Privacy

INTRODUCTION

At Nublado Sp. z o.o., a company registered in Poland ("we", "us", "our"), we are fully committed to processing your personal data with the utmost care, ensuring its security and privacy. This Privacy Policy sets out our obligations related to the processing of your personal data across all Nublado operations, particularly in relation to our Apps and Services, in accordance with our Standard Contract, which supplements this policy. This policy applies uniformly to all of our digital products, including our website, regardless of their specific features or the platform from which they are accessed, to ensure a consistent and lawful experience for all users of our products.  

We have created this document to fulfil our information obligation under the law. You must read and accept this Privacy Policy as a condition of your use of our services, as it is essential to your understanding and consent before you can use our App or Services. This policy is also referenced when we need to obtain information or consent from you and in our ongoing communications.  

Please read this document carefully to understand the scope, reasons and conditions under which we process your personal data. Our legal bases for processing your personal data may include the performance of a contract with you or compliance with legal requirements under the General Data Protection Regulation ("GDPR"), which is Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, which repeals Directive 95/46/EC. 

DATA CONTROLLER

Protecting your privacy is fundamental to Nublado. Please note, however, that when you use our Apps or Services, we most often only act as a data processor (with limited access to your data) and not as a data controller. For example, Nublado acts as a data controller when you sign up for our newsletter or create an account on our Apps. In cases where our Apps are integrated with or support the use of third-party platforms, Nublado may act as a data processor, but only if we process the data on behalf of the platform owner. However, this is usually not the case, as it is the owner of Microsoft Azure who handles the data, and Nublado only partially provides solutions for how Microsoft Azure processes this data. 

When we act as a data controller, in the circumstances or processes below, our responsibility extends to both the purpose and means of the processing of your personal data, in accordance with the high standards of privacy and data protection contained in our Privacy Policy. 

If you have any questions or would like to exercise your data protection rights, please contact our Privacy Team.  

Email: privacy@nublado.pl 

CATEGORIES, PURPOSES AND LEGAL BASIS OF DATA PROCESSING

In our mission to provide you with a smooth experience on Nublado's apps and services, we primarily collect personal data directly from your interactions, such as when you sign up or use features in our apps or services. Such direct interaction includes activities such as creating an account, using features or communicating with us or subscribing to our newsletter. Our approach avoids automated decision-making based on your data. 

Your engagement results in the collection of data in a variety of ways, including through direct data entry into our applications or services, and sometimes through third-party integrations. The extent of your interaction with our services determines which sections of this Privacy Policy apply to your data. 

When you use or interact with our apps or services, even without creating an account, we only process the personal data you choose to share with us. This can be basic information such as your name, surname, contact details (email, phone), or more specific data such as company name, job title, business interests and preferences – depending on the specific application or service you use or are interested in. We aim to improve your experience by providing tailored suggestions and marketing activities based on the data you provide to us and our analysis. 

For users who use our apps and services across devices, we may also process technical and usage-related data to provide you with an optimal experience. This includes, m.in things, device details, IP addresses, and session statistics to ensure that our apps and services run smoothly. 

The legal basis for processing your data is the performance of a contract, compliance with legal regulations and our legitimate interest in quality management and analytics, in accordance with Articles 6(1)(b), (c) and (f) of the GDPR. Providing data is a voluntary step, but necessary to access our services and their functionalities. 

For applications and services that require registration, it is necessary to provide additional data, such as your email address or login information via social media, to enable you to create and access your account. Storing this data is in line with our contractual obligations and legal requirements, ensuring the functionality and security of your account. 

Subscribing to our newsletter requires the processing of your contact details based on our legitimate interest in direct marketing and brand promotion (Article 6(1)(f) GDPR). The processing of this data is voluntary, but necessary for the delivery of the newsletter and lasts as long as you do not opt out of receiving it. 

Inquiries and contact with us (via contact forms and our e-mail addresses) lead to the processing of personal data that you provide (such as name, surname, e-mail address, company name, position and possibly other information contained in the imprint), including the content of the communication, on the basis of your consent or our legitimate interest in providing timely and accurate answers (Articles 6(1)(a) and (f) of the GDPR). This data is necessary to handle your enquiries and is stored for the period needed to resolve related issues or until the expiry of the limitation periods for legal claims. 

