Privacy Policy

Last Updated: October 12, 2021

NOWHERE is a video chat platform that allows fluid mobility in and out of conversations, activities, and events. The NOWHERE platform, website, products, and services (collectively “Services”) are provided by NWR Corp. We respect your privacy and have designed the Services with your privacy in mind.

This Privacy Policy describes how we collect, use, process, store, and disclose personal information when you access and use the Services. We may update or amend this Privacy Policy at our sole discretion. If we make material changes, we will notify you by posting an updated version on our website. If you object to any changes, you may close your account. Continued use of the Services after any such changes to the Privacy Policy have been made shall constitute your consent to such changes. When we change this Privacy Policy, we will modify the “Last Updated” date above.

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Types of Information That We Collect

We may collect both Personal Information and Anonymous Information when you access and use the Services. Personal Information means information that directly or indirectly identifies you, such as your name, email address, telephone number, or social media profile. Anonymous Information means information that does not directly or indirectly identify you, such as your computer’s operating system or browser version.

To access many of the Services, we require that you register for an account on our website and provide us with certain Personal Information, such as a valid email address, username, and password.

We may collect information about how you use the Services, such as the features you use, the actions you take, the people or accounts you interact with, and the time and duration of your activities.

You have the option to create a virtual business card to share with other users of the Services. You may add your name, company, job title, email address, phone number, and/or social media links to your business card. If you do so, we collect and store this information.

We may also collect information about you through your use of our Services. When you access and use the Services, our web server automatically collects Anonymous Information about your computer and/or browser, including the following: your browser type, IP address, operating system, internet service provider’s name and the referring URL.

How We Use Information

We may use your Personal Information for our internal purposes for any of the following reasons, as applicable: to enable you to register an account on the Services, to troubleshoot technical issues you may be experiencing and resolve any disputes, to provide you information that you have requested including information about offers and services, to enforce our terms of service, and to improve the content and general administration of the Services.

We may aggregate and use Anonymous Information to track how the Services are being used, to improve the Services, to offer new products and services, to personalize your experience, and to save your password in password-protected areas.

The Services allow you to join stations to connect with other members and receive access to certain features. Your name and email address are shared with the managers of any station of which you are a member.

Sharing Your Information with Third Parties

We may contract with certain third-party service providers in order to operate the Services. Those service providers may need access to your information, including Personal Information and Anonymous Information, to perform their services. We undertake to provide only that portion of your information needed to perform the pertinent service.

We do not sell your Personal Information to third parties.

We may share your information, including Personal Information and Anonymous Information, when legally required to do so, at the request of governmental authorities conducting an investigation or by applicable law, rule or regulation, to verify or enforce compliance with our terms of service and any other policies governing the Services, or to protect against misuse or unauthorized use of the Services. We also may disclose Personal Information or Anonymous Information whenever we believe disclosure is necessary to protect the safety, rights, or property of users of the Services or other third parties.

In the event of a merger, consolidation, or other corporate reorganization in which NWR Corp. participates, or a sale of all or substantially all of its stock and/or assets to which the Services relate, we may transfer your Personal Information to the successor entity or purchaser.

Cookies

Most Internet sites collect data about visitors through the use of “cookies.” Cookies are small text files that help sites recognize repeat visitors by assigning a random number to each desktop for tracking content preferences and traffic patterns. The Services may use browser cookies to track user behavior. Through cookies we may also record past activity in order to improve your experience with the Services or customize content based on your browser type or other information that you send us. We use cookies to verify your account, and blocking cookies may impact the functionality of the Services and prevent them from operating as expected.

The “Help” tab in the toolbar of most browsers will tell you how to prevent your browser from accepting new cookies, how to set your browser to notify you when you are to receive a new cookie, or how to disable cookies altogether.

Links to Third-Party Sites

The Services may contain links to other websites. We are not responsible for the privacy practices of other websites. This Privacy Policy applies solely to information collected by us.

Unsubscribing from Communications and Your Right to Be Forgotten

When you supply us with Personal Information in the course of registering an account, the information you provide may be added to our user database and email list.

We may send you an email with information on new products, services, and offers. If you do not wish to receive such email in the future, please contact us at support@urnowhere.com with the subject header “unsubscribe” to remove yourself from our email list.

We may send you periodic notices or announcements relating to the Services and/or your account. We reserve the right to send you such notices even if you unsubscribe from all voluntary email communications. If you do not wish to receive any communications from us at all, then you will need to delete your account entirely. To do so, go to the “My Account” page on the website and click the “Delete Account” button at the bottom of the page. Alternatively, you can email support@urnowhere.com with the subject header “delete account”. Upon your request we will delete your account as soon as reasonably possible.

Security

We employ procedural and technological measures that are reasonably designed to help protect your Personal Information from unauthorized access, disclosure, alteration, or destruction. We may use firewalls and/or password protection to help prevent unauthorized access to your Personal Information.

However, we cannot guarantee the protection of information against unauthorized access, disclosure, alteration, or destruction or that your information may not be disclosed or accessed by accidental circumstances or by the unauthorized acts of others.

The security of this information depends in part on the security of the computer you use to communicate with us, the security you use to protect usernames and passwords, and the security provided by your internet service provider. We are not responsible for the security of your internet service provider; you should review the security and privacy policies of your internet service provider carefully.

Children’s Privacy

We are committed to protecting the privacy of children. The Services are not intended or designed to attract children under the age of 13. We do not collect personally identifiable information from any person we actually know is a child under the age of 13.

Governing Law

This Privacy Policy is governed by the laws of the State of New York, without regard to its choice of law rule and without regard to the location of any user. Any dispute arising in connection with this Privacy Policy must be filed in the state or federal courts located in New York.

