Nanu Cognitive Performance

PRIVACY POLICY (Upated: 2023/06/01)

Introduction

Nanu Ltd respects the privacy of its customers, suppliers and partners. We have therefore formulated and implemented a policy on complete transparency regarding the processing of personal data, its purpose(s) and the possibilities to exercise your legal rights in the best possible way. For employees, we have formulated a separate privacy policy, available upon employment and upon request.

Definitions

Party responsible for processing personal data: Nanu Ltd; with registered address at 167-169 Great Portland Street, 5th Floor in United Kingdom and company registration number 14443667 (the “Controller”).
Data Protection Authority: The Data Protection Authority of United Kingdom.
Data Protection laws:

For European citizens or residents, the EU GDPR 2018; the EU e-privacy directive 2002 (soon to be replaced by the EU e-privacy regulation);
For UK citizens or residents, the UK GDPR 2020 and the UK Data Protection Act 2018
and/or the national laws of United Kingdom.

Collection of data

Your personal data will be collected by Nanu Ltd and its data processors.
Personal data means any information relating to an identified or identifiable natural person (‘data subject’).
An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

The types of personal data we may process:

Business process	Type	Data subject	Legal basis
Website	Location (e.g. address or IP address)	Customers	Consent
Email	Financial, Contracts, Business data	Customers, Employees, Contractors, Suppliers, Partners	Legitimate interest
Storage and exchange of documents	Not applicable	Not applicable	Legitimate interest
Delivery of goods and services	Financial, Location (e.g. address or IP address), Contracts, Software tools and applications, Business data, Technical data (e.g. source code)	Customers, Employees, Contractors, Suppliers, Partners	Performance of a contract
Financial and business administration	Identification, Financial, Date of Birth, Educational and employment history, Copy of ID, Location (e.g. address or IP address), Social Security Number, Contracts, Software tools and applications, Business data, Technical data (e.g. source code)	Customers, Employees, Contractors, Suppliers, Partners	Legitimate interest
Marketing	Business data	Customers, Contractors, Suppliers, Partners	Consent

Purposes

Nanu Ltd processes personal data for one or more of the following purposes:

Customer, employee, contractor, partner or supplier management
Business and financial administration
Direct marketing
Delivery of goods or services
Work planning

How we collect, store or otherwise process your data:

The following business processes describe how we may collect, store or otherwise process the types of personal information set out in the table above:

Collection of cookies, subscription to newsletter or filling out the contact form on the website(s);
Analyse trends and profiles, for our legitimate interest to aim to enhance, modify, personalise and improve our services and communications for the benefit of our customers;
Process and respond to support requests, enquiries and complaints received from you through use of business email;
Provide services and products requested and/or purchased by you and to communicate with you about such services and/or products. We do this as necessary in order to carry out a contract with you and in accordance with our legitimate interest to operate a business;
Carry out administrative activities such as invoicing and collecting payments either locally on devices or using cloud-services;
Store and exchange personal information contained in documents through email and cloud-services;
Marketing and customer acquisition through email or using cloud-services.

SHARING DATA WITH OTHER PARTIES

We may have to share your data with third parties, including third-party service providers. We require third parties to respect the security of your data and to treat it in accordance with the law.

We may transfer your Personal Data outside United Kingdom. If we do, you can expect a similar degree of protection in respect of your Personal Data.

We will only share your Personal Data with third parties in accordance with the GDPR and as outlined in the legal justification table above.

We share your personal data with the following enterprise third parties. We also share your data with SME third parties, details of which are available upon request. You will be notified when we have engaged with a new third party recipient of your personal data.

