Updated: January 28, 2021
Nudj is the name with which Base6 Services Ltd. does business.
Base6 Services Ltd. (“Nudj“, “we“, “our” or “us“) develops and operates a community management platform (the “Platform“), used by various organizations, businesses and community organizers to manage and engage with members of their communities (“Communities“).
We also maintain and operate the website https://nudj.app, its subdomains and its related features, such as blogs and newsletters (collectively, the “Site“) as well as the Nudj mobile application (the “App“), and access to the Platform is made possible through both (the Platform, together with the Site and App – the “Services“).
This Privacy Notice describes the personal data we typically receive or collect whenever someone visits our Site or installs and opens our App (a “Visitor“), creates (“Owner“), manages (“Manager”) or joins (“Member“) a Community, or uses the Platform and engages with other Members of the Community via the various communication features available via the Services. It also describes how and for which purposes we may use such data, where we store and for how long we retain it, with whom we may share it, our use of tracking technologies and communications, our security practices, your choices and rights (whether you are an Owner, Manager, Member or Visitor, “you“) regarding such data, our roles as “Data Controller” and “Data Processor”, and how to contact us if you have any concerns regarding this Notice or your Privacy.
We strongly urge you to read this Notice and make sure that you fully understand and agree to it. If you do not agree to this Notice, please discontinue and avoid using our Services.
You are not legally required to provide us with any Personal Data, but without it we will not be able to provide you with the full range or with the best experience when using our Services.
We collect data regarding users of our platform, as well as visitors to our site and app.
Such data is typically collected and generated through your interaction with our services, through automatic means or directly from you or your community owner or manager.
We collect two main categories of data (which, to the extent it may enable the identification of a specific person, or is linked to such identifying data, we will deem it as “**Personal Data**“:
Data automatically collected or generated: when someone visits, interacts with or uses our Services, including any e-mail or text messages sent to them via our Services, we may collect certain technical data about them. We collect or generate such data either independently or with the help of third-party services (as detailed in Section 4 below), including through the use of “cookies” and other tracking technologies (as further detailed in Section 5 below). Such data mainly consists of technical and aggregated usage data, such as IP address, non-identifying data regarding a device, operating system and browser, and user activity on our Services. It does not enable us to learn a person’s true identity or contact details and serves mostly so we could better understand how our users typically use our Services and how we could improve their user experience, our marketing campaigns and engagements, and the overall performance of our Services.
Data received from you: you may provide us Personal Data when you create your account and Community user profile (as an Owner, Manager or Member), such as your name, workplace or community role, contact details (such as e-mail, phone and address), profile image, location, gender, account login details (such as usernames and hashed passwords) (collectively, “Account Data”), as well as any other data you choose to provide when you visit our Services, post and share content with your Community or other Managers or Members, or when you contact us. Owners may also provide us additional Account Data in order to complete their selected transaction (such as their credit card number and related account and billing information, which we may update from time to time should you grant us permission to bill you for recurring charges), as well as their Community’s information and preferences. To the extent that such information concerns a non-human entity (e.g., a company or business), we do not regard it as “Personal Data” and this Notice shall not apply to it. As the Platform enables Owners and Managers to require or ask their Members to submit additional Personal Data, and as Owners, Managers and Members may choose to submit additional Personal Data and share it with their Community or certain other Members, the list above is not exhaustive. We will, however, indicate on the Platform, for each Personal Data parameter, if it is “required” or “optional” for either the adequate performance of our Services or per the Community Owner’s or Manager ’s requirements.
Member Data received from Community Owners and Managers: Community Owners and Managers may use the Platform to add and invite Members to their Community. When doing so, they may already submit such Members’ Personal Data as listed in paragraph 2 above, in whole or in part. Any Community Owner and Manager doing so are solely responsible to ensure the legal basis and authority for processing such Personal Data, its accuracy and completeness, and for providing sufficient notice and choice to their Members regarding the use of their data. The Community Owner is the “Data Controller” of such data, and Nudj solely acts as their “Data Processor” (as such roles are further explained in Section 9 below).
