Privacy Policy

Effective Date:  August 2, 2018

This Privacy Policy describes how Nucleus195 LLC (“Nucleus195” or “we”) collects and processes information.

Please read this Privacy Policy carefully.  When you submit information to us, you consent to the processing of your information as described in this Privacy Policy.

1.  SCOPE

This Privacy Policy applies to use of public portions of Nucleus195.com and its affiliated websites, as well as subscription services available only to registered users (collectively, “Services”).  If a particular part of the Services posts its own privacy policy, then that policy — not this Privacy Policy — applies.

This Privacy Policy does not apply to information that is collected offline or by any third-party website or service that you access through the Services.  IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, THEN PLEASE DO NOT USE THE SERVICES.

Our right to process information also may be described in our agreements with our customers (“Subscription Agreements”).  If a provision of a Subscription Agreement conflicts or otherwise is inconsistent with a provision of this Privacy Policy, then the term of the Subscription Agreement will prevail to the extent of the conflict or inconsistency.

In this Privacy Policy, to “process” information means to perform any operation on the information, whether or not by automated means, such as collection, recording, organizing, storing, adapting, use, disclosure, combining, erasing or destroying.

2. CHANGES TO THIS PRIVACY POLICY

The Effective Date of this Privacy Policy is set forth at the top of this webpage.  As we add new features to the Services, we may amend this Privacy Policy.  If we make a material change to this Privacy Policy that reduces your privacy rights, we will notify you in advance through the Services.  Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy.  The amended Privacy Policy supersedes all previous versions.

3. INFORMATION WE COLLECT

When you use the Services, we collect the information you give us when using the Services. This includes:

• When you create an account, you provide us with at least a user name and password, business information, such as name, business name, business address, email address, business phone number and any other information that you provide us.
• When you make a purchase, you provide us or the payment service provider with payment information, such as your debit or credit card number.
• When you participate in surveys or focus groups, you give us your insights into our products and services
• If you contact our customer service team, we collect the information you give us during the interaction.  Sometimes, we monitor or record these interactions for training purposes and to ensure a high quality of service.

Information we receive from others

We receive information about you from others, including your employer, Content Providers and our service providers.  We also receive information about your from the third parties that help us operate the Services, such as for fraud detection, digital forensics and similar functions. 

Information collected when you use the Services

When you use the Services, we collect information about which features you use and how you use them and the computer, tablet or mobile telephone (“Device”) that you use to access the Services (collectively, “Usage Data”). 

• Usage Information

We collect information about your activity on the Services, such as features you use and your search queries, through our server logs.  A server log is a list of the activities that a server performs.  Nucleus195’s servers automatically collect and store in server logs your search queries, Internet Protocol (IP) address, hardware settings, browser type, browser language, the date and time of your request and referral URL and certain cookies that identify your browser or Nucleus195 account.

• Device information

We collect information from and about the Device that you use to access the Services, including:

• • hardware and software information such as IP address, Device ID and type, Device-specific and apps settings and characteristics, app crashes, browser type and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your Device or browser
  • information on your wireless and mobile network connection, like your service provider and signal strength.

We may link personal information and Usage Data or different types of Usage Data.  We also may link publically-available personal information, such as personal information available in public databases. If the linked information may identify an individual person, we treat it as personal information.

Information collected through Data Collection Technology: We use cookies, pixel tabs (also known as web beacons, flash cookies and clear GIFs) and similar technology (“Data Collection Technology”) to automatically collect information about you when you use the Services.  Please read below to learn more about how Nucleus195 uses Data Collection Technology. 

Other information with your consent

We collect other information when you give us permission at the time of collection.

4. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

Cookies are small text files that are sent to or accessed from your web browser or your computer’s hard drive.  A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using the Services.  A web beacon (also called a pixel tag or clear GIF) is a piece of computer code that enables us to monitor user activity and website traffic.  To learn more about cookies and web beacons, visit www.allaboutcookies.org.

How We Use Data Collection Technology: Data Collection Technology helps us improve your experience of the Services by, for example, storing your password so you do not have to re-enter it each time you use the Services, compiling statistics about use of the Services and helping us analyze technical and navigational information about the Services and to detect and prevent fraud.

The Services use the following cookies:

• Strictly necessary cookies, which are required for the operation of the Services. Without them, for example, you would not be able to register or log in for the Services that we may offer.
• Analytical/performance cookies, which allow us to recognize and count the number of visitors, to learn how visitors navigate the Services and to help us to improve the way Services function.
• Functionality cookies, which are used to recognize you when you return to the Services.

We also use Google Analytics which is a Google service that uses Data Collection Technology to collect anonymous information about use of the Services and report website trends.    

Your Control of Cookies: Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your Device.  You also may be able to reject Device identifiers by activating the appropriate setting on your Device. Although you are not required to accept cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.

Our Policy On Do Not Track Signals: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked.  If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain personal information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, many website operators, including Nucleus195, do not respond to DNT signals.

5. HOW WE PROCESS PERSONAL INFORMATION

Nucleus195 processes personal information:

• To set up and maintain your account;
• To communicate with you;
• To prevent and investigate fraud and other misuses of the Services;
• To protect our rights and property;
• To operate, manage, secure and improve the Services;
• To respond to your questions and to try to resolve problems with one of our products;
• To complete transactions requested by you; and
• To help us improve our customer service.

