Nuvola Privacy Policy
Last updated May 2022
References in this Privacy Policy to “GDPR” are to EU GDPR 2016/679 and the UK implementation of EU GDPR 2016/679 on the UK’s exit from the European Union.
About us
This Privacy Policy is issued by Nuvola (“we,” “us,” “our” or “Nuvola”).
Your information
Your privacy is important to us, and we respect the privacy rights of our clients and the importance of protecting the information collected about you and compliance with legal requirements. This Privacy Policy sets out the basis on which any personal information (including any information from which we can identify you or in which you are identified) we collect from you, or that you provide to us, will be collected, used, disclosed, retained and be protected by us and applies to personal information collected when you use or access our website (www.mynuvola.com) or otherwise interact with us. This Privacy Policy may be relevant even if you are not a customer of ours and have never used the website or service of ours. We may have your personal information because we have received it from an end-user, application, or service of ours. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it. This statement also describes your choices regarding use, access, and correction (including deletion and retention) of your personal information. By providing personal information to us, you are accepting and consenting to the practices described in this statement.
This Privacy Policy only covers this website and your interactions directly with Nuvola. We are not responsible for the data policies or procedures or content of any other linked websites. We recommend that you check the privacy and security policies of each website you visit.
If you do not agree with the data practices described in this Privacy Policy, then you should not use the Nuvola website or services.
Information we collect
We will collect certain information (including personal information) relevant to the services we provide. The types of information we may collect directly from you include your name, telephone number, email address, postal address, transactional information (including services purchased and your billing address), information collected by cookies (if applicable and subject to applicable consent requirements), and any other information you may choose to provide. Please be aware that the information that you choose to provide may reveal or identify information that is not expressly stated (e.g., if you choose to provide your picture, your picture may reveal your gender). We may also store files and other information that you may upload or provide to us in order to be able to provide you with the features of the services we may offer.
We may also collect the following information each time you visit our website, in order to help us understand how to improve our service offering, our website and to ensure the content is presented to you in an effective manner:
- technical information, including the Internet protocol (IP) address used to connect your computer or mobile device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- subject to applicable consent requirements, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), services 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) and methods used to browse away from the page (see our Cookie section for more information), and any phone number used to call our office number;
- marketing information including marketing preferences, marketing list assignment, records of permission or marketing objections.
This Privacy Policy applies to all personal information collected or submitted to us over the phone when you visit us at our offices or via our website and your personal information that we process about you in the course of our business. On some pages, you may be able to order products, make requests, and register to receive materials. You can unsubscribe from marketing communications through the link included in these communications.
Providing us with information about others
If you provide us with personal information about someone else, you are responsible for ensuring that you comply with any obligation and consent obligations under applicable data protection laws in relation to such disclosure. In so far as required by applicable data protection laws, you must ensure that you have provided the required notices and have obtained the individual’s explicit consent or otherwise have a legal basis to provide us with the information and that you explain to them how we collect, use, disclose and retain their personal information or direct them to read our Privacy Policy.
How we use your information
We may use the information we collect from you when you register via our website or contact us directly for the limited purpose of providing our services to you and as permitted by applicable laws and set-out in this Privacy Policy, including the following:
- to carry out our obligations arising from any contracts entered into between us and to provide you with the information, products, and services you request from us;
- to provide, maintain and improve the services we offer;
- to improve our website in order to better serve you;
- to respond to comments, questions, and requests and provide support where requested;
- to communicate with you about services, newsletters, events and provide other news or information about us;
- monitor and analyze trends, usage, and activities in connection with the services we provide and for marketing and advertising purposes;
- investigate and prevent fraudulent transactions, unauthorized access to our services and other illegal activities;
- to notify you of any changes to our services;
- to administer our site and for internal operations, including data analysis, troubleshooting, testing, research, surveys;
- for other purposes, about which we notify you.
We have to establish a legal ground to use your personal data, so we will make sure that we only use your personal data for the purposes below:
- we have your explicit consent for the processing (where no other processing ground applies); or
- our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you (e.g., to fulfil obligations under the contract signed between you and us), or
- our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we are subject to, or
- our use of your personal information is necessary to support ‘legitimate interests’ that we have as a business (for example, to improve our services, or to carry out analytics across our datasets or for the purposes of investigations, complying with regulatory or governmental requests for information and/or for dispute management purposes) or your legitimate interests, provided it is carried out in a way that is proportionate, and that respects your privacy rights.
Who do we share your information with?