Using Personal Data
We use personal data in order to provide our services and make them better and safer; in accordance with our contractual obligations towards community owners; to contact our visitors and users, and in order to comply with applicable laws.
We collect and use Personal Data for the following purposes, in order to facilitate and perform our engagements with our users, in order to comply with the laws applicable to us, and based on our legitimate interests for maintaining and improving our Services and protecting and securing our Services, ourselves and our users:
To facilitate, operate, and provide our Services;
To authenticate the identity of our Owners and their Managers and Members, and allow them access to our Services;
To provide our Owners and their Managers and Members with assistance and technical support;
To further develop, customize and improve the Services and your user experience, based on common or personal preferences, experiences and difficulties;
To contact our Visitors, our Owners and their Managers and Members, with general or personalized service-related messages (such as password-retrieval or billing);to contact our Visitors, Owners and Managers with promotional messages (such as newsletters, webinars, new features etc.); and to facilitate, sponsor and offer certain events and promotions;
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
To create aggregated statistical data, inferred non-personal data or anonymized or pseudonymized data (rendered non-personal), which we or our business partners may use to provide and improve our respective services; and
To comply with any applicable laws and regulations.
Storing and Retaining Personal Data
Owner, Manager, Member and Visitor Data Retention: We retain Owner Personal Data, Manager Personal Data, Member Personal Data (to the extent that we are the “Data Controller” of such data, as explained in Section 9 below) and Visitor Personal Data as reasonably necessary to preserve and expand our mutual relationship, and thereafter in accordance with our Data Retention Policy.
Member Data Retention: We retain Member Personal Data (to the extent that we are the “Data Processor” of such Member data, as explained in Section 9 below) as instructed or authorized by the Owner, and thereafter in accordance with our Data Retention Policy.
If you have any questions about our Data Retention Policy.
Sharing Personal Data
We may share your data with certain third parties, including certain service providers, law enforcement agencies and our affiliated companies – but only in accordance with this notice.
Sharing Personal Data with Owners, Managers and Members of your Community: Once you join a Community, your user profile will be made available to all Owners and their appointed Managers of such Community. All or part of your user profile may also be made available to other Members of a Community you join, according to the discretion of the Owners and Managers of that Community. Please note that Nudj is not responsible or controls any further disclosure, use or monitoring by or on behalf of your Community Owners, Managers or Members.
Compliance with Laws, Legal Process and Authorities: We may disclose or allow government and law enforcement officials access to certain Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, including for national security purposes. Such disclosure or access may occur with or without notice to you if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.
Service Providers: We may engage selected third party companies and individuals to perform services complementary to our own (e.g. hosting and server co-location services, data analytics services, marketing agencies and advertising services, data and cybersecurity services, fraud detection and prevention services, payment processing services, user engagement services, e-mail distribution and monitoring services, session recording, remote access services, and our business, legal, financial and privacy advisors) (collectively, “Service Providers“). These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such purposes. Nudj remains responsible and liable for any Personal Data processing done by Service Providers on its behalf, other than for events outside of its reasonable control.
Third Party Integrations: The Services may allow you to integrate with certain third-party services, in which case you will be bound by the terms of service and privacy notices of said third parties – so please make sure you read and accept them. We do not receive or store your passwords for any of these third-party services.
Protecting Rights and Safety: We may share your Personal Data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Nudj, any of our users or any members of the general public.
Nudj Subsidiaries and Affiliated Companies: We may share Personal Data internally within our family of companies, for the purposes described in this Notice. In addition, should Nudj or any of its affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your Personal Data may be shared with the parties involved in such event. If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or a prominent notice on our Services.
For the removal of doubt, Nudj may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data in our sole discretion and without the need for further approval.
