privacy

Privacy Policy  

Introduction

This privacy policy covers Noir Space BH Limited referred to as (“We”, “Us”, “Our”). Noir Space BH (The Noir Space BH mobile app available for iOS and Android referred to here as the “App”) and Noir Space BH Website (Any Website accessible under the www.noirspacebh.com domain referred to here as the "Website") are provided by Noir Space BH. Consumers of the app will be referred to as ("You, "User").

We are committed to respecting your privacy. The purpose of this Privacy Policy is to explain how we may use any data we collect about you, how you can instruct us if you prefer to limit the use of that data and for us to tell you about the policies and procedures that we have in place to respect your privacy.

Please read this Privacy Policy carefully to understand how we handle your data. 
When you use the App /Website, you consent to the collection, storage, use, disclosure and other uses of your Personal Information as described in this Privacy Policy. You also confirm that you have read and understood the entirety of this Privacy Policy.

1. Grounds for data collection 

Processing of your personal information (i.e. any information which may potentially allow your identification through reasonable means; hereinafter " Personal Information ") 

1.1 "Your data'' means any data about you from which you can be identified. When you sign up to our App access or communicate with other users. If you connect with other users or share content on our feeds, your personal information may be processed by or shared with our associated companies, software developers, hardware developers, introducers, intermediaries, agents, our Principal and where applicable our administrators or any other company that distributes, advertises or recommends our products on our behalf.

1.2 Some of these organisations may be situated in countries outside the European Economic Area. If we transfer your data to these countries we will take steps, described in section 12, to ensure your information is appropriately protected. If you have consented, we will also use your data to provide you with updates where necessary, which will let you know about any additional products or services we offer and will provide you with useful control tips.

1.3 When you use the App / Website we may track data about how you navigate the App / Website to analyse usage, to manage these services, and to report aggregate information i.e. glitches to trusted third parties such as Firebase.

1.4 We reserve the right to use your data for other purposes set out in this Privacy Policy, for example, to respond to legal or regulatory requests, or to transfer your data to a purchaser of our business.
2. What information do we collect?

We collect two types of data and information from Users. 

2.1 The first type of information is un-identified and non-identifiable information pertaining to a User(s), which may be made available or gathered via your use of the Website (“ Non-personal Information ”). We are not aware of the identity of a User from which the Non-personal Information was collected. Non-personal Information which is being collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information (e.g. the type of browser and operating system your device uses, language preference, access time, etc.) in order to enhance the functionality of our Website. We may also collect information about your activity on the Website (e.g. pages viewed, online browsing, clicks, actions, etc.).

2.2 The second type of information Personal Information which is individually identifiable information, namely information that identifies an individual or may, with reasonable effort, identify an individual. Such information includes but is not limited to:
  • Registration information: When User (s) register personal information with our app you will be asked to provide us with certain details such as: full name; age, email, country region, contact number, education, experience, organisation, job title, phone contact list and other sensitive information such as gender. 

3. How do we receive information about you?

We receive User Personal Information from various sources:
  • When you voluntarily provide us with your personal details in order to register on our App;
  • When you use or access our App in connection with your use of our services.

4. What information do we collect?

We do not rent, sell or share Users’ information with third parties, except as described in this Privacy Policy.

4.1 We may use the information for the following;
  • To serve you advertisements when you use our Website (see more under "Advertisements"); 
  • To market our website, App and products (see more under "Marketing"); 
  • For statistical and analytical purposes, intended to improve the Website.
  • To track and improve our ability to serve our existing customers and acquire new customers; and
  • To improve our risk models and algorithms;
  • To provide guidance on how to use the App;
  • To contact you regarding administrative matters or notices or to deal with any enquiries made by you, to resolve disputes and to troubleshoot problems;
  • Providing you with our services, including providing a personalised display of our Website / App;
  • Storing and processing such information on our behalf to improve services and functionality; 
  • Serving you with advertisements and to assist us in evaluating the success of our advertising campaigns and help us retarget any of our users;
  • Providing you with marketing offers and promotional materials related to our Website and services; 
  • Performing research, technical diagnostics, geo-located data; or analytics;
  • Process your registrations and allow you to access and use the App;
  • To verify your identity for security purposes;
  • To service your end-to-end chat encryption service (including calls and messaging) and policy requests to enable us to maintain your privacy;
  • To price up subscription costs and identify different pricing models that are tailored to your profile and account needs;
  • To ensure our App and Website services are secure;
  • With your express consent only, we may also use your data to send you information about related products or services that may be of interest to you;
  • Hosting and operating our Website.