Stripe

Function	Payment software
Business process	Administration
Data categories	Location (e.g. address or IP address), Business data
Data subjects	Customers
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Microsoft Office 365

Function	Document storage service, Office software
Business process	Email, Digital storage of documents, Software tools and applications
Data categories	Financial, Contracts, Business data
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Google Cloud

Function	Email provider, Document storage service
Business process	Digital storage of documents
Data categories	Business data
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Calendly

Function	Appointment scheduling tool
Business process	Delivery of goods or services
Data categories	Business data
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

DocSend

Function	Document storage service
Business process	Digital storage of documents
Data categories	Business data
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

DocuSign

Function	Document storage service
Business process	Digital storage of documents, Administration
Data categories	Contracts, Business data
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Dropbox

Function	Document storage service
Business process	Digital storage of documents
Data categories	Contracts, Business data
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Adobe

Function	Other software suite
Business process	Software tools and applications, Production of content
Data categories	Photographs
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Figma

Function	Marketing tool
Business process	Delivery of goods or services, Production of content
Data categories	Software tools and applications, Business data
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Google Firebase

Function	Document storage service
Business process	Digital storage of documents, Delivery of goods or services
Data categories	Business data
Data subjects	Customers
Security measures	N/A

Google Workspace

Function	Email provider, Document storage service
Business process	Email, Digital storage of documents, Software tools and applications, Production of content
Data categories	Financial, Contracts, Business data
Data subjects	Customers, Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Github

Function	Document storage service
Business process	Digital storage of documents, Production of content
Data categories	Technical data (e.g. source code)
Data subjects	Employees
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Naq Cyber

Function	Other software suite
Business process	Digital storage of documents, Administration
Data categories	Business data
Data subjects	Employees, Contractors, Suppliers, Partners
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

Intercom

Function	Customer service software
Business process	Delivery of goods or services
Data categories	Business data
Data subjects	Customers, Employees
Security measures	Physical security such as access controls, clean desk policy and CCTV; Access controls and prevention of unauthorised access on the basis of roles and strong authentication methods; All data is encrypted at rest and access is only permitted via encrypted channels (e.g. SSL); Data is minimized and regularly deleted according to national retention periods.

International data transfers

The third parties we have engaged for the abovementioned business process may transfer your personal information to outside of United Kingdom. Nanu Ltd’s third party processors take all necessary measures to ensure the confidentiality, availability and integrity of personal data and to comply with the GDPR with regards to international data transfers. The international nature of its compliance certifications, as well as far-reaching technical security measures (including but not limited to encryption of the personal data, making the data illegible to an unauthorised recipient) are sufficient to ensure that the data subjects continue to benefit from the fundamental rights they are entitled to under the GDPR.

Nanu Ltd relies on processing agreements with these sub-processors that include the model clauses (or “Standard Contractual Clauses”) which have been tested on the adequacy of its protection with regards to the specific sub-processing activities carried out in this particular subprocessing relationship.

Additional security measures are taken to safeguard the international data transfers:

Encryption;
Anonymisation;
Pseudonymisation.

Storage and protection of data

Your data is protected by Nanu Ltd and its processors in pursuance to all legal requirements set by the relevant data processing laws. Nanu Ltd has taken technical and organizational security measures to protect your data and requires its data processors to meet the same requirements. Nanu Ltd has signed processing agreements with its processors to ensure an adequate level of data protection.

The following security measures are taken by Nanu Ltd to protect your personal data in the course of the listed business processes:

Organisational security measures

Staff

Nanu Ltd staff members are required to conduct themselves in a manner consistent with Nanu Ltd’s guidelines regarding confidentiality, business ethics, appropriate usage, and professional standards.All staff members undergo appropriate background checks prior to hiring and sign a confidentiality agreement outlining their responsibility in protecting customer data.

We continuously train staff members on best security practices, including how to identify social hacks, phishing scams, and hackers.

Access controls

Nanu Ltd maintains your data privacy by allowing only authorized individuals access to information when it is critical to complete tasks for you. Nanu Ltd staff members will not process customer data without authorization.