Using Cookies and Tracking Technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies which help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns. A “cookie” is a small text file that is used, for example, to collect data about activity on our Site. Some cookies and other technologies serve to recall Personal Data, such as an IP address, previously indicated by the user. While we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, most browsers allow you to control cookies, including whether or not to accept them and to remove them. You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.
Nudj uses certain monitoring and tracking technologies, such as cookies, beacons, pixels, tags and scripts (collectively, “Cookies”). These technologies are used in order to maintain, provide and improve our website and services, and in order to provide our users with a better experience (for instance in order to track users’ preferences, to better secure our services, to identify technical issues and to monitor and improve the overall performance of our services).
What are Cookies?
Cookies are small text files that are stored by the browser (for example, Google Chrome or Safari) on your computer or mobile device. They allow websites to store things like user preferences. You can think of Cookies as providing a ‘memory’ for the website so that it can recognize you when you come back and respond appropriately.
Performance Cookies: This type of cookie remembers your preferences for tools found on the services, so you don’t have to re-set them each time you visit.
Analytics Cookies: Every time someone visits our services, analytics services we use generate Cookies which can tell us whether or not you have visited the services in the past, and provide additional information regarding how our users use our services (such as regarding where users tend to click on our services). Your browser will tell us if you have these Cookies and, if you don’t, we generate new ones. This allows us to track how many individual users we have and how often they visit the services. Unless you are signed in to our services, we cannot use these Cookies to identify individuals. We use them to gather statistics. For example, the number of visits to a page.
Registration Cookies: When you register and sign in to our Services, we generate Cookies that let us know whether you are signed in or not. Our servers use these Cookies to work out which account you are signed in with and if you are allowed to access to a particular service. While you are signed in to our services, we combine information from your registration Cookies with analytics Cookies, which we could use to identify which pages you have seen.
Third Party Integration Cookies: On some pages of our services, other organizations may also set their own cookies. They do this to track the performance of their applications that are integrated with our services, or to customize their services for you. Because of how cookies work, our website cannot access these cookies, nor can the other organization access the data in cookies we use on our services.
Cookies Source Description
Nudj.app Performance & Registration
Google Analytics Analytics
Google Doubleclick Advertising
How do I turn Cookies off?
All modern browsers allow you to change your cookie settings. You can usually find these settings in the ‘Options’ or ‘Preferences’ menu of your browser. In order to understand these settings, the following links may be helpful, or you can use the Help option in your browser for more details.
If you are primarily concerned about third party cookies generated by advertisers, and you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users) or www.yourchoicesonline.com (for European users).
If you like to find out more about cookies and their use on the Internet, you may find the following websites useful:
Some web browsers may transmit Do Not Track signals to websites with which the browser communicates, telling the site not to follow its online movements. Because of differences in how web browsers interpret this feature, it is not always clear whether Users intend for these signals to be transmitted, or whether they are even aware of them. Therefore, we currently do not respond to such Do Not Track signals.
We or our partners may send promotional communications, that you can easily opt-out of receiving. We may also contact you with service-related communications. You will not be able to opt-out of receiving such communications.
Service Communications: we may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service changes, password-retrieval notices, etc. You will not be able to opt-out of receiving such service communications.
Promotional Communications: we may also send notifications about new services, events and special opportunities or any other information we think our Owners and Managers will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Services, or through our marketing campaigns on any other sites or platforms.
Securing Personal Data
We are committed to securing your personal data and use many security measures to better protect it. However, as we can’t guarantee absolute protection, we encourage you to be aware of the risk when using the services or providing us with your personal data.
In order to protect your Personal Data held with us and our Service Providers, we are using industry-standard physical, procedural and electronic security measures. However, please be aware that regardless of the security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 4 above.
EU and UK Residents
If you are a resident of the European Union (“EU”), United Kingdom, Lichtenstein, Norway, or Iceland, you may have additional rights under the EU General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.
For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. Nudj will be the controller of your Personal Data processed in connection with the Services.
