Last updated: January 30th, 2024
INTRODUCTION
Welcome to the Privacy Policy of Nicky L.L.C. (“company”, “we”, “us”, or “our”). We are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about our policy, or our practices with regards to your personal information, please contact us at [email protected] or by regular mail at:
Nicky L.L.C.
1775 I St., NW Suite 1150,
Washington, D.C. 20006
US
Company reg.no.: 92-0690436
This privacy policy applies to information collected by Nicky from or about you, through our website https://nicky.me (the “Site”) or the Nicky Application and/or otherwise through the Nicky services (the “Services”). This privacy policy thomas
therefore does not apply to information collected by third-party services or third party websites, and we recommend you consult the privacy policy for any such third-party website separately.
We are committed to being transparent and open with how we collect, use and disclose information. We hope you take some time to read through this Privacy Policy carefully, as it is important. If there are any terms in this privacy policy that you do not agree with, please discontinue use of our site and our services.
Nicky may, from time to time, develop new or offer additional services or products. If the introduction of these new or additional services or products result in any material change to the way we collect or process your personal data we will provide you with more information or additional terms or policies. Unless stated otherwise when we introduce these new or additional services or products, they will be subject to this Privacy Policy.
This Agreement shall provide for the processing of personal data in accordance with the EU Regulation 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, and repealing Directive 95/46/EC (General Data Protection Regulation).
Please read this Privacy Policy carefully as it will help you make informed decisions about sharing your personal information with us.
YOUR ACCEPTANCE OF OUR PRIVACY STATEMENT
By signing up to, accessing and/or using the Site and Services, you (including, for the avoidance of doubt, any entity or person on whose behalf you are acting) explicitly agree to the Privacy Policy set out below and agree that you fully understand it. If you do not agree, or are not comfortable, with any aspect of this Privacy Policy, your only option and remedy is to immediately discontinue use of the Site and Services.
We reserve the right to modify this Privacy Policy from time to time without notice to you. Any such changes or modification shall be effective immediately. Please take a look at the “LAST UPDATED” date at the top of this page to see when this Privacy Policy was last revised. Your use of the Site and Services following these changes means that you accept the revised Privacy Policy.
PERSONAL INFORMATION
We fully respect your right to privacy and are committed to protecting it. Any personal information which you submit via the Site or Services will be treated in accordance with this Privacy Policy.
While the Site may contain links to third-party websites, We are not responsible for the privacy policies of such other sites. We recommend that you read the privacy policies of such third-party sites that may collect your personal information. This Privacy Policy applies only to information collected by the Nicky Site and Services.
“Personal Information” we may collect is information that identifies you as an individual, such as name, email address or any other information that could directly or indirectly identify you.
How We Use Personal Information
We may use your Personal Information:
to identify who you are, including both for identification and authentication purposes and to enable you to login and access the Services;
as required for third party service providers to perform their services (see more under section DISCLOSURE OF PERSONAL INFORMATION);
to respond to your inquiries and fulfill your requests.
to send you important information regarding the Site or Services, changes to our terms, conditions, and policies and/or other administrative information.
to send you marketing communications that we believe may be of interest to you (you may, at any time, remove your details from this service by clicking on the Unsubscribe link in any email).
for our business purposes, such as data analysis, audits, developing new products, enhancing our Site, improving our Services, identifying usage trends and determining the effectiveness of our promotional campaigns.
for legal purposes. To identify who you are, including both identification and authentication purposes; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us (including for billing and collection); and to respond to legal requests, manage disputes or to prevent fraud. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond and reserve the right to, in good faith, disclose such data.
We only collect and process your Personal Data to the extent it is necessary for fulfilling these purposes. Where required, we will ask you for your prior consent.
DISCLOSURE OF PERSONAL INFORMATION
Your Personal Information may be disclosed to third parties only in the ways described in this Privacy Statement:
to our third party service providers who provide services such as contact information verification, dispute resolution services, payment processing, application fulfillment, customer service, website hosting, data analysis,
infrastructure provision, IT services, email delivery services, auditing services and other similar services to enable them to provide services. Each Service Provider must agree to use reasonable security procedures and practices in order to protect your Personal Information from unauthorized access, use or disclosure. Service Providers are prohibited from using Personal Information other than for the purpose for which such information was provided or authorized by you. Please forward any questions you may have for us to the contact information above.
to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with or properly manage any legal process, including that of the Nicky Dispute Resolution Policy; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our
affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
Personal data shall only be transferred to third countries, ie. countries outside EU/EEA which ensure an adequate level of protection, upon explicit agreement or instructions by the Controller. The Processor shall not transfer or give access to the personal data to persons in third countries without the explicit approval by the Controller. The consent or instruction given by the Controller must cover the country which the personal data shall be transferred to or accessed from. For transfer to or access from third countries for personal data it is required that the appropriate safeguards including with regard to the rights of data subjects are complied with.