Data hosting

As a rule, data is hosted within United Kingdom, but it is possible that we might transfer personal data to countries within the EEA, to the UK or in exceptional circumstances outside of those areas. We ensure that we comply with the GDPR and the DPA when sending data overseas by relying on data processing agreements containing standard contractual clauses with our subprocessors or by taking additional measures to secure this data transfer, such as anonymisation.

Physical security

The data centres on which personal data is hosted are secured and monitored 24/7 and physical access to facilities is strictly limited to select staff.

Technical security measures

All devices which are used to access personal data for which we are responsible are secured with antivirus software, firewalls, encryption and access management. We regularly update operating systems and software to ensure vulnerabilities cannot be exploited.

We carry out regular vulnerability scanning of our website and have engaged credentialed external auditors to verify the adequacy of our security and privacy measures.

Your rights regarding information

Each data subject has the right to information on and access to, and rectification, erasure and restriction of processing of their personal data, as well as the right to object to the processing and the right to data portability.

You can exercise these rights by contacting us at the following email address: privacy@nanu.tech. Each request must be accompanied by a copy of a valid ID, on which you put your signature and state the address where we can contact you. Ensure that you write “Data Request” in the subject line of your email.

Within one month of the submitted request, you will receive an answer from us. We will not charge you for submitting your request unless the request is manifestly unfounded or otherwise unreasonable in its nature. Depending on the complexity and the number of the requests this period may be extended to two months.

Marketing

You may receive commercial offers from Nanu Ltd. If you do not wish to receive them (anymore), please send us an email to the following address: privacy@nanu.tech and ensure that you write “Data Opt-Out” in the subject line of your email.
Your personal data will not be used by our partners for commercial purposes.
If you encounter any personal data from other data subjects while visiting our website, you are to refrain from collection, any unauthorized use or any other act that constitutes an infringement of the privacy of the data subject(s) in question. The collector is not responsible in these circumstances.

Data retention

The collected data are used and retained for the duration determined by law. You may, at any time, request your data to be deleted from any Nanu Ltd account, system or other data processing medium in accordance with the process described above.

Applicable law

These conditions are governed by United Kingdom legislation. The court in the district where the collector has its place of business has the sole jurisdiction if any dispute regarding these conditions may arise, save when a legal exception applies.

Contact

For questions about this privacy policy, product information or information about the website itself, please contact: privacy@nanu.tech.

INTERNATIONAL DATA TRANSFERS

Stripe

Third party headquarter address	510 Townsend Street, San Francisco, CA 94103, United States of America
The primary location of processing is the USA.	Personal data collected by Stripe may be stored and processed in any country where Stripe or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Stripe’s Privacy Policy	https://stripe.com/gb/privacy

Microsoft Office 365

Third party headquarter address	1 Microsoft Way, Redmond, WA 98052, United States
The primary location of processing is the USA.	Personal data collected by Microsoft Office 365 may be stored and processed in any country where Microsoft Office 365 or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Microsoft Office 365’s Privacy Policy	https://privacy.microsoft.com/en-ca/privacystatement

Google Cloud

Third party headquarter address	1602 Amphitheatre Pkwy, Mountain View, CA 94043, United States
The primary location of processing is the USA.	Personal data collected by Google Cloud may be stored and processed in any country where Google Cloud or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Google Cloud’s Privacy Policy	https://cloud.google.com/privacy

Calendly

Third party headquarter address	271 17th St NW, Ste 1000, Atlanta, Georgia, 30363, United States
The primary location of processing is the USA.	Personal data collected by Calendly may be stored and processed in any country where Calendly or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Calendly’s Privacy Policy	https://calendly.com/privacy

DocSend

Third party headquarter address	351 California St #1200, San Francisco, United States
The primary location of processing is the USA.	Personal data collected by DocSend may be stored and processed in any country where DocSend or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see DocSend’s Privacy Policy	https://www.docsend.com/privacy-policy/

DocuSign

Third party headquarter address	221 Main Street, Suite 1550, san Fransisco, CA 94105 United States
The primary location of processing is the USA.	Personal data collected by DocuSign may be stored and processed in any country where DocuSign or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see DocuSign’s Privacy Policy	https://www.docusign.com/company/privacy-policy

