Last updated: 12th June 2024
This Privacy Policy covers the services provided by Noloco Limited trading as Noloco (“Noloco”, “we”, “us” or “our”). Noloco is incorporated in Ireland with company registration number 685318 and having its registered address at 77 Camden Street Lower, Dublin 2, D02 XE80, Ireland. This Privacy Policy provides details of the way in which we process personal data in line with our obligations under the General Data Protection Regulation (No. 2016/679) (“GDPR”), the Data Protection Act 2018 and any other laws which apply to us in relation to the processing of personal data (collectively referred to as “Data Protection Laws”). In this Privacy Policy, “controller”, “processor”, “personal data” and “process” (and its derivatives) have the meanings given to those terms in Data Protection Laws.
Personal data generally means information that can be used to individually identify a person, and processing generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Noloco will be the controller of your personal data processed in connection with our services.
Noloco enables users (the “User” or “Project Owner”) to build web applications and websites (collectively, a “Project”) that can be made accessible for use by the general public (“End Users”). Such Projects are built, hosted and managed on the Noloco Platform (the “Platform”).
To the extent that the Project Owner inputs personal data into the Platform and Noloco processes the personal data, both parties acknowledge that the Project Owner acts as the data controller and Noloco as the data processor that processes personal data on behalf of the Project Owner. If you are an End User of a Project and have queries about how your personal data is processed by the Project Owner or wish to address your rights, please contact the Project Owner.
The purpose of this Privacy Policy is to explain Noloco’s data processing activities, including how and why we process personal data. In addition, this Privacy Policy outlines our duties and responsibilities regarding the protection of such personal data. The manner in which we process personal data will evolve over time and we will update this Policy from time to time to reflect changing practices.
We collect personal data about you when you provide it directly to us through the Noloco Platform, when third parties such as Project Owners provide us with personal data about you, or when personal data about you is automatically collected in connection with your use of the Noloco website *.noloco.io (the “Website”). Noloco does not disclose your personal data to third parties, except as outlined in this Privacy Policy.
In providing our services, we may collect and process the following information:
We receive personal data directly from you when you provide it to us through use of the Website, submit data through Projects developed on the Noloco Platform or through creating an account on the Noloco Website, including, but not limited to:
- name
- email address
- home address
- payment details
A Project Owner may provide us with personal data about you to deliver services (“Project Services”) to you through the Noloco platform. The Project Owner is responsible for outlining the Project Services delivered through their Project.
Some personal data is automatically collected when you use the Website, such as:
- IP address;
- device identifiers;
- browser information; and
- cookie data (as explained in our Cookie Policy).
We process personal data to operate, improve, understand and personalise our services e.g. we use personal data to:
- personalise Noloco content based on your preferences;
- communicate with you
- protect against or deter fraudulent, illegal or harmful actions;
- respond to user inquiries;
- provide support and assistance;
- comply with our legal or contractual obligations;
- enforce our terms and conditions; and
- resolve disputes.
Data Sharing and Disclosure
We are committed to protecting your personal data and only share your information as described below:
Security procedures are in place to protect the confidentiality of your data. The data we store for your Noloco app(s) and the transmission of information between your device and our servers is protected using 256-bit TLS encryption. This data is also encrypted at-rest. For more information on how Noloco protects your data view our Security page.
Data Protection Laws provide certain rights in favour of data subjects (the “Data Subject Rights”).
Data Subject Rights include the right of a data subject to:
- receive detailed information on the processing (as per transparency obligations on controllers) which we have provided through this Privacy Policy;
- access personal data;
- rectify or erase personal data (i.e. right to be forgotten);
- restrict processing;
- data portability;
- object to processing; and
- object to automated decision making (including profiling).
These Data Subject Rights will be exercisable by you subject to limitations as provided for under Data Protection Laws.
If you require more information about how a Project Owner processes your personal data or you wish to exercise any of your data subject rights in respect of the processing of your personal data by a Project Owner you should contact the Project Owner directly.
In relation to the processing of your personal data by Noloco, you may contact us or make a request to exercise any Data Subject Right by contacting support@noloco.io. Your request will be dealt with in accordance with Data Protection Laws.
We do not share any personally identifying data with third parties and will not disclose your personal data to any other party except as set out in this policy. Noloco may be required to disclose personal data in some scenarios e.g. when you violate our terms and conditions or other policies. Noloco may disclose such personal data, at our sole discretion, if we believe it necessary or appropriate in connection with investigation of fraud, IP infringement, piracy, or other unlawful activity. This may require disclosure of your name, address, phone number, or email.
Noloco may engage other companies and people to perform tasks on our behalf (i.e. processors) and may need to share your information with them to provide you with our services e.g. delivery services, hosting services, analysing data, billing, and marketing assistance.
In some cases, Noloco may buy or sell its assets which may involve the transfer of user information. Noloco will transfer such information if we are acquired by or merged with another company. In this event, we will notify you by email.
Without limiting the above, in an effort to respect your privacy and Noloco’s ability to keep the community free from bad actors, we will not otherwise disclose your personal data to law enforcement, other government officials, or other third parties without a court order, law enforcement request, legal process, or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to protect Noloco’s rights or the rights of third parties, prevent physical harm or financial loss, or to report suspected illegal activity.
We may transfer to and process your personal information in countries outside of the jurisdiction where you are located for the various purposes described above. When required bylaw, we will ensure that we rely on an appropriate legal mechanism for the transfer, such as your consent, standard contractual clauses (or their equivalent), or adequacy decisions. You may ask us, via email, using support@noloco.io, for more information about the specific basis we use for transferring your data.
We will keep personal data only for as long as the retention of such personal data is deemed necessary for the purposes for which that personal data are processed (as described in this Privacy Policy) unless we are required to retain your personal data for a longer period (e.g. in the event of legal proceedings or investigations).
On occasion, we include links to third parties on the Website. Where we provide a link it does not mean that we have any control over the linked website or its privacy policy or that we endorse, or approve that website’s policy towards visitor privacy. You should review the linked website’s privacy policy before sending them any personal data.
Any changes to this Privacy Policy in the future will be posted to the Website and, where appropriate, through email notification. Noloco may send you Noloco service-related announcements. You may not opt-out of service-related communications.
For further information about this Privacy Policy or the processing of your personal data by or on behalf of Noloco, please contact us at support@noloco.io.
While you may make a complaint in respect of Noloco’s compliance with Data Protection Laws to the Data Protection Commission, we ask that you contact us in the first instance to give us the opportunity to address your concerns.