• Introduction

We are delighted that you have shown interest in the services of [NSDxpert Education and Consultancy Services LLC] (hereby collectively referred to as “NURSELTC”, “we”, “us”, “our”) which are provided via the NURSELTC mobile application (hereinafter collectively referred to as the “Platform”). Data protection is our utmost priority. The use of the Platform is possible without any indication of personal data; however, if a data subject wants to use special services via our Platform, processing of personal data may become necessary. If the processing of personal data is necessary, and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the California Consumer Privacy Act (CCPA) and in accordance with the country-specific data protection regulations applicable to us. Utilizing this data protection declaration, we would like to inform the public of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, data subjects are informed through this data protection declaration, of the rights to which they are entitled.

As the controller, NURSELTC has implemented numerous technical and organizational measures to ensure the complete protection of personal data processed through this Platform. However, Internet-based data transmissions may in principle have security gaps, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g., by telephone.

• What Personal Data Do We Collect About You?

We collect personal data from you when you provide it to us directly and through your use of the Platform. This information may include:

• Information you provide to us when you use our Platform (e.g., your name, contact details, and any information which you add to your account profile);
• Transaction and billing information (collected via app distributors/ payment processors and not NURSELTC), if you make any purchases from us or using our Platform (e.g., credit/debit card details);
• Records of your interactions with us (e.g. if you contact our customer service team, interact with us on social media);
• Information you provide us when you enter a competition or participate in a survey;
• Information collected automatically, using cookies and other tracking technologies (e.g. which pages you viewed and whether you clicked on a link in one of our email updates). We may also collect information about the device you use to access our Platform; and
• Other information necessary to provide the Platform, for example we may access your location if you give us your consent.

• What Do We Use This Personal Data For?

Depending on how you use our Platform, your interactions with us, and the permissions you give us, the purposes for which we use your personal data include:

• To fulfil your transactions and maintain your online account.
• To manage and respond to any queries or complaints to our customer service team.
• To personalise the Platform to you and show you content we think you will be most interested in, based on your account information, your purchase history and your browsing activity.
• To improve and maintain the Platform and monitor its usage.
• For market research, e.g. we may contact you for feedback about our products.
• To send you marketing messages and show you targeted advertising, where we have your consent or are otherwise permitted to do so.
• For security purposes, to investigate fraud and where necessary to protect ourselves and third parties.
• To comply with our legal and regulatory obligations.

We rely on the following legal basis, under data protection law, to process your personal data:

• Because the processing is necessary to perform a contract with you or take steps prior to entering into a contract with you (e.g. where you have made a purchase with us, our partner third-party payment processors use your personal data to process the payment and complete your transaction).
• Because we have obtained your consent (e.g. where you contact us with a query, where you add optional information to your account profile, or if you consent to receive marketing from us).
• We use information about you to tailor your view of the Platform, to make it more interesting and relevant in respect of the products and offers on view.

• Marketing

Depending upon your marketing preferences, we may use your personal data to send you marketing messages by email, phone, or post. Some of these messages may be tailored to you, based on your previous browsing or purchase activity, and other information we hold about you.

If you no longer want to receive marketing communications from us (or would like to opt back in!), you can change your preferences at any time by clicking on the ‘unsubscribe’ link in any email or updating your settings in your account. If you unsubscribe from marketing, please note we may still contact you with service messages from time to time, and information about your legal rights).

You may also see ads for our Platform on third party websites, including on social media. These ads may be tailored to you using cookies (which track your web activity, so enable us to serve ads to customers who have visited our Platform). Where you see an ad on social media, this may because we have engaged the social network to show ads to our customers, or users who match the demographic profile of our customers. In some cases, this may involve sharing your email address with the social network. If you no longer want to see tailored ads you can change your cookie and privacy settings on your browser and these third-party websites.

• Who Do We Share This Personal Data With?