ENTRUSTING THE PROCESSING, SHARING OR TRANSFER OF DATA

To ensure the optimal functionality of our Apps and Services, it is sometimes necessary to entrust your personal data to our partners. These entities, selected for their ability to improve the quality of their services, include, m.in, IT system providers, cloud hosting services and email operators. We ensure that these collaborations are governed by strict data processing agreements that require that your data is only processed in accordance with our guidelines. 

In certain cases, we may also disclose your personal data to independent data controllers, such as judicial or regulatory authorities, where required to do so in order to comply with legal obligations or to protect our legal interests. 

The nature of our activities determines the categories of third parties with whom your data may be shared: 

For general use of our Applications and Services: This includes providers of IT infrastructure, technology services, email operators, hosting companies, as well as entities to whom you have consented to provide marketing information. 

When you purchase a subscription, create an account, or provide services: This category includes payment processors, digital platforms that enable you to access our Applications or Services, subcontractors, and technology and IT support companies. 

For sending newsletters: We use providers of IT systems and e-mail platforms. 

If you contact us directly: Communications may include postal services, couriers, IT support providers and our consulting team, including legal counsel, if necessary. 

In addition, we may anonymize your data by removing any personally identifiable information from it in order to use it to create business or statistical analyses related to the functioning of our Applications. 

When it comes to international data transfers, particularly outside the European Economic Area (EEA), we use safeguards such as standard contractual clauses approved by the European Commission, which are part of our Standard Contract. These measures ensure that your data is protected at a level that complies with European standards by working with recognized service providers. We work with trusted cloud service providers, such as Microsoft Azure, to ensure secure data storage and management. 

PROTECTING YOUR DATA

At Nublado, we are deeply committed to protecting the confidentiality, integrity, and availability of your personal information. To this end, we have put in place robust security measures, both organisational and technical, to align our operations with the highest standards and applicable legal requirements. Our comprehensive information security policies contain detailed guidelines and safeguards designed to prevent your data from being lost, damaged, altered, or accessed in an unauthorized way. These include, but are not limited to, encrypting data in transit and at rest, regular security assessments, and putting in place strict access controls. 

When it comes to handling payment information, such transactions are managed by independent platforms where you purchase our subscriptions. As a result, we do not have direct access to your payment details. 

Please note that our Apps and Services may contain links to other websites or applications. We are not responsible for the content or data processing practices of these third-party sites and applications. We encourage you to read their privacy policies before sharing any personal information. 

YOUR PRIVACY RIGHTS

As a Nublado user, you have certain rights regarding the personal data we process about you. This includes the right to access your data and obtain a copy of it, with certain exceptions as required by law. You also have the right to have outdated or incorrect personal data corrected, as well as to request the deletion or restriction of the processing of your data, unless we are legally obliged or entitled to continue processing it for legal, tax, accounting purposes or in connection with the defence of potential claims.  

Under certain circumstances, you have the right to receive your personal data in a structured, commonly used and machine-readable format and to transmit this data to another data controller (data portability).  

You also have the right to withdraw consent previously given, however, this does not affect the lawfulness of the processing carried out before the withdrawal of consent.  

To exercise your rights or withdraw your consent, please contact us at: privacy@nublado.pl  

If you believe that we are not complying with data protection laws, we encourage you to contact us. However, you also have the right to lodge a complaint with the relevant supervisory authority, which in Poland is the President of the Office for Personal Data Protection (President of the Office for Personal Data Protection). 

USE OF COOKIES

Our website uses cookies to ensure that all of its functions function properly. These small data packets, stored in accordance with your browser settings, do not allow us to identify users of the website, but they may track data such as session ID, IP address, device location and browsing behavior.  

We may also use third-party cookies for analytical, statistical, marketing and social media purposes, including services such as Google Analytics.  

You have the option to adjust the cookie settings in your browser, and if you do not change them, you agree to our use of cookies. 

POLICY UPDATES

We reserve the right to change this Privacy Policy at any time. Updates will be available on our website, on the platforms hosting our apps, and sent to your registered email address or through in-app notifications if necessary.  

This Privacy Policy comes into force on 14.03.2024. 

QUESTIONS? CONTACT US

Nublado Services SP. z o.o. Address: 3 / 5 Henryka Sienkiewicza Street,  

80-227 Gdansk, Poland e-mail: info@nublado.pl