Privacy Policy

Effective Date/Last Updated: November 2020

This Privacy Policy (“Policy”) describes how NT Analyzer Holdings (“NTAH”, “we,” “our,” or “us”), collects, uses, shares, and protects your information, including personal information/personal data (collectively, “personal information”), when you use the features on our Site (www.ntanalyzer.com) or enter into a contract with or otherwise engage with us (collectively, “Services”). NTAH, together with its affiliates (Norton Rose Fulbright US LLP) is the data controller in relation to your personal information.

This Site is intended for representatives of businesses, and is not intended for consumers.

Information We Collect

The types of information, including personal information, we may collect include:

Information You Give to Us

  • Full name
  • Email address
  • Phone number
  • Other information you may provide in our online contact form

Other Information We Collect

  • Geolocation related to our Site location features
  • Details about devices used to access our Site such as IP address, browser information, device information, cookies, HTML5 localStorage and similar technologies. This is discussed further below.

How We Collect Your Information

We may collect personal information from various sources, including:

  • When you voluntarily provide it to us
  • When you interact with our Site
  • When you contact us through the Site
  • From third parties for our business purposes
  • When you communicate with us
  • When you provide it through our Site
  • Directly from you, at your direction or with your consent
  • In connection with your use of the Services
  • From our service providers, partners, and third parties, such as those discussed in the “How We Use Your Information” and “How We Share Your Information” sections below
  • From other platforms that you may use to engage with us
  • Automatically, from devices that you use to connect to our Site

From time to time, we may use or augment the personal information we have about you with information obtained from other sources, such as public databases, social media platforms and other third parties.  For example, we may use such third party information to confirm contact information.

How We Use Your Information

We will only use your personal information where we are permitted to do so by applicable law, such as to provide our Services. Under applicable law, the use of personal information must be justified under one of a number of legal grounds. The principal legal grounds that justify our use of your personal information are:

  • Contract performance: where your information is necessary to enter into or perform our contract with you.
  • Legal obligation: where we need to use your information to comply with our legal obligations.
  • Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
  • Legal claims: where your information is necessary for us to defend, prosecute, or make a claim against you, us, or a third party.
  • Consent: where you have consented to our use of your information (you will have been presented with a consent form or facility in relation to any such use and may withdraw your consent through an unsubscribe or similar facility).

We may use your personal information in the following ways. In each case, we note the grounds that we rely on to use your personal information.

  • To provide our services to you and to conduct our business – to administer and perform our services, including to carry out our obligations arising from any agreements entered into between you and us;

Legal grounds: contract performance, legitimate interests (to enable us to perform our obligations and provide our services to you), consent.

  • To facilitate use of our Site and to ensure content is relevant – to respond to requests for information or inquiries from visitors to our Site and to ensure that content from our Site is presented in the most effective manner for you and for your device;

Legal grounds: legitimate interests (to allow us to provide you with the content and services on the Site), consent, contract performance.

  • For marketing and business development purposes – to provide you with details of new services, updates and invites to seminars and events where you have chosen to receive these. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt out by contacting us as set out in our Contact Us section below.

Legal grounds: legitimate interests, consent.

  • To fulfil our legal, regulatory, or risk management obligations – to comply with our legal obligations (performing client due diligence/”know your client”, anti-money laundering, anti-bribery, sanctions or reputational risk screening, identifying conflicts of interests); for the prevention of fraud and/or other relevant background checks as may be required by applicable law and regulation and best practice at any given time (if false or inaccurate information is provided and fraud is identified or suspected, details may be passed to fraud prevention agencies and may be recorded by us or by them); to enforce our legal rights, to comply with our legal or regulatory reporting obligations and/or to protect the rights of third parties;

Legal grounds: legal obligations, legal claims, legitimate interests (to cooperate with law enforcement and regulatory authorities, to ensure that you fall within our acceptable risk profile and to assist with the prevention of crime and fraud). Where we process special categories of personal information we may also rely on substantial public interest (prevention or detection of crime) or legal claims.

  • To ensure that we are paid – to recover any payments due to us and where necessary to enforce such recovery through the engagement of debt collection agencies or taking other legal action (including the commencement and carrying out of legal and court proceedings);

Legal grounds: contract performance, legal claims, legitimate interests (to ensure that we are paid for our services).

  • To inform you of changes – to notify you about changes to our services or our Privacy Policy;

Legal grounds: legitimate interests (to ensure we can notify you about changes to our Service, etc.).

  • To reorganize or make changes to our business – In the event that we are undergo a reorganization (for example if we merge, combine or divest a part of our business), we may need to transfer some or all of your personal information to the relevant third party (or its advisors) as part of any due diligence process or transfer to that reorganized entity or third party your personal information for the same purposes as set out in this Privacy Policy or for the purpose of analyzing any proposed reorganization;

Legal grounds: legitimate interests (in order to allow us to change our business).