4.2 Information we receive from other sources. We will receive information about you if you use any of the other Websites or Apps we operate or the other services we provide. In this case we will have informed you when we collected that data that it may be shared internally and combined with other data we collect through the App / Website. We work closely with third parties (including, for example analytics and search information providers "Firebase", software providers "Digital Ocean" and IT Consultants "Trigonsoft Ltd") and may receive information about you from them.

4.3 Communicating with User – sending you notices regarding our services, providing you with technical information and responding to any customer service issue you may have and to keep you informed about our latest updates and services;
  • User Reporting Feedback: If you choose to give us feedback through our Website or App, we’ll use your feedback, combined with others, at an aggregate level, to identify any fixes needed and to improve our products and services;
  • Communicating with you: When you email us or use our feedback report option in the app, we use this info to help us with things like resolving account/functional issues or investigating malicious behaviour reported;
  • Customer Service: If you contact us, we will process your data so that our Customer Service or Technical teams can fix any issues you’ve raised, as well as for training and quality purposes. Noir Space BH relies on your consent when you contact us in order to provide services you have requested from us; and our legitimate interests when we use data at an aggregate level to improve our services.
4.4 Aggregated data. We may collect and aggregate, on an anonymous basis, information about you, your spending and your use of the Website with information about other users of the Website in order to identify trends.
4.5 ("Aggregated Data"). Aggregated Data will not contain information from which you may be personally identified.
We may track data about how you navigate the Website to analyse usage and how visitors navigate the Website. This allows us to manage the App / Website and to see what content is most popular.

4.6 We may pass Aggregated Data to the third parties referred to in the section below, such as partners, to give them a better understanding of our business and to bring you a better service in the future where necessary but you will be informed when that happens.

4.7 In processing your data as discussed in this Privacy Policy, we consider this processing is necessary to provide you with our service and enable you manage your network in a secure environment. Where this may not apply, processing is necessary for our legitimate interests in providing the App / Website and ensuring they operate in a commercially suitable way which is tailored to your use and interests. In some cases, this processing is also subject to your consent (which can be withdrawn at any time, as described below).

In addition to the different uses listed above, we may transfer or disclose Personal Information to our subsidiaries, affiliated companies and subcontractors when deemed necessary.

5. In addition to the purposes listed in this Privacy Policy, we may share Personal Information with our trusted third-party providers, who may be located in different jurisdictions across the world, for any of the following purposes: 
  • Our employees, service providers, sub-contractors and agents to administer your account and the products and services provided to you by us now or in the future, including but not limited to our database processors;
  • Analytics providers that assist us in the improvement and optimisation of our App / Website;
  • Our distribution partners, which includes software developers / engineers, hardware developers and any other company that distributes, advertises or recommends networking Apps on our behalf.
5.1 We may also disclose your data to third parties:

We may also disclose information if we have good reason to believe that disclosure of such information is helpful or reasonably necessary to: (a) comply with any applicable law, regulation, legal process or governmental request; (b) If we sell or buy any business or assets, we may disclose your data to the prospective seller or buyer of such business or assets; (c) if we, or substantially all of our assets, are acquired by a third party, your data held by us may be one of the transferred assets; (d) enforce our policies (including our Agreement), including investigations of potential violations thereof; (e) investigate, detect, prevent or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (f) to establish or exercise our rights to defend against legal claims; (g) prevent harm to the rights, property or safety of us, our users, yourself or any third party; or (h) for the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.

5.2 Except as detailed above, we will never share, sell or rent any of your data to any third party without notifying you and/or obtaining your consent.

6. Optional and Future Services

6.1 There are optional services which you may choose to sign up to. The information required will vary for each service which is offered. This section explains the information we collect for each service, and how we may use it. These uses are in addition to the uses described in sections 4 and 5 of this Privacy Policy.

6.2 Emails and notification alerts: You may sign up to receive other emails and notification alerts when you sign up to the App / Website, which will let you know about any additional products or services we offer and will provide you with useful flight tips. If you agree, we may share your information with these additional products and services. You can cancel your subscription to newsletters, emails and alerts by contacting us via the email address or other methods which you will normally find at the bottom of the newsletter, email and alert in question.

6.3 Remember, if you consent to receive texts from us, your mobile network may impose a charge on incoming texts. Please check with your mobile network provider for details.

