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Nerv | Privacy

Privacy Policy

Hi, we’re Nerv.  

You’re probably here because you’re interested to know more about how seriously we take your privacy. 

We’ve created this policy to explain things like our online information practices and the choices you can make about the way your information is collected and used because transparency is one of our core values.  

This Policy

  1. This Privacy Policy relates to information collected by Nerv Global Pte. Ltd. (referred to in this Privacy Policy as “Nerv” “we” or “us” or “our”) through your use of our website and our Services, features, and information available on our website (which are collectively referred to in this Privacy Policy as the “Nerv Service”).
  2. This Policy describes how your information, including Personal Data (described below), will be collected, used and shared in connection with your use of Nerv Services and this Site, our legal basis for doing so as well as your rights and choices regarding the information you provide to us. This Policy is intended to meet the requirements of the Personal Data Protection Act of Singapore (“PDPA”) and the EU’s benchmark General Data Protection Regulation (EU) 2016/679 (“GDPR”).
  3. We reserve the right to update this Policy from time to time. You should periodically visit this page to review the current terms of this Policy so that you are aware of any updated terms to which you are bound. If we do so, we will either notify you via e-mail or post the changes to this Policy on our site and update the “Last Updated” date at the top of this Policy as the effective date of change. However, any changes will not apply retrospectively.
  4. By using Nerv Service, you agree that you have read and understood this Policy, and you consent to our use of your information in accordance with this Policy.
    If you have any questions about this Policy or our practices, please contact our Data Protection Office (“DPO”) at privacy@getnerv.io. (“DPO Contact”

What Information do we Collect?

In order to access certain features of the Nerv Service, you will need to create an account. Creating an account requires you to provide us with your Personal Data as defined below (including personally identifiable information and non-personally identifiable information). In addition, we may obtain your Personal Data from you if you identify yourself to us by sending us an email with questions or comments.

“Personal Data” means data that may enable us to identify you personally, including data about a person who can be identified (i) from that data, or (ii) from that data and other information to which we have or are likely to have access.

Personally Ideantifiable information

Personally identifiable information identifies you or can be used to identify or contact you. Examples of personally identifiable information include:

your name, country, company name, job title, e-mail address, and billing and credit card information.

Depending on your use of the Nerv Service, we collect two types of information:

Non-Personally Identifiable Information

Non-personally identifiable information is information, any single item of which, by itself, cannot be used to identify or contact you, including demographic information (such as age, profession, company industry, gender, current location, or zip code), IP addresses, browser types, domain names, and statistical data involving the use of the Nerv Service. Certain non-personally identifiable information may be considered a part of your personally identifiable information if it were combined with other identifiers (for example, combining your zip code with your street address) in a way that enables you to be identified. But the same pieces of information are considered non-personally identifiable information when they are taken alone or combined only with other non-personally identifiable information (for example, your account preferences).

Why do we need your Personal Data?

We do not share or sell any data, including your personal data. We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to Nerv. If you register with us, you will be asked to check a tick box indicating your agreement to provide this data in order to access our services. This consent provides us with the legal basis we require under applicable law to process your data. If you do not agree to our use of your personal data in line with this policy, please do not use our platform.

Information we collect automatically when you use the Services:

We collect information about you when you use our Services, including browsing our website and taking certain actions within the Services.

  • Your use of the Services: We keep track of certain information about you when you visit and interact with any of our Services. This information includes the features you use; the chat; the type, size and filenames of attachments you upload to the Services.
  • Device and Connection Information: We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, and crash data. We use your IP address in order to approximate your location to provide you with a better Service experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
  • Cookies and Other Tracking Technologies: Nerv and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you across different Services and devices. For more information, please see our Cookies policy, which includes information on how to control or opt out of these cookies and tracking technologies.
  • Log files: We collect non-personally identifiable information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving the use of the Nerv Service. This information may be used to analyze trends, to administer the Nerv Service, to monitor the use of the Nerv Service, and to gather general demographic information. We may link this information to Personal Data for these and other purposes, such as personalizing your experience on the Nerv Service, and evaluating the Nerv Service in general.

Information we receive from other sources

We receive information about you from other Service users, from third party services, and from our business and channel partners.

  • Other users of the Services: Other users of our Services may provide information about you when they submit content through the Services. For example, you may be mentioned by someone else on a task, or a team member may upload content about you to Nerv. We also receive your email address from other Service users when they provide it in order to invite you to the Services. Similarly, an administrator may provide your contact information when they designate you as another administrator for a chat, a space, a task or a file.
  • Other services you link to your account: We receive information about you when you or your administrator enable third-party apps or integrate or link a third-party service with our Services. For example, you or your administrator may also integrate our Services with other services you use, such as to allow you to access, store, share and edit certain content from a third-party through our Services. For example, you may authorize our Services to access and display files from a third-party document-sharing service within the Services interface. The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.
  • Other partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in, and engagement with, our Services and online advertisements.
  • Nerv’s use of information received, and Nerv’s transfer of information to any other app, from Google APIs will adhere to Google’s Limited Use Requirements.