We may share your information with third parties to help manage our business and deliver services. These third parties may, from time to time, need to have access to your personal data. These third parties may include:
- Service providers, who perform functions on our behalf such as fulfilling orders, delivering packages, sending postal mail and email, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), providing customer services and providing maintenance or any other services related to our services. If you share your information through our website or devices with a third-party account such as Facebook, Google, and/or Twitter, your personal data will be managed respectively by one of those third parties. You should also note that we use the distributor (their platforms may be directly accessible via our website) for the online sale of goods and services. You are responsible for reviewing such third party’s Privacy Policy, as their data processing will not be covered by this Privacy Policy;
- Other third parties, for the purposes of detecting, preventing or otherwise addressing fraud, security or technical issues, protecting against harm to the rights, property or safety of our users or the public;
- Legal advisors, financial and tax advisors and other professional services firms (including our auditors).
Also, if we were to sell all or part of our businesses, we would need to share and/or transfer your personal information to the purchaser/prospective purchasers and relevant advisors. We may need to share your personal information with third-parties and advisors for these purposes. If your personal information is transferred across borders, we will comply with applicable transfer requirements.
Information security
The security of your information is very important to us, and we endeavour to prevent unauthorized access, maintain data accuracy, and ensure the correct use of information. Therefore, we have put in place appropriate physical, electronic, and managerial procedures that are designed to safeguard and secure the information we collect from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. Even though we follow reasonable procedures to try to protect the information in our possession, no security system is perfect and we cannot promise, and you should not expect, that your information will be secure in all circumstances.
In the event that your personal information is acquired, or reasonably believed to have been acquired by an unauthorized person and applicable law requires notification, we will notify you by email or mail. We will give you prompt notice, consistent with the reasonable requirements of the law, and we will investigate to determine the scope of the breach and restore the integrity of the data system.
Transfers
Nuvola is based in the US and Colombia. We may transfer your personal information to entities and service providers that are located in the US and other locations. . We may also share your personal information s, for example, if we receive a legal or regulatory request from a foreign law enforcement body. We will take steps to ensure that any international transfer of information is carefully managed to protect your rights and interests:
- we will only transfer your personal information to countries which are recognized as providing an adequate level of legal protection; or
- service providers and other third-parties will be required to execute contractual transfer agreements, such as the approved transfer agreements.
You have the right to ask us for more information about the safeguards we have put in place, as mentioned above. Please contact us as set out in section at the end of this Privacy Policy if you would like further information.
Cookies
Our website may use “cookies” to enhance your experience. Subject to applicable consent requirements for non-essential cookies, our web browser places cookies on your hard drive for record-keeping purposes and sometimes to track information about you. If you have provided consent, you may choose to set your web browser to refuse cookies or to alert you when cookies are being sent. If you do, please note that some parts of our website may not function properly. Note that browser-management tools for cookies are outside of our control and we cannot guarantee their effectiveness.
We use the following cookies:
| Provider | Name of cookie | Duration | Category | Purpose |
| LinkedIn (.ads.linkedin.com) | lang | Session | Functional | Remembers the user’s selected language version of a website |
| Set by LinkedIn when a web page contains an embedded “Fllow us” panel | ||||
| .adsymptotic.com | U | 3 months | ||
| Facebook (.facebook.com) | fr | 3 months | ||
| Google (.google.com) | AEC | 5 months | Analytical | Google Analytics is a web analytics service provided by Google, Inc. Google Analytics helps evaluate your use of our websites and compiles reports for us on activity on our websites. |
| Google (.google.com) | NID | 6 months | Analytical | Google Analytics is a web analytics service provided by Google, Inc. Google Analytics helps evaluate your use of our websites and compiles reports for us on activity on our websites. |
| Google (.google.com) | 1P_JAR | 1 month | Analytical | Google Analytics is a web analytics service provided by Google, Inc. Google Analytics helps evaluate your use of our websites and compiles reports for us on activity on our websites. |
| LinkedIn (.linkedin.com) | lang | Session | Functional | |
| LinkedIn (.linkedin.com) | AnalyticsSyncHistory | 29 days | Analytical | Used in connection with data-synchronization with third-party analysis service |
| LinkedIn (.linkedin.com) | UserMatchHistory | 29 days | Essential | Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor |
| LinkedIn (.linkedin.com) | lidc | 1 day | Analytical | Used by the social networking service, LinkedIn, for tracking the use of embedded services |
| LinkedIn (.linkedin.com) | li_sugr | 3 months | ||
| LinkedIn (.linkedin.com) | bcookie | 2 years | Analytical | Used by the social networking service, LinkedIn, for tracking the use of embedded services |
| Nuvola (.mynuvola.com) | _gid | 1 day | Analytical | Registers a unique ID that is used to generate statistical data on how the visitor uses the website |
