Nuevas Soluciones Digitales SAS (”we” or “NetworkGrid” ) is committed to protecting and respecting your privacy. This Privacy Policy applies to all users of NetworkGrid’s website, products and other resources. It also applies to personal data collected by NetworkGrid concerning its suppliers, service providers, resellers and partners, or other counterparties entering into contracts or communications with NetworkGrid. It also applies to you when you act as an agent on behalf of a corporate entity.

Our Privacy Policy governs privacy issues regarding your use of our website and products, including the collection and processing of your personal information. It outlines how we collect, use, disclose, and protect your information when you sign-up for our products, interact with our website or provide information through alternative means, including, but not limited, filling out any webforms with the link to this Privacy Policy.

However, for data protection issues specifically related to the performance of contracts for NetworkGrid’s services, where you are the data controller and NetworkGrid acts under your instructions, as a data processor, please refer to our Data Processing Agreement. The Data Processing Agreement addresses the obligations and responsibilities regarding the processing of personal data in the context of our services and products.

We may collect and process the following personal data about you:

This is information about you that you give us by filling in forms on https://networkgrid.io and other websites, or by concluding a contract with us, or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you register to use our website, subscribe or use our services, search for a product, place an order, report an issue to us, or leave the information in other forms for us to contact you.

The information you give us may include :

• your identification data (your first and last name);
• your contact details (country, postal address, email address, phone number);
• additional information required for KYC procedures (proof of identity, proof of address, PEP information etc.);
• financial information;
• corporate information (company, job title, position).

With regard to your visits to NetworkGrid’s website or using our products, filling out the relevant webforms we will collect the following information:

• account settings, including technical specifications, identifiers and attributes of resources, as well as the settings for services and data;
• reasonable business records of charges, payments, and billing details and issues;
• technical and operational details of your usage of NetworkGrid’s products: usage data, operational status, software malfunctions, crash diagnostics, authentication credentials, performance evaluations, and other pertinent technical particulars crucial for the management and upkeep of products and associated software;
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer support;
• records of your interactions and exchanges with NetworkGrid and our partners, including feedback, tickets for customer support or other requests for assistance.

This is information we receive about you if you use any of the other websites we operate or the other services we provide.

We also may obtain information about you from open sources or third-party service providers who intentionally collect your information as part of their services. This information may include business contact details such as your name, company, telephone number, email address, job title, job function, and social media URLs.

We are working closely with third parties (including, for example, business partners, subcontractors in technical, payment and delivery services, analytics providers, other service providers, etc.). When required by law, we will notify you when we receive information about you from them and the purposes for which we intend to use that information.

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

4. Purposes of processing your personal data and legal basis

We use information held about you for the following purposes:

• to enter into contracts with you as a customer, reseller, partner or other countparty - Legal Basis: Necessity to take Pre-contractual Steps;
• to respond to your requests, provide you with the information you inquire, and communicate with you about our products and services - Legal Basis: Consent or Necessity to take Pre-contractual Steps;
• to comply with laws and regulations, including Know Your Customer (KYC) purposes - Legal Basis: Legal Obligation;
• to carry out our obligations arising from any contracts entered into between our customers and us and to provide with the information, products and services requested from us - Legal Basis: Performance of Contract;
• to manage our relationship with our existing customers which includes processing information for the purposes of customer administration and performance of the contract with our customers - Legal Basis: Performance of Contract or Legitimate Interest;
• to carry out analysis and reporting to build and maintain strong customer relationships - Legal Basis: Legitimate Interest;
• to incorporate your information in our databases for the purposes verification of customer identity and solvency, fraud detection and prevention to ensure that we only contract with trustworthy customers - Legal Basis: Legitimate Interest;
• to send you updates, promotional materials, marketing communication, and other relevant communications, if you have consented or signed up for our newsletter - Legal Basis: Consent;
• to provide you with information about other services or products we offer that are similar to those that you have already purchased or enquired about to market our products and services - Legal Basis: Legitimate Interest;
• to reach out to you using your business contacts we received from the open sources or third-party providers - Legal Basis: Legitimate Interest or Consent;
• to provide you, or permit selected third parties to provide you with information about services or products we feel may interest you - Legal Basis: Consent;
• to ensure that content from our website is presented in the most effective manner for you and for your computer to provide users with a positive user experience - Legal Basis: Legitimate Interest;
• to administer our referral and affiliate programs - Legal Basis: Performance of Contract or Consent;
• to facilitate your involvement in NetworkGrid's bug bounty program, where we offer rewards for discovering vulnerabilities in our code, and the review reward program, where we offer incentives for writing independent evaluations of our products - Legal Basis: Legitimate Interest or Performance of Contract;
• to oversee your application to NetworkGrid's startup support program and perform the contract for such program - Legal Basis: Performance of Contract or Consent;
• to administer our website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes - Legal Basis: Legitimate Interest;
• to allow you to participate in interactive features of our service when you choose - Legal Basis: Consent;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you - Legal Basis: Consent;
• to make suggestions and recommendations to you and other users of our website about goods or services that may interest you - Legal Basis: Consent.