If there are any conflicts between this section and any other provision of this Privacy Notice, the policy or portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following applies to you, please contact us.. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.
Exercising Your Data Subject Rights
You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need to you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.
Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data. You can also access certain of your Personal Data by contacting us at privacy@Nudj.io.
Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. You can correct some of this information directly by contacting us at privacy@Nudj.io.
Erasure: You can request that we erase some or all of your Personal Data from our systems.
Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
Right to File Complaint: You have the right to lodge a complaint about Nudj’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.
Data Controller and Data Processor
Certain data protection laws and regulations, such as the EU GDPR, typically distinguish between two main roles for parties processing Personal Data: the “Data Controller”, who determines the purposes and means of processing, and the “Data Processor”, who processes the data on behalf of the Data Controller. Below we explain how these roles apply to our Services, to the extent that such laws and regulations apply.
Each Community Owner is the “Data Controller” of their Managers’ and Members’ Personal Data (excluding Account Data), when Nudj processes such data solely on such Owner’s behalf. This means that in such cases, we will only process such Member’s data in accordance with the reasonable instructions of the Owner, subject to our Terms of Service, and strictly on their behalf. The Owner will be solely responsible for meeting any legal requirements applicable to Data Controllers (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
Nudj is the “Data Controller” of the Account Data of its Owners, Managers and Visitors, and also of certain Member Personal Data, when it processes such data for its own purposes. This means that when processing is performed for Nudj’s purposes (as set forth under this Notice), namely Personal Data which pertains to Owners and Visitors, and Member Personal Data which relevant to their overall use of our Services, then Nudj will control such data, and assume the responsibilities of Data Controller (solely to the extent applicable under law).
Transfers of Personal Data
The Services are hosted and operated in Canada through Nudj and its service providers, and if you do not reside in Canada, laws in Canada may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Nudj in Canada. and will be hosted on servers in Canada, and you authorize Nudj to transfer, store and process your information to and in Canada. You hereby consent to the transfer of your data to Canada pursuant to another safeguard(s) for cross-border transfer: (i) a data processing agreement incorporating standard data protection clauses promulgated by the EC, a copy of which can be obtained at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.
Nudj’s Customers may electronically submit data or information to the Nudj Platform for hosting and processing purposes (“Customer Data”). Nudj will not review, share, distribute, or reference any such Customer Data except as provided in an applicable Master Subscription Agreement, Statement of Work, or as may be required by law. Nudj may access Customer Data only for the purpose of providing the services or preventing or addressing service or technical problems, or as may be required by law.
Correcting and updating your information
Nudj may retain your information for a period of time consistent with the original purpose of collection (for instance, we may retain your information for during the time in which you have an active Nudj account), and for a reasonable period of time afterward. We also may retain your information during the period of time needed for Nudj to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
You may request to review, correct, delete or otherwise modify any of the personal information that you have previously provided to us through the Nudj website or the Nudj Platform. Requests to access, change, or delete your information will be addressed within the legally permissible timeframe.
Nudj has relationships with several subprocessors to deliver its services. Our list of current subprocessors includes:
Google (for Google maps)
Updates and amendments: We may update and amend this Notice from time to time by posting an amended version on our Services. The amended version will be effective as of the published effective date. We will provide a 10-days’ prior notice if any substantial changes are involved, via any of the communication means available to us, or on the Services. After this notice period, all amendments shall be deemed accepted by you.
External links: While our Services may contain links to other websites or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services and to read the privacy notices of each and every website and service you visit. This Notice applies only to our Services.
Children’s Privacy: Our Services are not designated to attract children under the age of 16. We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a child is using the Services, we will prohibit and block such use and will make all efforts to promptly delete any Personal Data stored with us with regard to such child.
Questions, Concerns or Complaints: If you have any comments or questions about this Privacy Notice or if you have any concerns regarding your Privacy, please contact us at firstname.lastname@example.org. Nudj’s appointed Data Protection Officer may be reached at email@example.com