| Nuvola (.mynuvola.com) | _gat_gtag_UA_46641392_1 | 6 hours | Analytical | This third-party Google Analytics cookie is used by Google to monitor requests rate toward their servers. |
| This cookie helps Nuvola to identify application areas to be improved. | ||||
| Nuvola (.mynuvola.com) | _fbp | 3 months | Advertising | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers |
| Nuvola (.mynuvola.com) | _ga | 2 year | Analytical | Registers a unique ID that is used to generate statistical data on how the visitor uses the website |
| Youtube (.youtube.com) | SAPISID | 1 year | ||
| Youtube (.youtube.com) | __Secure-3PSID | 1 year | ||
| Youtube (.youtube.com) | HSID | 1 year | ||
| Youtube (.youtube.com) | VISITOR_INFO1_LIVE | 179 days | Functional | Tries to estimate the users’ bandwidth on pages with integrated YouTube videos |
| Youtube (.youtube.com) | __Secure-3PAPISID | 1 year | ||
| Youtube (.youtube.com) | __Secure-1PAPISID | 1 year | ||
| Youtube (.youtube.com) | APISID | 1 year | ||
| Youtube (.youtube.com) | SSID | 1 year | ||
| Youtube (.youtube.com) | SID | 1 year | ||
| Youtube (.youtube.com) | __Secure-1PSID | 1 year | ||
| Youtube (.youtube.com) | YSC | Session | Analytical | Registers a unique ID to keep statistics of what videos from YouTube the user has seen |
| Nuvola (www.mynuvola.com) | catAccCookies | 1 month | ||
| LinkedIn (.linkedin.com) | li_gc | 2 years | Essential | Stores the user’s cookie consent state for the current domain |
| Google (.google.com) | rc::a | Persistent | This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website | |
| Google (.google.com) | rc::c | Session | This cookie is used to distinguish between humans and bots. | |
| Nuvola (www.mynuvola.com) | plyr | Persistent | Essential | Necessary for the implementation of video-content on the website |
| Nuvola (www.mynuvola.com) | _gat | 1 day | Analytical | Used by Google Analytics to throttle request rate |
| Google (.google.com) | ads/ga-audiences | Session | Analytical | Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites |
| LinkedIn (.linkedin.com) | bscookie | 2 years | Analytical | Used by the social networking service, LinkedIn, for tracking the use of embedded services |
| Facebook (.facebook.com) | tr | Session | Advertising | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers |
| Youtube (.youtube.com) | ytidb::LAST_RESULT_ENTRY_KEY | Persistent | Functional | Stores the user’s video player preferences using embedded YouTube video |
Your information and your rights
If you are based within the UK, EEA or another jurisdiction having similar data protection laws, in certain circumstances, you have the following rights:
- the right to be told how we use your information and obtain access to your information;
- the right to have your information rectified or erased or place restrictions on processing your information;
- the right to object to the processing of your information e.g., for direct marketing purposes or where the processing is based on our legitimate interests;
- the right to have any information you provided to us on an automated basis returned to you in a structured, commonly used and machine-readable format, or sent directly to another company, where technically feasible (“data portability”);
- where the processing of your information is based on your consent, the right to withdraw that consent subject to legal or contractual restrictions;
- the right to object to any decisions based on the automated processing of your personal data, including profiling; and
- the right to lodge a complaint with the supervisory authority responsible for data protection matters (e.g., in the UK, the Information Commissioner’s Office).
If we hold any information about you, which is incorrect, or if there are any changes to your details, please let us know by so that we can keep our records accurate and up to date.
If you withdraw your consent to the use of your personal information for purposes set out in our Privacy Notice, we may not be able to provide you with access to all or parts of our website, applications, and services.
We will retain your personal information for the duration of our business relationship and afterward, for as long as it is necessary and relevant for our legitimate business purposes, in accordance with the Sage Group Data Retention, Marking and Destruction Policy, or as otherwise permitted by applicable laws and regulations. Where we no longer need your personal information, we will dispose of it in a secure manner (without further notice to you).
Compelled disclosure
We reserve the right to use or disclose your personal information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with the law, court order, or legal process.
Retention of personal information
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided in agreements between you and Nuvola or as required or authorized by law. Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made de-identified.
Children
The website and Nuvola’s services are not directed to children, nor do we knowingly collect any personal information from children under the age of thirteen without verifiable parental consent. If you believe that a child has provided personal information to us, please contact us promptly as described below, and we will endeavor to investigate and delete such information from our systems.
Third-party websites
The website may contain links to third-party websites, such as social media sites like Facebook and Twitter, which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any external site before disclosing any personal information. Please contact those websites directly if you have any questions about their privacy policies.
How to contact us
Should you have other questions or concerns about these privacy policies, please email Privacy@sabre.com.
Policy updates
We may update this Privacy Policy from time to time. In the event we make any material changes that reduce your rights or our obligations under this Privacy Policy, we will post a prominent notice in this section of the Privacy Policy and on our website notifying you of the updates.