7. User Rights

7.1 You may request the following but not subject to: 
  • Rectification - You can ask us to correct inaccurate or incomplete information by clicking here.
  • Access - You can ask us for copies of your data. This right always applies but there are some exceptions by clicking here.
  • Remove – You can ask us to remove your data in some circumstances by clicking here.
  • Object to Processing - You can object to how we process your data by clicking here.
  • Restrict processing - You can ask us to restrict processing of your information in some circumstances by clicking here. 
7.2 Your request must include your:
  • Full name;
  • Email address, user name, contact number used to register with your Noir Space BH account;
  • We may also request proof of your address i.e. Utility Bill within the last 3 months, Full UK Driving Licence and or Passport to verify account
7.3 Please allow at least 14 working days for us to respond to requests and we manage the privacy of your data in line with the Data Protection Act 2018.

7.4 However, please note that these rights are not absolute and may be subject to our own legitimate interests and regulatory requirements. Without limiting the above, you have the right to ask us to not process your data for marketing purposes. We will inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. Alternatively, you can contact us by email at contact@noirspacebh.com at any time.

7.5 If you have previously given your consent to the use of your data for marketing purposes, you can choose to stop receiving marketing communications which we send to you from time to time by following the unsubscribe instructions included in such communications. Alternatively, you can opt out of such communications at any time by contacting us by email at contact@noirspacebh.com.

8. Retention

We will retain your personal information for as long as necessary for the purpose intended to provide our services, and as necessary to comply with our legal obligations, resolve disputes and enforce our policies. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable opportunity. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations. 

We may rectify, replenish or remove incomplete or inaccurate information, at any time and at our own discretion.

9. Cookies

We and our trusted partners use cookies and other technologies in our related services, including when you visit our Website or access our services. 

9.1 A "cookie" is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes. These purposes include allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and our Services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our Services. 

9.2 The Website uses the following types of cookies:

a. 'session cookies' which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed; 

b. 'persistent cookies ' which are read only by the Website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in; 

c. 'third-party cookies' which are set by other online services who run content on the page you are viewing, for example by third-party analytics companies who monitor and analyse our web access.

9.3 Cookies do not contain any information that personally identifies you, but Personal Information that we store about you may be linked, by us, to the information stored in and obtained from cookies. You may remove the cookies by following the instructions of your device preferences; however, if you choose to disable cookies, some features of our Website may not operate properly and your online experience may be limited.

9.4 We also use a tool called “Google Analytics” to collect information about your use of the Website. Google Analytics collects information such as how often users access the Website, which pages they visit, when they do so, etc. We use the information we obtain from Google Analytics only to improve our Website and services. Google Analytics collects the IP address assigned to you on the date you visit Websites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

9.5 Custom and Lookalike audiences
 
We use custom and similar audiences at Noir Space BH in order to advertise to existing and potential customers via social media platforms. 

A custom audience is a type of audience created made up of existing customers. We may target ads to the audience we’ve created across common social media channels, outlined below.

We also use carefully selected social media platforms to create Lookalike Audiences. These are lists of people to target with advertising who are similar to (or 'look like') people currently engaging with us in the community. For both types of activity (custom audiences and Lookalike audiences) we aim to target people based on aggregate customer behaviour. For example, people who have recently connected or registered as a new user in the app.

The platforms we use include: 

Instagram: for more info
LinkedIn: for more info
Twitter: for more info

10. Third-party collection of information

Our policy only addresses the use and disclosure of information we collect from you. To the extent you disclose your information to other parties or Websites throughout the internet, different rules may apply to their use or disclosure of the information you disclose to them. Accordingly, we encourage you to read the terms and conditions and privacy policy of each third party that you choose to disclose information to. 

This Privacy Policy does not apply to the practices of companies that we do not own or control, nor to individuals whom we do not employ or manage, including any of the third parties which we may disclose information to as set out in this Privacy Policy. 

11. How do we safeguard your information?

We take great care in implementing and maintaining the security of the Website and your information. 


11.1 We use industry standard efforts to safeguard the security and confidentiality of your data. These methods include but are not limited to:

 

  • Encrypting all messages in transit via HTTPS;
  • Separate security and business concerns to ensure resilience (Two point verification);
  • Encrypting all user chats and credentials;
  • Preventing unauthorised data access by isolating data;
  • Preventing malicious traffic with firewalls;
  • Users accounts are password protected with a 2 Factor Authentication system;
  • We take weekly backups protect our customers against data loss, which we clear out every 28 days;
  • Although we make every effort to protect your data, the transmission of data over the internet is not completely secure. As such, you acknowledge and accept that we cannot guarantee the security of your transmitted data, and that any such transmission is at your own risk.
  • We will only transfer data outside of the EEA where there has been an Adequacy Decision or where it is safeguarded under Standard Contractual Clauses.

