PRIVACY POLICY

Last modified: May 24, 2018

NuORDER, Inc. (“Company,” “we,” “our” or “us”) is committed to protecting your privacy.  This Privacy Policy explains how we collect, use, and share the personal information we collect from visitors to our websites, including www.nuorder.com, its subdomains and related domains and all other websites where this Privacy Policy is posted, and from our customers during the provision of our online and mobile services (collectively, our “Service”). By accessing or using our websites or Service, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms and Conditions.

For the purposes of EU data protection laws (“EU Data Protection Law”), Company is a data controller (i.e., the Company is responsible for, and controls the processing of, your personal data).

For information about how we collect and use information about our customers’ end users, please see the section below headed “Customer Data”.

  1. How We Collect and Use Information

We collect your personal information in order to provide you with a personalized, useful and efficient experience. The categories of information we collect can include:

Information that you provide to us. We collect information that you provide to us when you set up an account with us, use our Service, or communicate with us. For example, we may request your personal information (e.g., name, postal address, email address, DOB, telephone number, credit/debit card number, security code) or your applicable business information when you register for an account or purchase our Service. We may also collect any communications that you exchange with us, as well as any information you provide if you take part in any interactive features of the Service (e.g., promotions, surveys, etc.).  We collect information you may provide when providing content or commentary to our Service in the form of blog posts, comments, and the like, which may be published on our site and viewable by the public.

Information we receive from social networking sites.  When you interact with our Service through various social media, such as when you login through Facebook, or share Company content on Facebook, Twitter, Pinterest, Instagram or other sites, we may receive information from the social network including your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our websites or Service.

Information from other sources. We may obtain information from other sources, such as third-party information providers, or through mergers and acquisitions, and combine this with information previously collected. In these cases, our Privacy Policy governs the handling of the combined personal information.

We use this information to operate, maintain, improve and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages about products and services that may be of interest to you.  We may also send you Service-related emails or messages (e.g., account verification, purchase confirmation, changes or updates to features of the Service, technical and security notices). Similarly, if you request information from us through an online contact form or if you email us, we collect the information you provide (e.g., name, telephone number, email address) so that we can respond to you. For more information about your communication preferences, see “Control Over Your Information” below.

  1. How We Use Cookies and Other Tracking Technology To Collect Information

We, and our third party partners, automatically collect certain types of usage information when you visit our websites, read our emails, or otherwise engage with us or our Service. We typically collect this information through a variety of tracking technologies, including cookies, web beacons, file information and similar technology (collectively, “tracking technologies”).  For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our websites or Service, for example, the site from which you came and the site to which you are going when you leave our websites, the pages you visit, the links you click, how frequently you access the websites or Service, whether you open emails or click the links contained in emails, whether you access the websites or Service from multiple devices, and other actions you take on our websites or Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.  We may collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. We may also work with third party partners to employ technologies, including the application of statistical modeling tools, which attempt to recognize you across multiple devices. Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

We use or may use the data collected through tracking technologies to:  (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our service.

If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.  Please note that doing so may negatively impact your experience using the websites, as some features and services on our websites may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies.  You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Deleting cookies does not delete Local Storage Objects (LSOs) such as HTML5. If you choose to delete Local Storage Objects from our sites, then you may not be able to access and use all or part of the sites or benefit from the information and services offered.

We and our third party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see “Third Party Tracking and Online Advertising” below.

  1. How We Share Personal Information

We may share your personal information in the instances described below. For further information on your choices regarding your information, see “Control Over Your Information.”

  • We may share your personal information with other users of the Service, and with third parties with whom you communicate or transact with on the Service.
  • We may share your personal information with third parties at your request or with your consent.
  • We may share your personal information with the public if you choose to create a “public profile” that will be available to others on the Internet. Please do not provide personal information you do not want to be public.
  • We may share your personal information with third-party service providers or business partners who help us deliver or improve our service or who perform services on our behalf, such as identifying and serving targeted advertisements, processing payments, sending postal mail, providing back-office services, or measuring site traffic.
  • We may share your personal information with third parties with whom we partner to provide contests and sweepstakes, which will usually be identified by name in the official rules of the contest or sweepstakes.
  • We may share or disclose your personal information if we determine, in our sole discretion, that we are required to do so under applicable law or regulatory requirements, or if we reasonably believe disclosure is necessary to prevent harm or financial loss, or in connection with preventing fraud or illegal activity, and/or to enforce our Terms and Conditions.
  • We may share your personal information with other companies and brands owned or controlled by Company, and other companies owned by or under common ownership as Company, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy.
  • We reserve the right to transfer any information we collect in the event we sell or transfer all or a portion of our business or assets (including any shares in the company) or any portion or combination of our products, services, businesses and/or assets. Should such a transaction occur (whether a divestiture, merger, acquisition, bankruptcy, dissolution, reorganization, liquidation, or similar transaction or proceeding), we will use reasonable efforts to ensure that any transferred information is treated in a manner consistent with this Privacy Policy.

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.