We share customers’ personal data with third parties in the following circumstances:

• With other companies as necessary to operate the Platform.
• With our suppliers and service providers working for us, e.g. payment processors.
• With our professional and legal advisors.
• With third parties engaged in fraud prevention and detection.
• With law enforcement or other governmental authorities, e.g. to report a fraud or in response to a lawful request.

If we sell any business assets, the personal data of our customers may be disclosed to a potential buyer. In this event, we will make reasonable attempts to ensure the buyer will be bound by the terms of this Privacy Policy. Otherwise, where we have your consent or are otherwise legally permitted to do so.

• Storage And Retention

We will keep your personal data for as long as we need it for the purposes set out above, and so this period will vary depending on your interactions with us. For example, where you have made a purchase through the Platform, we will keep a record of your purchase for the period necessary for invoicing, tax and warranty purposes. We may also keep a record of correspondence with you for as long as is necessary to protect us from a legal claim. Where we no longer have a need to keep your information, we will delete it. When you cancel your Subscription, we retain your data for at least one (1) year. Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.

• Security

This Platform ensures that data is encrypted when leaving the Platform. This process involves the converting of information or data into a code to prevent unauthorised access. This Platform follows this process and employs secure methods to ensure the protection of all credit and debit card transactions. Encryption methods such as SSL are utilised to protect customer data when in transit to and from this Platform over a secure communications channel.

Whilst we do everything within our power to ensure that personal data is always protected from our Platform, we cannot guarantee the security and integrity of the information that has been transmitted to our Platform.

• Children

Our Platform is not intended for, and should not be used by, children under the age of 18. We do not knowingly collect personal data from children under 18.

• Cookies

Our Platform uses cookies and similar technologies to provide certain functionality to the Platform, to understand and measure its performance, and to deliver targeted advertising.

• Your Rights

If you are a Consumer under the California Consumer Protection Act you have certain rights in respect of your personal data, including the right to access, portability, non- discrimination, correct and request the erasure of your personal data. 

Right to access 

• You have the right to request NURSELTC to disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive your verifiable request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The specific pieces of personal information we collected about you
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• Sales, identifying the personal information that each category of recipient purchased; and 
• Disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

Right to non-discrimination 

• We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
• However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels.
•  

Right of erasure or deletion  

• You have the right to request PerfectlyPot to delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546  seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Verifiable Customer Request 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either: 

• Contacting us via: privacy@migrate.ghnb.co.uk

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: 

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

You also have the right to object to your personal data being used for certain purposes, including to send you marketing. See ‘Marketing’ above in clause-3, for more details of how to opt-out of marketing. 

We will comply with any requests to exercise your rights in accordance with applicable law. Please be aware, however, that there are a number of limitations to these rights, and there may be circumstances where we are not able to comply with your request. To make any requests regarding your personal data, or if you have any questions or concerns regarding your personal data, you should contact us using the details below. You are also entitled to contact your local supervisory authority for data protection.

• Period For Which The Personal Data Will Be Stored

The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfilment of the contract or the initiation of a contract.

• Provision Of Personal Data As Statutory Or Contractual Requirement; Requirement Necessary To Enter Into A Contract; Obligation Of The Data Subject To Provide The Personal Data; Possible Consequences Of Failure To Provide Such Data

We clarify that the provision of personal data is partly required by law (e.g. tax regulations) or can also result from contractual provisions (e.g. information on the contractual partner). Sometimes it may be necessary to conclude a contract that the data subject provides us with personal data, which must subsequently be processed by us. The data subject is, for example, obliged to provide us with personal data when our company signs a contract with him or her. The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded. Before personal data is provided by the data subject, the data subject must contact us. We will clarify to the data subject whether the provision of the personal data is required by law, contract or is necessary for the conclusion of the contract, whether there is an obligation to provide the personal data and the consequences of non-provision of the personal data.

• Contact Us

If you have any queries on any aspect of our Privacy Policy, please contact us using the email address provided below:

hello@nsdxpert.com