Your Rights

Where and when is information collected?

Opt-out: You may contact us anytime to opt-out of: (i) direct marketing communications; (ii) automated decision-making and/or profiling; (iii) our collection of sensitive personal data; or (iv) any new processing of your personal data that we may carry out beyond the original purpose. Please note that your use of some of the platform may be ineffective upon opt-out.

Access: You may access your Personal Data which is held by us at any time by contacting us directly. If you are within the EU, this enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Correction: You may contact us to correct any incomplete or inaccurate information we hold about you.

Erase: In situations, when the data we hold about you is no longer relevant, you can request that we delete your Personal Data.

Objection: You may object to the processing of your Personal Data, even where we are relying on legitimate interest as the legal basis for our processing. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

Restriction: You may request us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

Transfer: If you are within the EU, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent: You may withdraw your consent to process your Personal Data, in situations where we rely on your consent. If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of Nerv Services or site, which we will advise you accordingly.

Complaint and Remedy: Pursuant to the GDPR, you have inalienable rights to (i) be informed about your right to complain through this Policy, (ii) make an actual complaint to your relevant supervisory authority depending on where you live (such as the European Data Protection Supervisor), and (iii) to receive an effective judicial remedy if your rights need to be upheld or enforced.

Please note that certain rights provided above are available to you if you are within the EU in accordance with the GDPR. If the GDPR is not applicable to you, your rights will be governed by this Policy to the extent of complying with the PDPA.

You may contact us at privacy@getnerv.io anytime for any other questions you may have about your Personal Data and our use of such Personal Data.

Where will Data be Transferred to?

Your data, including personal data that we collect from you, may be transferred to, stored at and processed by us and other third parties outside the country in which you reside, including, but not limited to Singapore, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our platform, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy. Your chat, files, notes and task data will never be transferred to third parties. The only data we share with third parties is for analytics, error tracking, and marketing.

How Long will Data be Stored?

We will only retain your personal data as long as reasonably required for you to use the website or application and/or to provide you with the Services unless a longer retention period is required or permitted by law (for example, for regulatory purposes). Thereafter, we will destroy or delete the information, or remove the means by which the data can be associated with you. We will however periodically review the data we hold, and erase or anonymise it when we no longer need it.

Do we Collect Information from Children?

The Nerv Service is a business platform, and as such is not intended to be used by minor.

If you are an individual in the EU who is less than 16 years old, please do not send us any information or your Personal Data. We do not knowingly collect nor do we wish to collect and Personal Data or other user information from children under the age of 16. In the event that we learn we have collected any personal information from a child under the age of 16, we will delete the information from our database and terminate the corresponding account, if any.

What do we do with the information we Collect?

In general, we use the information collected to provide you with a great overall experience using the Nerv Service, to help us understand who uses the Nerv Service, for internal operations such as operating and improving the Nerv Service, to contact you for customer service and billing purposes, and to facilitate the delivery of our advertising in some cases.

We use your information to send you a welcome e-mail after you create an account, when you are invited to Nerv, or when you sign up for a demo, webinar or to receive our newsletter. We also use your information to send other e-mail communication related to the Nerv website. We always give you the option to unsubscribe in any email we send you.

We may also use the information gathered to perform statistical analysis of user behavior or to evaluate and improve the Nerv Service. We may link some of this information to your Personal Data for internal purposes or to improve your experience with the Nerv Service.

Pursuant to GDPR requirement of “lawful bases” for the processing of your Personal Data, we collect and use your Personal Data only where:

  1. We need to meet our contractual obligations with you by providing you with Nerv Service, and provide customer support and relevant features and protect the safety and security of Nerv Services; and
  2. We need to pursue our legitimate interest as we are a commercial software business and would need to collect the Personal Data as it is necessary to scale the functions of Nerv Services.

If we intend to use, handle or process any Personal Data in any manner that is not consistent with this Policy, we will publish a notification of change on this Site prior to the change becoming effective. You are deemed to have consented to such variation if we do not receive your notice of objection within seven (7) days from the date of the said notice. If you are in the EU, we will notify you of such change through emails and you should respond accordingly to indicate whether or not you consent to such change.


 

When do we Disclose Information to Third Parties?

Except as set forth in this Privacy Policy, the Cookie Policy or as specifically authorized by you, we will not disclose any information to third parties outside of Nerv.