Nucleus195 processes Usage Data:

• To analyze trends and gather broad aggregate demographic information;
• To statistically monitor how many people are using the Services;
• To develop, improve and protect the Services;
• For audience research;
• To audit and analyze the Services; and
• To ensure the technical functionality and security of the Services.

To process your information as described above, we rely on the following legal bases:

• Provide our service to you: Most of time, the reason we process your information is to perform the contract that you have with us when you agreed to our Terms of Service.
• Legitimate interests: We may use your information when we have legitimate interests to do so. For instance, we analyze users’ behavior on the Services to continuously improve our offerings and to process information for administrative, fraud detection and legal purposes.
• Consent: From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time by contacting us at the address provided at the end of this Privacy Policy.

6. HOW WE SHARE INFORMATION

Nucleus195 may share personal information collected via the Services as follows:

• Service Providers: We share information with our third-party service providers that help us operate the Services, such as by providing customer service or product support or testing and hardening our security measures.  Nucleus195 will ensure that any service provider with which we share personal information agrees to use commercially reasonable measures to safeguard it.

• Corporate Transaction: We may share and transfer personal information if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control by Nucleus195 or any affiliated company (in each case, whether in whole or in part).

• When Required by Law:  Applicable law may require Nucleus195 to disclose your personal information if: (i) reasonably necessary to comply with legal process (such as a court order, subpoena or search warrant), government investigation or other legal requirements  or (ii) necessary for the prevention or detection of crime (subject in each case to applicable law).

• Other Lawful Disclosures: We also share information if (i) disclosure would mitigate Nucleus195’s liability in an actual or threatened lawsuit; (ii) as necessary to protect legal rights of Nucleus195, users, customers, business partners or other interested parties; (iii) to pursue available remedies or limit the damages; (iv) to enforce our agreements; and (v) to respond to an emergency.

Nucleus195 may aggregate information collected though the Services and remove identifiers so that the information no longer identifies or can be used to directly identify an individual (“Aggregated Information”).  Nucleus195 shares Aggregated Information with third parties and does not limit third parties’ use of the Aggregated Information.

7. CROSS-BORDER DATA TRANSFERS

Sharing of information sometimes involves cross-border data transfers. As an example, personal information of users of the Services located in the European Economic Area (“EEA”) is transferred countries outside of the EEA.  Your information may be maintained and processed in the US and other jurisdictions.  When required by law, we use lawful mechanisms to legitimize data transfers from the EEA to other countries. 

8. YOUR CHOICES ABOUT YOUR INFORMATION

If you do not wish to receive marketing-related emails from us, please click the unsubscribe link in one of our marketing emails or contact us at privacy@nucleus195.com. 

• Device & App Permissions. Mobile platforms have permission systems for specific types of Device data.  You can change your settings on your Device to either consent to or oppose the collection of information. Of course, if you do that, certain Services may lose full functionality. You can stop all information collection by an App by uninstalling it using the standard uninstall process for your device.
• Account Deactivation & Deletion. You can deactivate (where this functionality exists) or delete your account in your account settings or by contacting us at privacy@nucleus195.com
• Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you. You can request a copy of your personal information by emailing us at privacy@nucleus195.com.
• Updating your information. If you believe that the information we hold about you is inaccurate or if you believe that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us by emailing us at privacy@nucleus195.com.

In your request, please make clear what personal data you would like to have changed, whether you would like to have your personal data suppressed from our database or other limitations you would like to put on our use of your personal data.  For your protection, we will verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we often need to retain certain data for recordkeeping purposes and our databases and other records may have residual data that we will not remove. We also may not allow you to review or delete certain data for legal, security or other reasons.

• Accountability. In certain countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information.  If you are an EEA resident, you have the right to lodge a complaint with a data protection authority about how we process your personal information.

If at any time you believe that the Services have not adhered to this Privacy Policy, please let us know. We will use good faith efforts to determine and correct the problem.

Notice to California Residents: California Civil Code Section 1798.83 permits individual California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at privacy@nucleus195.com.

9.  LINKS TO OTHER WEBSITES AND SERVICES

The Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from the Services. A link to a third-party website or service does not mean that we endorse it or the quality or accuracy of information presented on it.  If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours.  This Privacy Policy does not apply to any personal information that you provide to these other websites and services. 

10. PROTECTION & RETENTION OF PERSONAL INFORMATION

We take precautions intended to help protect information that we collect and store.   Unfortunately, however, no system or online transmission of data is completely secure. We cannot guarantee the security of information transmitted to or through the Services.  Any transmission is at your own risk and we expect that you will use appropriate security measures to protect your information.  We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security.

If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below. 

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law.  In practice, this means that we delete or anonymize your Account and personal information associated with it after two (2) years of continuous inactivity, unless we must keep it to comply with applicable law; because an issue, claim or dispute has not yet been resolved; or the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. 

Please note that, although our systems are designed to carry out data deletion processes, we cannot promise that deletion will occur within a specific timeframe due to technical constraints.

11. CHILDREN’S PRIVACY

The Services are not directed to or intended for use by minors.  Consistent with the requirements of the Children’s Online Privacy Protection Act, if we learn that we have received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services.

HOW TO CONTACT US

Please contact us at privacy@nucleus195.com or at Nucleus195 LLC, Attn: Privacy, 68 Southfield Avenue, 2 Stamford Landing, Suite 100, Stamford, CT 06902.