Natural Insight, Ni Reveal and Capango are interactive services that can be accessed via the Web, Ni WorkTrak or Capango mobile applications, phone and through transaction gateways (together, the “Services”). The services are provided under their respective brand names provided by South49 Solutions, Inc. a Delaware corporation. For the purpose of applicable data protection legislation and subject to the following sentence, the data controller of your personal data is South49 Solutions, Inc. located at 46040 Center Oak Plaza, Suite 160, Sterling, VA 20166-6595 www.south49.com
Information We Collect
General. When you register as a User of the Services (each, a “User”) and at other times, we will collect personally identifiable information from you. The personally identifiable information we collect includes limited personal data such as name, address, phone number and email address. We ask that you not send us, and you do not disclose, any sensitive personal data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us.
Usage Information. Our web services, mobile applications and phone servers automatically collect usage information when you visit our Services. Website usage information is information about our visitors (unregistered users of the Services) and Users that describes how our Services is used and navigated, including the number and frequency of visitors and Users to each web page and the length of their stays. Website usage information also includes the domain names and/or corresponding IP addresses (a numerical identifier for a computer on the Internet) of those who visit our website. Mobile application usage information includes location services data (when authorized on the phone) and photo metadata information (when authorized on the phone). Finally, phone usage information may include caller ID results depending on your local phone company’s ability to transmit that information. To disable caller ID transmissions, please contact your local phone company.
Device and Connection Information. We collect information about your computer, phone, tablet, or other devices you use to access the Services. This device information includes your connection type and settings when you install, access, update, or use our Services. We also collect information through your device about your operating system, browser type, IP address, URLs of referring/exit pages, device identifiers, and crash data. We use your IP address and/or country preference in order to approximate your location to provide you with a better Services experience. How much of this information we collect depends on the type and settings of the device you use to access the Services.
The personally identifiable information we collect about you is stored in limited access servers. We will maintain appropriate safeguards to protect the security, integrity, and privacy of these servers and of your personally identifiable information. Except as described below, we will not use or intentionally disclose any personally identifiable information about you to any unaffiliated third parties without your consent.
How We Use Information Collected
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide you with access to the Services. If you registered with us, you would have been asked to check a box indicating your agreement to provide this data in order to access our Services or view our content. This consent provides us with the legal basis we require under applicable law to process your data. You maintain the right to withdraw such consent at any time. If you do not agree to our use of your personal data in line with this policy, please do not use our website. When fulfilling our contractual obligations to our customers (i.e., the data controllers), we have a legitimate interest in processing certain personal data for such contractual purposes.
We may combine the personally identifiable information we collect from you when you use the Services with other information about you that is available to us, including survey information, affiliate and third-party website usage information and information from other sources. We may use such information in several ways, including:
To provide you with the goods and services you have requested, and for the purposes disclosed when you provide the personally identifiable information.
To send Users email notifications of new Services features and topic-based news alerts if they have signed up for these announcements.
To provide you with personalized content.
To give South49 Solutions editors information that is useful for developing new features and services that meet Users’ needs.
To improve the content and navigation on our Services.
To alert you about new products and services and special offers.
We may also share such information with our affiliates and other third parties to provide you with goods or services requested by you. However, any party that receives your information for this purpose will be prohibited from using it for any means other than those necessary to facilitate your transaction with South49 Solutions unless you agree that the party may make other uses of your information.
Customer support. We use your information to resolve technical issues you encounter, to respond to your requests for assistance, to analyze crash information, and to repair and improve the Services.
With your consent. We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
Automated decision making. We may use automated decision-making and/or profiling in regard to your personal data for some services and products. For example when calculating a Ni Score for a user which uses login, scheduling, reporting and work execution information to determine a User rating an employer may consider when offering work assignments. You can request a manual review of the accuracy of an automated decision that you are unhappy with or limit or object to such automated decision-making and/or profiling by contacting us at [email protected] .
Your rights in your data
Opt Out. You can notify us if you do not wish to receive information about new products and services and special offers by opting out at the time you enter your personally identifiable information on the NaturalInsight.com website or by emailing us at [email protected].
Opt In. Several of the services we provide, including many of the email notifications and the surveys we conduct, are entirely voluntary. You will not receive such services unless you opt in, i.e., unless you expressly choose to receive these services.
Access. You may access the data we hold about you at any time via your profile/account, by contacting your employer if they have provided you with our services, or by contacting us directly.
Amend. You can also contact us to update or correct any inaccuracies in your personal data.
Erase and forget. In certain situations, for example when the data we hold about you is no longer relevant or is incorrect, you can request that we erase your data.
We employ cookie technology to help visitors and Users move faster through the website portion of the Services. When a visitor or User accesses a South49 Solutions website and takes advantage of certain features, we place several cookies on that User’s computer. A cookie is a string of information sent by a website and stored on your hard drive or temporarily in your computer’s memory. This allows the website to recognize you as you move through the website without having to keep asking you for your username and password.
|Type of cookies||Purpose|
|Essential Cookies||These cookies are essential to provide you with services available through our website and to enable you to use some of its features. For example, they allow us to retain your secure connection to our servers as you interact with our site. Without these cookies, the services that you have asked for cannot be provided, and we only use these cookies to provide you with those services.|
|Functionality Cookies||These cookies allow our website to remember choices you make when you use our website, such as remembering your language preferences and remembering the changes you make to other parts of our website which you can customize. The purpose of these cookies is to provide you with a more personal experience and to avoid you having to re-enter your preferences every time you visit our website.|
|Analytics and Performance Cookies||These cookies are used to collect information about traffic to our website. The information gathered does not identify any individual visitor. The information is aggregated and anonymous. We use this information to help operate our website more efficiently, to gather broad demographic information and to monitor the level of activity on our website.