 


11.2 Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorised access or abuse our app, and we make no warranty, express, implied or otherwise, that we will prevent such access. However, we will isolate incidents and log issues as quick as possible. We will report all data breaches via the public electronic communications service (PECS) at the Information Commissioner's Office (ICO), and users will be notified where applicable regarding breaches that may impact their person data.

12. Transfer of data outside the United Kingdom (UK)

Please note that some data recipients may be located outside the UK. In such cases we will transfer your data only to such countries as approved by the UK as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.


12.1  We may transfer Personal Data outside of your home country; however, we will always ensure that this is done in compliance with the relevant laws of your country. 


We will normally use and share personal data outside of your country for the following reasons:


  • to carry out corporate oversight of our mobile app business globally
  • to provide shared services in certain functions such as HR, Finance, and IT
  • to deploy certain services and resources across the business globally
  • to facilitate interactions and sustainability measures between our contractors across our app globally


12.2 We will ensure that any transfer of Personal Data outside of any jurisdiction is undertaken using legally compliant transfer mechanisms and in accordance with relevant laws.


12.3 Some of these countries do not have laws that protect your privacy rights as extensively as those in the United Kingdom. However, if we do transfer your data to other territories, we will take proper steps, the safeguard procedures we use are described in section 11, to ensure that your data is properly protected and processed only in accordance with this Privacy Policy.


12.4 By providing us with your data, you acknowledge that such transfer, storage and processing of your data may take place.


12.5 While you’re using our services, your personal data will be safe with us, but we’ll never keep it for longer than we need to. As soon as we don’t need your personal data to offer our full services to you, we’ll make sure it’s either deleted or anonymised.


13. Advertisements

13.1 We may use a third-party advertising technology to serve advertisements when you access the Website. This technology uses your information with regards to your use of the Services to serve advertisements to you (e.g., by placing third-party cookies on your web browser). 

13.2 You may opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). For more information about this practice by NAI and DAA members, and your choices regarding having this information used by these companies, including how to opt-out of third-party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

14. Marketing

14.1 We may use your Personal Information such as your name, email address, telephone number, etc., ourselves or by using our third-party subcontractors, for the purpose of market research or providing you with promotional materials concerning our services which we believe may interest you.  

14.2 Website Marketing activities: may include us inviting you to participate in market research, such as surveys, interviews, or other activities (to improve our service for you). We may use third parties to carry out that research, these third parties may require you to sign up to their terms in order to participate in such market research. We may also use carefully selected third party analytics tools to help analyse research responses;

We may send things like marketing emails and App push notifications in order to let you know about our system updates, community opportunities and more from Noir Space BH. This may include competitions and promotions like our Refer-a-Friend programme coming soon. We want to send you marketing messages to give you the best user experience and info, and we’ll only send you messages that we think will be relevant to you. 

14.3 To respect your right to privacy, within such marketing materials we provide you with the means to opt out of receiving further marketing offers from us. If you unsubscribe, we will remove your email address or telephone number from our marketing distribution lists. Processing this data is conducted based on legitimate interests, or consent (where you have opted-in to marketing where necessary).
14.4 Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important email communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

However, we want your input in our market research so that we can keep improving our products and services. We use the absolute minimum amount of your personal data to carry out this research such as full name, contact number, gender and email address.

15. Corporate transaction

We may share information in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale). In the event of the above, the transferee or acquiring company will assume the rights and obligations as described in this Privacy Policy. You will be informed in advance prior to any such event.

16. Minors

We understand the importance of protecting children’s privacy, especially in an online environment. The App is not designed for or directed at anyone under 16 years of age. Under no circumstances shall we allow the use of our services by minors without prior consent or authorisation by a parent or legal guardian. We do not knowingly collect Personal Information from minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at contact@noirspacebh.com for us to remove this data as soon as possible.

17. Updates or amendments to this Privacy Policy

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments. However, we encourage users to be responsible about their privacy and recommend that you consult this page frequently so that you are aware of our latest policy and can update your preferences if necessary. Your continued use of this App / Website shall constitute that you have read and understood the revised privacy policy.

18. How to contact us

If you have any general questions about the Website or the information we collect about you and how we use it, you can contact via email. Please note that this Privacy Policy is not legal advice but a statement of guidance general guidance purposes only. If you wish to exercise any of the above rights or receive more information, please contact our Data Protection Officer (“DPO”) at contact@noirspacebh.com.


If you are located in the EEA, you may also make a complaint to a supervisory body for data protection matters in the country in which you are based. In the UK, this would be the UK Information Commissioner's Office (https://ico.org.uk/). Alternatively, you may seek a remedy through local courts if you believe your rights have been breached. This Privacy Policy is merely a guide and not to used as legal advice.


Last Modified  Tuesday 9th January 2024.

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