NON-PERSONAL INFORMATION
“Non-Personal Information” we may collect is any information that does not reveal your specific identity, such as:
Browser information
Information collected through cookies, pixel tags and other technologies such as scripts
Demographic information and other information provided by you
Aggregated information
How We Collect Non-Personal Information
We and our third party service providers may collect Non-Personal Information from you, including your computer type, screen resolution, OS version, and Internet browser. We also aggregate Personal Information in a manner such that the end-product does not personally identify you or any other user of the Site, for example, by using Personal Information to calculate the percentage of our users who reside in a particular country.
How We Use and Disclose Non-Personal Information
Because Non-Personal Information does not personally identify you, we may use and disclose Non-Personal Information for any purpose. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your name with your geographical location). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is combined.
IP RIGHTS INFORMATION
When using the Services, you, via your authorized representative or reseller, may also be required to provide information about your intellectual property, such as details regarding your SMD File or registered trademark (collectively, “IP Rights Information”). Nicky requires this information to ensure your eligibility for the Services and to protect third party rights from infringement.
Nicky may disclose such IP Rights Information as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with or properly manage any legal process, including that of the Nicky Dispute Resolution Policy; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
THIRD PARTY SITES
This Site contains links to external websites. This Privacy Statement does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which this Site contains a link. The inclusion of a link on the Site does not imply endorsement of the linked site by us or by our affiliates.
CHILDREN’S PRIVACY
Please note that we do not knowingly permit or solicit information from individuals under eighteen (18) years of age. In addition, we do not knowingly market our products or services to individuals under eighteen (18) years of age.
INTERNATIONAL TRANSFERS
Nicky may subcontract processing to, or share your personal data with, third parties located in countries other than your country. Your personal data, therefore, may be subject to privacy laws that are different from those in your country. In such instances Nicky will ensure that the transfer of your personal data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place such as the Standard Contractual Clauses approved by the EU
Commission as well as the equivalent standard contractual clauses for the UK (“UK Addendum”) or Swiss standard data protection clauses (“Swiss SCCs”) where appropriate.
SECURITY
We take our security responsibilities seriously, employing appropriate physical, organizational and technical measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by emailing us at [email protected].
YOUR RIGHTS
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from the use of certain tracking tools such as Cookies, or from receiving electronic communications from Us and our affiliates. If you no longer want to receive marketing-related emails from Us and our affiliates on a going-forward basis, you may opt-out of receiving these marketing-related emails by following the instructions to unsubscribe contained within the email.
We will seek to comply with your request(s) as soon as reasonably practicable. Please note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.
ACCESS REQUESTS
You have the right to request a copy of the Personal Information held by us about you. You also have the right to access your Personal Information, have changed any inaccuracies in the details we hold about you, the right to object to the use of your Personal Information and the right to block any specific uses of your Personal Information.
You may make such a request by sending us an email to [email protected] or by regular mail at:
Nicky L.L.C.
1775 I St., NW Suite 1150,
Washington, D.C. 20006
US
Company reg.no.: 92-0690436
When making a request, please indicate when the information was provided, your full name, mailing address, phone number and email address so that we may identify you. We will respond to your request within a reasonable timeframe.
For your protection, we will only implement such requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
In your request, please make your request clear and we will try to comply with your request as soon as reasonably practicable.
CALIFORNIA AND VIRGINIA RESIDENTS’ RIGHTS
Residents of California, USA have additional rights afforded to them under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA, effective 1 January 2023).
Residents of Virginia, USA also have additional rights afforded to them under the Virginia Consumer Data Protection Act (VCDPA, effective 1 January 2023).
For more details, see Additional California and Virginia Privacy Disclosures.
RETENTION PERIOD
We only process your personal data for the purpose we collected it and only for so long we can justify retaining the personal data. This means, for example, that personal data we process on the basis of your consent will be deleted if you withdraw your consent. Personal data we process to fulfill an agreement with you will be deleted when the agreement is fulfilled and all obligations arising from the agreement are fulfilled. In certain cases, we may retain Personal Information for a longer period of time if doing so is necessary to e.g. collect outstanding payments, comply with legal obligations or requests, or is otherwise permitted or required by applicable law, rule, or regulation.
UPDATES TO THIS PRIVACY STATEMENT
We reserve the right to modify this Privacy Policy from time to time without notice to you. Any such changes or modification shall be effective immediately when such changes have been posted to the Site. Please take a look at the “LAST UPDATED” date at the top of this page to see when this Privacy Policy was last revised. Your use of the Site or Services following these changes means that you accept the revised Privacy Policy.
COMPLAINTS
If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here:
http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
CONTACT US
If you have any questions about this Privacy Statement, please contact us by email at [email protected] or by regular mail to:
Nicky L.L.C.
1775 I St., NW Suite 1150,
Washington, D.C. 20006
US
Company reg.no.: 92-0690436