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Privacy notice

Effective: 1st October 2024

This Privacy Notice (“Notice”) explains how Nebula (“we”, “us”, “our”) collects, processes, uses, stores, and shares (“processing” or “process”) your personal information about your interaction with, access to, and use of the Nebula website and cloud service (“Nebula offerings”).

We value the safety of your privacy and personal information. We monitor the evolving privacy space and regularly update this Notice to reflect the necessary changes in accordance with the regulatory landscape and our commercial/compliance requirements. We may notify you of such updates by changing the effective date at the top of this Notice, placing a pop-up nudge on our home page, or sending email notices.

Personal data we collect

Personal Data/Information means any information relating to an identified or identifiable individual or information that can identify a person when combined with other data, including identifiers such as a name, an identification number, location data, photo, email address, posts on social networking websites, and other unique identifiers such as but not limited to Media Access Control (MAC) address, Internet Protocol (IP) address, International Mobile Equipment Identity (IMEI) number, International Mobile Subscriber Identity (IMSI) number, Subscriber Identification Module (SIM). Personal data shall include any online or device identifier or any one or more factors specific to the individual's physical, physiological, genetic, mental, economic, cultural, or social identity.

If you provide to us any personal data on behalf of an entity you represent or a third party such as an end-user, you represent and warrant that you have satisfied all legal pre-requisites including procuring the necessary consent/authorization before disclosing such personal data to us for our Processing.

We collect your data through our interactions with you and your interaction with the Nebula offerings for purposes outlined in this Notice. The data collected depends on the context of your interactions with us and the choices you make (including your privacy settings), the products and features you use, your location, and applicable law. This data may be collected through a variety of channels including when you provide the data directly, such as when you create or sign into a Nebula cloud account, administer your entity’s licensing account, register for or attend a Nebula event, upload a document on the Nebula console, or contact us for support; your data provided to us by selected third-parties such as data aggregators or third-parties who collect information about you.

Some of your data collected are as follows:

Automatic information including your network and connection information such as IP address or device information such as device location, browser, or application type; your content interaction information such as streams or content downloads or content you viewed, search or browser history, subscription data; your email addresses or phone numbers used in connection with your Nebula offerings; your setting preference and back up information.

Personal information such as your name, aliases, usernames, or other authentication information; email or physical address, phone number, or other contact information; your payment information or transactional data; your identification information such as government-issued or work identification; your image or location; corporate and financial information such as VAT or other unique identifiers.

For entities, entity name, location of company, the industry where entity operates and service/product offered by entity.

How we use your personal data

We collect and use your personal data for the following reasons including:

  • Provide, maintain, and improve our services
  • Product activation and performance evaluation
  • Provide personalized services and recommendations
  • Provide customer support
  • Compliance with legal obligations & industry standards
  • Research and product development
  • Marketing and promotional materials
  • Communication of information and notices
  • Systems security
  • In accordance with your instructions

Basis for processing your personal data

To process your personal information, Nebula relies on a variety of legal basis and permissions (“legal bases”) including compliance with applicable laws and regulations, with your consent, a necessity to perform contracts with you, balancing of legitimate interests, to protect your interests or the safety of others.

Scope of this privacy notice

This Notice shall apply to the processing of personal information by visitors to the Nebula website; all users (individual or entity) of Nebula offerings; subscribers to any publications including newsletters and marketing materials; suppliers, business partners and their representatives (collectively referred to as “you”, “your”).

This notice does not apply to:

  • Personal information provided on third-party websites or links. In the course of interacting with Nebula offerings, you may access third-party links or content hosted by Nebula’s customers using the Nebula offerings, or products/services offered through the Nebula offerings. Accessing or using these third-party resources may trigger the processing of your personal information over which Nebula has no control.
  • Personal information collected about or from you by Nebula’s customers: Nebula customers are responsible for their Processing of your personal information.

How we share your personal data

We value your personal information and will not share it except with your consent and at your direction or for the following reasons:

  • Internally with authorized personnel within Nebula or its current/future parents, subsidiaries, or any companies under common control or ownership (“Affiliates”) only to the extent necessary to enable them perform their functions in relation to the provision of services to you;
  • On a need-to-know basis in the event of a restructuring of Nebula including a merger, sale, or transfer of some or all of our assets or equity;
  • In compliance with legal obligations or a request from law enforcement or government authorities;
  • With essential third-party service providers such as auditors, lawyers, cloud hosting business partners essential for the provision of the services to you
  • To protect Nebula’s rights or safety or that of others

How we store and retain your personal data

Nebula stores information collected at licensed and secured locations in Nigeria. However, should the need to store your information outside Nigeria arise, we will ensure your information is transferred and stored only at licensed locations as permitted by this Notice and applicable data protection regulations.

Retention – Nebula shall not retain your personal data longer than it is necessary to fulfil our obligations or exercise our rights in relation to the services provided to you; or in accordance with your instructions or with applicable law. Where you no longer require the services or for other reasons, you may choose to close your account after which your personal information shall be deleted in line with our data retention policy as dictated by applicable law.

Your privacy rights

You have choices regarding the technology you use and the data you share. When we ask you to provide personal data, you can decline. Many of our products require some personal data to provide you with a service. If you choose not to provide the data required to provide you with a product or feature, you cannot use that product or feature. Likewise, where we need to collect personal data by law or to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or if this relates to an existing product you are using, we may have to suspend or cancel it. We will notify you if this is the case at the time. Where providing the data is optional, and you choose not to share personal data, features like personalization that use such data will not work for you.

  • Right to access the personal data we hold about you and obtain copies thereof;
  • Right to request us to update or correct your personal data;
  • Right to request us to erase your personal data;
  • Right to object to or restrict our processing of your personal data;
  • Right to obtain your personal data and have us transfer it to a third party of your choice (data portability);
  • Right to lodge a complaint with the competent data protection authority;
  • Right to withdraw consent previously provided for processing of information(opt-out).

Should you suspect a violation of your rights or require assistance with exercising the same, please contact us via: legal@usenebula.io

How we secure your data

Nebula uses various technical and organizational measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction inconsistent with your instructions, applicable data protection laws, guidelines, and security standards.

International transfer of your data

The information we collect about you may be transferred, used, or stored in any country where we operate or engage service providers. This means your information may be transferred to a country other than where it was collected, which may not provide data protection equivalent to Nigeria.

The level of Data protection in countries outside Nigeria may be less than that offered within Nigeria. Where this is the case, Nebula will implement appropriate measures to ensure that your personal information remains protected and secure in accordance with applicable data protection laws, guidelines, and standards in Nigeria at the least. Nebula shall strive to ensure that personal data is processed in line with standard data processing contracts in place between Nebula and all entities that share and process personal data.

Where our third-party service providers process personal data outside Nigeria in the course of providing services to us, our contracts with them will include appropriate measures, usually standard contractual clauses, on data sharing in accordance with prevailing local and international standards.