1. Introduction This Privacy Policy explains how Nialum LLC ("Nialum," "we," or "us") collects, uses, stores, and safeguards personal data processed through our digital platform, custom applications, and official website (www.nialum.com, collectively referred to as the "Platform"). Legal Framework: This policy complies with: • The General Data Protection Regulation (GDPR) in the European Economic Area (EEA). • Applicable privacy laws in the United States, including the California Consumer Privacy Act (CCPA) and other federal and state regulations. • Other data protection laws worldwide. Nialum LLC Information: • Legal Name: Nialum LLC • Address: 1209 Mountain Road Pl NE Ste N, Albuquerque, NM 87110, USA • EIN: 99-1967971 • Contact Email: dpdnialum@nialum.com • Website: www.nialum.com
2. Definitions • Personal Data: Information relating to an identified or identifiable individual (e.g., name, email address, IP address). • Data Subject: The individual whose data is being processed. • Controller: The entity determining the purposes and means of data processing (Contracting Entities). • Processor: Nialum, acting on behalf of Contracting Entities. • Third-Party Processors: Subcontractors providing auxiliary services under strict confidentiality agreements.
3. Data Categories We Collect Depending on user interaction with the Platform, we process the following categories of data: • Identification Data: Name, email address, phone number. • Technical Data: IP address, browser type, operating system. • Usage Data: Preferences, interactions, and activity logs. • Geographic Data: ZIP code, city, and country for use in interactive features (not real-time geolocation).
4. Purpose of Processing We process personal data for the following purposes: 1. Service Provision: Enable account creation, authentication, and service delivery. 2. Feature Enhancement: Improve Platform functionality and user experience. 3. Compliance: Fulfill contractual and legal obligations. 4. Analytics: Monitor usage trends and measure performance (aggregated and anonymized). 5. Legal Basis for Processing Our processing relies on these legal bases: 1. Contractual Necessity: Processing required to fulfill service agreements. 2. Consent: Voluntary opt-in for optional features (e.g., analytics, newsletters). 3. Legal Obligations: Data retention for regulatory compliance. 4. Legitimate Interests: Improvement of services and fraud prevention.
6. Data Retention We retain and delete data as follows: 1. Active Accounts: Personal data is stored for the duration of the account. 2. Post-Termination: Upon account termination, personal data will be permanently deleted within 30 days, unless: o Retention is required to fulfill legal obligations (e.g., tax or regulatory requirements). o Data must be retained to resolve disputes or enforce agreements. 3. Anonymization: Where deletion is not immediately possible, data is anonymized to prevent identification. Note: Users may request specific retention extensions for compliance or record-keeping purposes.
7. Data Recipients Personal data may be shared with: 1. Service Providers: For hosting, analytics, and operational support (e.g., AWS, Arsys). 2. Legal Authorities: In response to lawful requests or regulatory obligations. 3. Contracting Entities: Limited to fulfilling contractual obligations.
8. International Data Transfers We ensure adequate protection for cross-border data transfers by implementing: 1. Standard Contractual Clauses (SCCs): For transfers outside the EEA. 2. Data Privacy Frameworks: Adherence to frameworks like the EU-U.S. Data Privacy Framework. 3. Additional Safeguards: Encryption, pseudonymization, and strict access controls. Supplemental Terms for International Users: For users outside the European Economic Area (EEA) and the United States, Nialum processes personal data in accordance with the applicable laws of the user’s country. Where no specific law applies, Nialum adheres to the principles of the General Data Protection Regulation (GDPR) as a global standard for data protection. If your country has specific requirements that conflict with this Privacy Policy, these will take precedence to the extent necessary to comply with local regulations.
9. Security Measures Nialum implements rigorous technical and organizational measures, including: • Data Encryption: All data is encrypted using HTTPS protocols. • Access Controls: Restricted access to authorized personnel only. • Regular Backups: Redundant systems and offsite backups. • Incident Response: Robust protocols for handling data breaches, with notification within 72 hours as required under GDPR Article 33.
10. Data Subject Rights Under GDPR and U.S. privacy laws, users have the following rights: 1. Access: Request a copy of processed data. 2. Correction: Rectify incorrect or incomplete information. 3. Deletion: Request erasure of personal data ("right to be forgotten"). 4. Portability: Receive data in a machine-readable format. 5. Objection: Oppose certain processing activities. 6. Restriction: Temporarily halt processing in specific circumstances. 7. Consent Withdrawal: Revoke previously granted consent. How to Exercise Rights: Contact dpdnialum@nialum.com. Response times: • EEA Users: Within 30 days as per GDPR. • U.S. Residents: Within 45 days as per applicable laws, including CCPA. • International Users: Within the timeframe mandated by applicable local laws.
11. Subcontracting and Third-Party Processors We use verified processors under strict contractual terms. Subcontractors must comply with the same data protection obligations as Nialum.
12. Breach Notification Nialum notifies data breaches as follows: • EEA Users: Within 72 hours to supervisory authorities. • Affected Individuals: Prompt notification if risks to rights and freedoms are identified. 13. Special Categories of Data Nialum does not process sensitive data or data relating to minors. Our services are strictly for adults who are alumni of Contracting Entities.
14. Cookies and Tracking Refer to our Cookie Policy for details on tracking technologies and user control mechanisms.
15. Modifications Nialum reserves the right to update this policy in line with changes to legal or operational requirements. Users will be notified of material changes.
16. Contact For inquiries or complaints, contact: • Email: dpdnialum@nialum.com • Address: 1209 Mountain Road Pl NE Ste N, Albuquerque, NM 87110, USA