Laws and Legal Rights

We may disclose your information (including Personal Data) if we believe in good faith that we are required to do so in order to comply with an applicable statute, regulation, rule or law, a subpoena, a search warrant, a court or regulatory order, or other valid legal process. We may disclose Personal Data in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be violating our Terms of Service, to detect fraud, or to protect the safety and/or security of our users, the Nerv Service or the general public. We are subject to the investigatory and enforcement powers of the Competition and Consumer Commission of Singapore.

We also may be required to disclose an individual’s personal information in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

Outside Contractors

We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to the Nerv Service, such as hosting, credit card processing and fraud screening, and mailing list hosting for the Nerv Service. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Nerv Service, including your Personal Data. We require that these contractors agree to (1) protect the privacy of your Personal Data consistent with this Privacy Policy and (2) not use or disclose your Personal Data for any purpose other than providing us with the products or services for which we contracted or as required by law.

Sale of Business

We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer of all or substantially all of the assets of Nerv or any of its Corporate Affiliates (as defined herein), or that portion of Nerv or any of its Corporate Affiliates to which the Service relates, or in the event that we discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.

Affiliates

We may disclose information (including Personal Data) about you to our Corporate Affiliates. For purposes of this Privacy Policy, “Corporate Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with Nerv, whether by ownership or otherwise. Any information relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in accordance with the terms of this Privacy Policy.

Does this Privacy Policy apply when I link to other websites or services?

The Nerv Service may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Nerv Service. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to information collected by us through the Nerv Service.

Informations about others

If you provided information on behalf of others in Nerv Service, you warrant that you have obtained the necessary authorisation from such person and he/she has agreed for you to provide such Personal Data on his/her behalf, and to give consent on his or her behalf to the processing of his or her Personal Data in accordance with this Policy, to receive on his/her behalf any data protection notices, and lastly to consent to the use and transfer of his/her Personal Data in accordance to this Policy, and you agree to indemnify us and hold us harmless from claim with regards to such authority being absent.

Is the information collected through the Nerv Service secure?

We take precautions to protect the security of your information. We have physical, electronic, and managerial procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your information. However, neither people nor security systems are foolproof, including encryption systems. In addition, people can commit intentional crimes, make mistakes or fail to follow policies. If applicable law imposes any non-disclaimable duty to protect your Personal Data, you agree that intentional misconduct will be the standards used to measure our compliance with that duty.

Could my Information be Transferred to other Countries?

Personal Data collected on the Nerv Service may be transferred from time to time to our offices or personnel, or to third parties, located throughout the world, and the Nerv Service may be viewed and hosted anywhere in the world, including countries that may not have laws of general applicability regulating the use and transfer of such data. To the fullest extent allowed by applicable law, by using the Nerv Service and submitting such information on it, you voluntarily consent to the trans-border transfer and hosting of such information. To the fullest extent allowed by applicable law, if you are a User accessing the Nerv Service from a jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from those of Singapore, please be advised that all aspects of the Nerv Service are governed by the internal laws of Singapore, regardless of your location.

Do Not Track

The term “Do Not Track” refers to an HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests.

How will I know if there are any changes to this Privacy Policy?

We may revise this Privacy Policy from time to time. We will not make changes that result in significant additional uses or disclosures of your Personal Data without notifying you of such changes via email. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your Personal Data, for which an email is not required. We encourage you to check this page periodically for any changes. If any changes to this Privacy Policy are unacceptable to you, contact us immediately and stop using the Nerv Service until the issue is resolved. Your continued use of the Nerv Service following the posting of non-significant changes to this Privacy Policy constitutes your acceptance of those changes.

Whom do I Contact if I have any Privacy Questions?

If you have any questions or comments about this Privacy Policy or feel that we are not abiding by the terms of this Privacy Policy, please contact us by email at privacy@getnerv.io.

Subject to the next paragraph, we ask that you not send or disclose to us any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through [the Site/Applications(s)/Services] or otherwise.

If you send or disclose any sensitive personal data to us when you submit user-generated content to our Site or Services, you consent to our processing and use of such sensitive personal data in accordance with this policy. If you do not consent to our processing and use of such sensitive personal data, you must not submit such user generated content to our platform.

 

Governing Law and Dispute Resolution

Irrespective of the country from which you access or use this Site or Nerv Services, to the extent permitted by law, this Policy shall be governed in accordance with the laws of the Republic Singapore without regard to choice or conflicts of law principles, and you hereby agree to submit to the exclusive jurisdiction of the courts of Singapore to resolve any claims or disputes which may arise in connection with this Policy. Any disputes concerning this Policy and claims concerning breach or inadequacy of Personal Data protection raised by an EU Individual will be dealt with in accordance (to the maximum permissible extent) with the GDPR.

By using the Nerv Service, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, you should not use the Nerv Service. Continued use of the Nerv Service following the posting of changes to this Privacy Policy that do not significantly affect the use or disclosure of your Personal Data will mean that you accept those changes.