Dropbox

Third party headquarter address	333 Brannan Street San Francisco, CA 94107, United States
The primary location of processing is the USA.	Personal data collected by Dropbox may be stored and processed in any country where Dropbox or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Dropbox’s Privacy Policy	https://www.dropbox.com/features/cloud-storage/cloud-security

Adobe

Third party headquarter address	345 Park Avenue San Jose, CA 95110-2704
The primary location of processing is the USA.	Personal data collected by Adobe may be stored and processed in any country where Adobe or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Adobe’s Privacy Policy	https://www.adobe.com/privacy.html

Figma

Third party headquarter address	Figma, Inc. 760 Market St, Floor 10 San Francisco, CA 94102
The primary location of processing is the USA.	Personal data collected by Figma may be stored and processed in any country where Figma or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Figma’s Privacy Policy	https://www.figma.com/privacy/

Google Firebase

Third party headquarter address	N/A
The primary location of processing is the N/A.	Personal data collected by Google Firebase may be stored and processed in any country where Google Firebase or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Google Firebase’s Privacy Policy	N/A

Google Workspace

Third party headquarter address	1602 Amphitheatre Parkway, Mountain View, CA, 94043
The primary location of processing is the USA.	Personal data collected by Google Workspace may be stored and processed in any country where Google Workspace or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Google Workspace’s Privacy Policy	https://cloud.google.com/privacy

Github

Third party headquarter address	88 Colin P. Kelly Jr. Street, San Francisco, CA 94107
The primary location of processing is the USA.	Personal data collected by Github may be stored and processed in any country where Github or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Github’s Privacy Policy	https://docs.github.com/en/github/site-policy/github-privacy-statement

Naq Cyber

Third party headquarter address	Vlamingstraat 4, 2712BZ, Zoetermeer
The primary location of processing is the The Netherlands.	Personal data collected by Naq Cyber may be stored and processed in any country where Naq Cyber or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between United Kingdom and European Union
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Naq Cyber’s Privacy Policy	https://www.naqcyber.com/policies/privacy-policy

Intercom

Third party headquarter address	2nd Floor, Stephen Court, 18-21 Saint Stephen's Green, Dublin 2
The primary location of processing is the Ireland and EEA.	Personal data collected by Intercom may be stored and processed in any country where Intercom or its affiliates, subsidiaries, or service providers operate facilities.
Safeguards (art. 45 GDPR)	Adequacy decision exists between United Kingdom and European Union
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible
For more information, see Intercom’s Privacy Policy	https://www.intercom.com/help/en/articles/1722980-how-intercom-tracks-and-stores-data

Ember

Country where data is processed or sent to	United Kingdom
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible

Seedlegals

Country where data is processed or sent to	United Kingdom
Safeguards (art. 45 GDPR)	Standard Contractual Clauses
Additional safeguards (Schrems II)	Encryption Anonymisation where possible Pseudonymisation where possible

Safeguards for international data transfers

Nanu Ltd’s third party processors take all necessary measures to ensure the confidentiality, availability and integrity of personal data and to comply with the GDPR with regards to international data transfers. The international nature of its compliance certifications, as well as far-reaching technical security measures (including but not limited to encryption of the personal data, making the data illegible to an unauthorised recipient) are sufficient to ensure that the data subjects continue to benefit from the fundamental rights they are entitled to under the GDPR.

Additional security measures are taken to safeguard the international data transfers:

Encryption;
Anonymisation;
Pseudonymisation where possible.

Where Pseudonymisation is used by this third-party processor, they ensure that the personal data can no longer be attributed to a specific data subject without the use of additional information.
This additional information is kept separately; and
Technical and organisational measures are taken to ensure that the personal data cannot be attributed to identifiable persons (encryption; database and data separation; access controls; and logging).