Unless otherwise specifically provided by this Policy - if you are an existing customer, we will only contact you by electronic means with information about services or products similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer/prospect, or where we permit selected third parties to use your data, we (or they) will contact you by electronic means - Legal Basis: Legitimate Interest for the existing clients and consent for the new customers.

5. Disclosure of your Information and data recipients

You acknowledge that we may share your personal information, for the abovementioned purposes, with any member of NetworkGrid group, which means our subsidiaries, our holding company, its subsidiaries, and other affiliates.

We can also share your personal data with:

• credit bureaus, fraud detection agencies, or other relevant entities involved in credit assessment or fraud prevention;
• domain name registries for domain registration purposes;
• debt collection agencies or similar organizations for debt recovery processes;
• law enforcement agencies, regulatory bodies, courts, or other governmental authorities as required by law;
• other customers of the cloud provider, if misuse of services is reported and deemed necessary for enforcement of policies or laws;
• individuals or organizations making claims against misuse of services, as mandated by law;
• partners or affiliates involved in joint ventures or collaborations related to the cloud services;
• auditors or legal advisors for compliance and legal purposes;
• third-party service providers engaged in delivering the services, in alignment with this Privacy Policy, ensuring appropriate confidentiality and security measures are maintained;
• third-party providers or vendors when you procured a third-party service or goods through NetworkGrid;
• other entity as described in the Privacy Policy and in accordance with applicable laws.

In certain cases, we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Master Services Agreement, available at https://networkgrid.io/legal, and other contracts, or to protect the rights, property and safety of NetworkGrid, our customers or other persons or entities. This includes exchanging information with other companies and organisations, lawyers, consultants and auditors for the purposes of fraud protection and credit risk reduction. We will not sell, purchase, provide, exchange or in any other manner disclose your account or transaction data, or personal information about you as a cardholder to anyone, except the payment intermediaries, for instance, acquirer and Visa/Mastercard Corporations. We may use SSL and other security measures to protect such information.

6. Your Rights

You have the right (i) to obtain confirmation whether we hold your personal data and the right to access those data; (ii) to request correction of inaccurate personal data; (iii) under the conditions provided in GDPR, to ask for deletion of your personal data; (iv) to request the restriction of the processing of your personal data; (v) to portability of your data, and (vi) to ask us not to process your personal data for marketing purposes.

We will usually inform you before processing your data if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to revoke your consent to certain processing activities you approved earlier, for instance, by using the unsubscribe link in our marketing communications. You can also exercise the right at any time by contacting us at privacy@networkgrid.io. Where processing is based on consent, you have the right to withdraw your consent at any time.

You also have the right to lodge a complaint with the competent data protection authority.

7. How Long We Keep Your Data

We keep personal data for no longer than is necessary for the purposes for which it was collected and in accordance with the applicable laws.

For data processed for the implementation, administration and management of the contractual relationship this period usually will be ten years upon termination or expiration of the relevant contract (contractual relationships).

The data of our prospective customers is kept for a maximum of three years from the last contact with them or deleted if they object to the processing.

Data collected for the purpose of sending our newsletters is deleted at the request of the data subjects concerned or in the event of unsubscription.

For more information with regard to the retention of your data, please contact us at the email address given below in clause 11.

8. Changes to Our Privacy Policy

From time to time this Privacy Policy can be modified by NetworkGrid. Such modifications will not apply retroactively.

9. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@networkgrid.io.