European Residents

If you are a resident of the European Union (“EU”) or European Economic Area (“EEA”), you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Information, as detailed below.

Subject to any exemptions provided by law, you may have the right to request access to your Personal Information, as well as to seek to update, delete, or correct your Personal Information. 

All individuals have a number of rights under data protection laws. However, they do not apply in all circumstances. If you wish to exercise any of them, please email us at support@urnowhere.com and we will explain at that time if they are applicable or not.

We will inform you in writing following receipt of your written request and if necessary, seek additional information from you about your request, including proof of identity.

The right to request access to your personal information, be informed about the processing of your personal information and receive a copy of the personal information we hold about you. We are obliged to respond to any such request within one month of receiving a request, subject to limited exceptions.

NWR Corp. will be the controller of your Personal Information processed in connection with the Services.

Data Protection Officer (GDPR)

NWR Corp. takes data privacy and security very seriously. We will always comply with any applicable data protection legislation and will ensure that collection and use of your Personal Information is carried out in accordance with applicable data protection laws. To that end, we have designated a Data Protection Officer (DPO) who shall be given the authority and responsibility of information security and data privacy. The objective of such designation shall be to have a single point of contact that shall be answerable for any information security related incidents. To communicate with our Data Protection Officer, please email privacy@urnowhere.com.

Contact Us

If you have any concerns or questions regarding this Privacy Policy, please contact us at support@urnowhere.com.

PRIVACY POLICY FOR USERS FROM THE EUROPEAN ECONOMIC AREA

This Privacy Policy for Users from the European Economic Area is an addendum to NWR Corp’s existing Privacy Policy.

All capitalized terms shall be understood as defined in the Terms of Service.

Since NWR Corp is an American company, all data collected from users is processed within the United States.

NWR Corp respects personal data of users within the European Economic Area and commits to adhering to all regulations of the generally applicable law of the European Union, in particular, with regard to Regulation (EU) 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 or GDPR).

NWR Corp ensures that its employees are trained in how to protect the personal data of its users.

Why does NWR Corp process personal data?

NWR Corp collects personal data from our users to provide the services outlined in the Terms of Service.

What rights do users have over the collection, storage and use of their personal data?

A user has the right to request from NWR Corp access to their personal data and to obtain information about the purposes of its processing, categories of data processed, recipients of data, and storage period of said data.

A user also has the right to update incorrect personal data and to provide missing personal data if they deem their personal data is incomplete.

A user has the right to request that their personal data be deleted if:

1. Their personal data is no longer required by NWR Corp to fulfill the Terms of Service
2. They have withdrawn their consent for NWR Corp to collect and use their personal data
3. They object to their personal data being used for marketing purposes
4. They object to the processing of their personal data by NWR Corp, or any third party, on any grounds unless there are valid, legally justified grounds for processing of the user's personal data that override the interests, rights and freedoms of the user, or there are grounds for establishing, investigating or defending such claims.
   

A user has the right to request that the use of their personal data be restricted if:

1. They contest the accuracy of the personal data; in this case, the use of personal data will be restricted for a period of time suitable for NWR Corp to verify the accuracy of the personal data
2. They feel that the use of their personal data is unlawful and would prefer that the use of it be restricted rather than requesting that their data deleted
3. NWR Corp no longer needs the User’s personal data, but the user still needs pieces of personal data to be retained by NWR Corp for the purpose of legal claims
4. They are in disagreement with NWR Corp as to the legitimate grounds for the use of their personal data; in this case, the user can request that the use of their data be restricted until this is resolved.
   

If a user requests that the use of their personal data be restricted, NWR Corp will refrain from using their personal data without their consent except to:

1. store or process personal data in order to establish, exercise, or defend claims
2. protect the rights of another natural or legal person
3. honor important reasons of public interest of the European Union or one of its member states.

The user will be informed about this before the restriction of processing is lifted.

The user has the right to object in case of processing of the personal data for the purposes of direct marketing, including profiling, to the extent that it is related to such direct marketing. After submitting the objection, NWR Corp will refrain from processing the personal data of the User for direct marketing purposes (including profiling). The user has the right to submit objections by automated means using technical specifications.

A user has the right to request a copy of their personal data collected by NWR Corp. The data must be given to the user in a structured, commonly-used and machine-readable format. A user also has the right to transfer their personal data to another service without interference from NWR Corp if:

1. processing takes place on the basis of the user’s consent or a contract, which performance needs processing of data; and
2. the processing is carried out by automated means.

A user has the right to withdraw their consent to the processing of personal data at any time, but the withdrawal does not retroactively apply to the consented-to use of their personal data before the withdrawal.

A user has the right to lodge a complaint with a supervisory authority about NWR Corp’s use of their personal data.

What personal data does NWR Corp collect?

In order for a user to create and maintain an account with NWR Corp, the following data are collected:

• email address;
• username;
• password.
  

When contacting a user, NWR Corp will only collect what personal data the user provides to us for such purpose.

NWR may collect a user’s email address, with te user’s consent, for the following purposes:

• The information is provided by the user during the account registration process
• The information becomes available for owners of the spaces the user visits within NOWHERE 
• The information becomes available for other people a user is connected with (but only information that the user explicitly chooses to share in their orbit card)
• The information is transported to the CRM tool and might be used for communication and marketing purposes (i.e., newsletter).

How long is personal data stored?

NWR Corp stores a user’s personal data from the moment when the user registers their account or when the user starts using the Service. After a user deletes their account or sends an email requesting to delete an account, NWR Corp will permanently remove all of the user’s data from its servers within 30 days.

NWR Corp will store user data for longer than 30 days only in instances where storing the data is necessary under a legal obligation such as in handling disputes or complaints from users.

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