, telephone number and email address. Within 10 days of our receipt of the Right to Deletion request, we will provide a response that includes information about our process to verify the consumer’s identity and when the California consumer or his or her agent should expect a further response.

 

  • Right to Not Be Discriminated Against
    Consumers have the right not to receive discriminatory treatment from us for the exercise of the privacy rights conferred by the CCPA and listed in Section 9 of this Privacy Policy. We will not discriminate against those who exercise their privacy rights. Specifically, if you exercise your privacy rights, we will not deny you goods or services, charge you different prices or rates for goods or services or provide you a different level or quality of goods or services.

 

  • Authorizing an Agent to Exercise Your Rights
    Consumers have the right to designate an authorized agent to exercise the privacy rights conferred by the CCPA and listed in this Privacy Policy on their behalf. To designate an authorized agent, a consumer must either provide the agent with an executed power of attorney or provide the authorized agent with written permission to exercise the rights set forth in this section that is signed by the consumer and notarized.

 

Notice to EEA Citizens and Residents Only—Your Rights

In relation to personal data we hold about you, you have the right to:

  • where we process your personal data based on your consent, to withdraw your consent easily and at any time (withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent);
  • get access to your personal data that we hold, and receive information about our processing of it;
  • ask us to correct the record of your personal data maintained by us if it is inaccurate or to complete incomplete personal data;
  • ask us, in certain instances, to erase your personal data or cease processing;
  • object to us processing your personal data for direct marketing purposes and for certain other purposes;
  • challenge us processing your personal data which has been justified on the basis of our or a third party’s legitimate interests;
  • ask us, in certain instances, to restrict processing personal data to merely storing it;
  • request portability of your personal data in certain limited instances;
  • be notified of a personal data breach which is likely to result in high risk to your rights and freedoms; and
  • complain to a data protection authority (contact details for data protection authorities in the European Economic Area, Switzerland and certain non-European countries (including the US and Canada) are available here).

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.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances

If you would like to exercise any of these rights, please contact us and our data protection officer at privacy@nisos.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one calendar month (starting from the day after we receive your request). Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.