  1. Customer Data

In providing our Service, our customers may upload data to our Service, which may include personal information or data about our customers’ end users (all of which we call “Customer Data”).  Customer Data is owned and controlled by our customers, and any Customer Data that we maintain or process we consider to be strictly confidential. We collect and process Customer Data solely on behalf of our customers, and in accordance with our agreements with the customers. We do not use or disclose Customer Data except as authorized and required by our customers and as provided for in our agreements with our customers.

  1. Legal Basis for Processing Your Information in the EU

In the EU, the purposes for which we process your personal data are:

  • The provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;
  • Where it is necessary for compliance with our legal obligations laid down by EU law;
  • Where in our legitimate interests (provided these are not overridden by your interests and fundamental rights and freedoms – this includes our own legitimate interests and those of other entities and branches in our group of companies) such as:
    • to contact you and respond to your requests and enquiries;
    • for business administration, including statistical analysis;
    • to provide the Service to you;
    • for fraud prevention and detection; and
    • to comply with applicable laws, regulations or codes of practices.

We may also process your personal data on the basis of your freely given, specific, informed and unambiguous consent. You should be aware that you are entitled under the EU Data Protection Law to withdraw your consent where that has been given, at any time.  If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Service.

  1. Control Over Your Information

Email Communications. From time to time, we may send you emails regarding updates to our websites, products or services, notices about our organization, or information about products/services we offer (or promotional offers from third parties) that we think may be of interest to you. If you wish to unsubscribe from such emails, simply click the “unsubscribe link” provided at the bottom of the email communication. Note that you cannot unsubscribe from certain Service-related email communications (e.g., account verification, confirmations of transactions, technical or legal notices).

Modifying Account Information. If you have an online account with us, you have the ability to modify certain information in your account (e.g., your contact information) through “profile,” “account,” “settings,” or “preferences” options provided on the websites or Service. If you have any questions about modifying or updating any information in your account, please contact us at the email or postal address provided below. Please note that Company does not own or control the Customer Data uploaded to our Service by our customers, and cannot modify or delete Customer Data except at the request of our customer, or as permitted by our  .

  1. Third Party Tracking and Online Advertising

We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our websites over time so that they may play or display ads that may be relevant to your interests on our websites as well as on other websites or apps, or on other devices you may use.  Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the site, and other information. This information is used to display targeted ads on or through our websites or on other websites or apps, including on Facebook.  We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests.  As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device.  You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings.  You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices  and downloading the mobile AppChoices app.  You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.eu. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at privacy@nuorder.com.

  1. Data Protection and Security

Data Retention:  Following termination or deactivation of your User account, Company may retain your information commercially reasonable time for record keeping, audit or other purposes. Any Customer Data that we have access to shall be retained, stored, and deleted according to our agreement with our business customer.

Data storage and transfer:  Your information may be stored and processed in the United States or any other country in which Company or its subsidiaries, affiliates or service providers maintain facilities.  If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Policy. Such transfers are made pursuant to appropriate safeguards. If you wish to enquire further about these transfers, please contact us using the details set out at the end of this Privacy Policy.

Keeping information safe:  Company cares about the security of your information and uses commercially reasonable physical, technical and organizational measures designed to preserve the integrity and security of all information we collect.  However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

Company’s obligations with respect Customer Data are defined in our agreements with our customers and are not included in this Privacy Policy. Each customer will remain responsible for the privacy and security of the Customer Data that it collects and processes and for compliance with applicable data protection laws that may apply to the collection, processing and disclosure of Customer Data through the Service.

For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data, as detailed in this Privacy Policy and our Terms and Conditions, unless otherwise required by law.

  1. For Residents in the EU and Switzerland

If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:

  • Right of access. The right to obtain access to your personal data;
  • Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete;
  • Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed;
  • Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data;
  • Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another; and
  • Right to object. You have a right to object to processing based on legitimate interests and direct marketing.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Policy.

You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

  1. Links to Third-Party Websites and Service

For your convenience, our websites and Service may provide links to third-party websites or services that are not governed by this Privacy Policy. To the extent that any linked third-party websites or services you visit are not owned or controlled by Company, we are not responsible for those websites’ or services’ content or information practices. We encourage you to review the privacy policies of any site or service before providing any personal information.

  1. Children’s Privacy

Company’s website and services are intended for use strictly by adults. We do not knowingly solicit or collect personal information from children under the age of 13. If we learn that any personal information has been collected inadvertently from a child under 13, we will delete the information as soon as possible. If you believe that we might have collected information from a child under 13, please contact us at privacy@nuorder.com.

  1. Changes to Privacy Policy

We reserve the right to change this Privacy Policy from time to time in our sole discretion. We will post changes on this page and indicate the “last modified” date at the top of this page. Please check back often for any updates. Your continued use of our website or services after any change in this Privacy Policy will constitute your acceptance of such change.

  1. Contact Us

For additional inquiries about this Privacy Policy, please send us an email at privacy@nuorder.com, or contact us at: NuORDER, 900 Hilgard Avenue, Los Angeles, CA 90024.