We may also aggregate any personal information that we collect in connection with our Services, such that the information is no longer personally identifiable or attributable to you. We may use such aggregated information for our own legitimate business purposes without restriction.

How We Share Your Information

We may share the information we collect:

  • With service providers that perform services for us or on our behalf, such as for business functions and operations, and for fulfilling requests by you
  • With other parties for our marketing purposes
  • With your consent and at your direction
  • When you voluntarily provide content for the purpose of it being shared with us or other users

We may also disclose personal information in order to assist with or otherwise enable our compliance with a legal or regulatory obligation, protect and defend our rights or property, and protect the safety of our users or the public.

We reserve the right to transfer the information we maintain in the event we sell or transfer all or a portion of our business or assets.  If we engage in such a sale or transfer, we will make reasonable efforts to direct the recipient to use your personal information in a manner that is consistent with this Privacy Policy. After such a sale or transfer, you may contact the recipient with any inquiries concerning the recipient’s privacy practices.

How long we keep your personal information

We will retain your personal info for as long as is necessary to fulfill the purpose for which this data was collected and any other permitted linked purpose (for example certain transaction details and correspondence related to any services we provide may be retained until the time limit for claims in respect of the transaction has expired or in order to comply with regulatory requirements regarding the retention of such data). If your personal information is used for two purposes, we will retain it until the purpose with the latest period expires; but we will stop using it for the purpose with a shorter period once that period expires. Our retention periods are also based on our business needs and good practice.

What rights you have in relation to your personal information

If you have any questions about your personal information, you should first contact us via the details provided in our Contact Us section below. Under certain circumstances and in accordance with application data protection laws, you may have the right to require us to:

  • provide you with further details on the use we make of your information;
  • provide you with a copy of information that we hold about you;
  • take reasonable steps to ensure that your personal information remains accurate;
  • update any inaccuracies in the personal information we hold;
  • delete any personal information that we no longer have a lawful ground to use;
  • where processing is based on consent, to withdraw your consent so that we stop that particular processing;
  • object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
  • restrict how we use your information while a complaint is being investigated.

While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) and some of these rights may be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal information to defend our legal rights or meet our legal and regulatory obligations.

If you contact us to exercise any of these rights, we will check your entitlement and respond in most cases within a month.

If you are not satisfied with our use of your personal information or our response to any exercise of these rights, you have the right to complain to the relevant Supervisory Authority (data protection regulator) which in the United Kingdom is the Information Commissioner’s Office.

Which countries we transfer your personal information to

If you engage us for our Services and you are within the United Kingdom or the European Economic Area (EEA), then in most cases we will process your personal information within the United Kingdom or the EEA. In certain cases, however, your personal data may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal data as set out in this Privacy Policy.

Where we transfer personal data outside the UK or the EEA, we may be required to take specific additional measures to safeguard the relevant personal data. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

Please contact us if you would like to see a copy of the specific safeguards applied to the export of your personal data.

Children’s Privacy

Our Services are not directed to children under the age of 16, and we do not knowingly collect personal information from children under the age of 16 on this Site. In addition, we do not sell any personal Information of minors under 16 years of age.

Cookies and Similar Technologies

We, our service providers, and our business partners may also collect certain information about the use of our Site by automated means, such as cookies, web beacons, HTML5 localStorage, and other technologies. We may also collect information about online activities over time and across third party websites.

The information that may be collected by automated means includes:

  • URLs that refer users to our Site
  • Search terms used to reach our Site
  • Details about the devices that are used to access our Site (such as IP address, browser type, operating system information, geolocation, and mobile device information)
  • Details about users’ interaction with our Site (such as the date, time, frequency, and length of visits, and specific pages accessed during the visits)

Because there is not yet a consensus on how companies should respond to web browser-based do-not-track (“DNT”) mechanisms, we do not respond to web browser-based DNT signals at this time.

Links to Other Websites and Third Party Content

We may link to other websites, services, and applications that are not operated or controlled by us (the “Third Party Services”). This Privacy Policy does not apply to such services. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content, privacy policies, or practices of those Third Party Services. We encourage you to review and understand the privacy practices of any Third Party Services before providing any information to or through them.  Your interactions with these features are governed by the privacy policy of the Third Party Service that provides the feature.

How We Protect Your Information

We maintain administrative, technical and physical safeguards designed to protect personal information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Changes to Our Privacy Policy:

We may update our Privacy Policy periodically.  If we do make changes, we will post those changes on this Policy and indicate at the top of this page the date this Privacy Policy was last revised. Any changes will be effective only after the effective date of the change.

Contact Us

If you have any questions about this Privacy Policy, please contact us at NTAnalyzer@nortonrosefulbright.com.