We use Google Analytics and other third party analytics services for this purpose. Google Analytics uses its own cookies. It is only used to improve how our website works. You can find out more information about Google Analytics cookies here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies. You can find out more about how Google protects your data here: www.google.com/analytics/learn/privacy.html.
You can prevent the use of Google Analytics relating to your use of our website by downloading and installing the browser plugin available via this link: https://tools.google.com/dlpage/gaoptout
|Social Media Cookies||These cookies are used when you share information using a social media sharing button or “like” button on our website or you link your account or engage with our content on or through a social networking website such as Facebook, Twitter, or Google+. The social network will record that you have done this.|
Review and Correction
You may review and update the personal information you provide us as part of the registration process, or unsubscribe from the Services, by accessing your Profile or calling us directly at (800) 961-5203 or if you are outside the US, +1 703 852 2109.
How we store and secure information we collect.
Transfer of information
Your data, including personal data that we collect from you, may be transferred to, stored at, and processed by us outside the country in which you reside, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By using our website and services, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this policy.
Information storage and security
We use a third-party data hosting service provider in the United States and Germany to process and host the information we collect, and we use technical measures to secure your data.
While we implement safeguards designed to protect your information, no security system is impenetrable and due to the inherent nature of the Internet, we cannot guarantee that data, during transmission through the Internet or while stored on our systems or otherwise in our care, is absolutely safe from intrusion by others.
Do we share your personal information with others?
Other than our third-party data hosting services provider, who acts only as a contracted processor for us, we do not share your personal information with any of our Vendors, Service Providers, Contractors, Agents, or Partners.
If we have received your personal information and subsequently transfer it to a third party for processing, we will remain responsible if they process your personal information in a manner inconsistent with the Privacy Shield Principles, unless we prove that we are not responsible for the event giving rise to the damage.
How long we keep information
How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.
Account information: We retain your account information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Services improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.
Information you share on the Services: If your account is deactivated or disabled, some of your information and the content you have provided will remain in order to allow your company or other users to make full use of the Services.
Managed accounts: If the Services are made available to you through an organization (e.g., your employer), we retain your information as long as required by the administrator of your account.
Marketing information: If you have elected to receive marketing emails from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our Services, such as when you last opened an email from us or ceased using your account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
Legal bases for processing (for EEA users).
If you are an individual in the European Economic Area (EEA) which includes European Union Member nations, among others, we collect and process information about you only where we have legal bases for doing so under applicable EU laws. The legal bases depend on the Services you use and how you use them. This means we collect and use your information only where:
- We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
- It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
- You give us consent to do so for a specific purpose; or
- We need to process your data to comply with a legal obligation.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
EU-U.S. Privacy Shield
As a part of our commitment to the Privacy Shield Framework, we are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.
How EEA users can resolve disputes with us
If you have contacted us and are still not satisfied that we have correctly completed our responsibilities with your data, you have the right to contact, free of charge, a panel established by the EU Data Protection Authorities (DPAs), that we have identified as our independent recourse mechanism (IRM). Please contact the appropriate EU DPA based on the country that you reside in. Contact information can be found at https://edpb.europa.eu/about-edpb/board/members_en . If you reside in Switzerland, you will need to contact the appropriate DPA in Switzerland. Contact information for DPAs in Switzerland can be found at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html . We commit to cooperating with the EU data protection authorities (DPAs) or the Swiss Federal Data Protection and Information Commissioner (FDPIC) and complying with any advice given by such authorities with regard to unresolved Privacy Shield complaints concerning data transferred from the EU and Switzerland.
You also have the option of invoking binding arbitration, if certain conditions are met. Those conditions can be found at https://www.privacyshield.gov/article?id=ANNEX-I-introduction .
Other important privacy information
Notice to End Users
Many of our products are intended for use by organizations. Where the Services are made available to you through an organization (e.g. your employer), that organization is the administrator of the Services and is responsible for the accounts and/or Services sites over which it has control. If this is the case, please direct your data privacy questions to your administrator, as your use of the Services is subject to that organization’s policies. We are not responsible for the privacy or security practices of an administrator’s organization, which may be different than this policy.
Administrators are able to:
- require you to reset your account password;
- restrict, suspend or terminate your access to the Services;
- access information in and about your account;
- access or retain information stored as part of your account;
- install or uninstall third-party apps or other integrations
In some cases, administrators can also:
- restrict, suspend or terminate your account access;
- change the email address associated with your account;
- change your information, including profile information;
- restrict your ability to edit, restrict, modify or delete information
Please contact your organization or refer to your administrator’s organizational policies for more information.
Comments and Questions
South49 Solutions, Inc.
46040 Center Oak Plaza, Suite 160
Sterling, Virginia 20166
This policy was last updated on June 24, 2019.