Nooli Privacy Notice

We’re so glad you’re here. It’s great to see you care about how we use the data you give us.  

We made Nooli so that everyone can live their richest life, realise their goals, and make the most of their money. But, we also know that these things will look different for everyone. That’s why we personalise Nooli just for you.  To achieve this, we need to ask for some information about you and your life. But, rest assured, we never have and never will sell the personal data you give us. 

 Your data has not been given to a third party, so no junk mail will be landing in your inbox because of Nooli . Your personal data will never be used in a way that means you, or any other Nooli member for that matter, can be identified. 

How do we use this information?

We use the information you give us about yourself to make sure you only see noolies (these are bite-sized ways to create your richer life throughout the app) that will help you reach your personal goals.

For example, if you tell us you don’t have children, we’ll use personalisation to make sure we don’t show you noolies about maternity pay or nursery fees! If you tell us you’re self-employed, we won’t show you noolies about asking your boss for a pay rise. 

We use the data you share to give you noolies that we believe will help you live a richer life. That’s it.

Your personalised journey is waiting for you. It’s time to explore it! But if you’d like more detailed information, our Privacy Notice is below.

NOOLI PRIVACY NOTICE

1. Who we are

This Privacy Notice applies to your use of the Nooli App, referred to as “Nooli” or the “app” in this Notice.  The Nooli App is provided by Loqbox Technology UK Limited (company number 07916178).

This Privacy Notice applies when you download and use the  Nooli App” and it applies to all personal data processing activities related to the App. 

This Privacy Notice should be read in conjunction with our Cookie Policy, available at https://www.nooli.co.uk/cookie-policy

We comply with the EU law retained version of the General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018 (the “Data Protection Legislation”). If any of these laws are replaced or superseded, we will also comply with that.

This Privacy Notice addresses where we act as Controllers in respect of personal information that we process in connection with our business.

We respect individuals’ right to privacy and to the protection of their information. The purpose of this Privacy Notice is to explain the information we collect, how we use and share it, how to manage your marketing preferences and a confirmation of your rights. It is important that you read this Privacy Notice when we are collecting or processing personal data about you so that you are aware of how and why we are using your personal data.

We may update this Privacy Notice from time to time, and we will publish the latest version on our site and would encourage you to visit our site regularly to stay informed of how we use your data.

If you have any questions regarding this Privacy Notice, please contact us at hello@nooli.co.uk

2. The information we collect and use

Personal data means any information which relates to an individual and can be used for the purposes of identification, either directly or indirectly, typically through the use of an identifier.

We collect, process and use the following kinds of personal data at the start of, and during, your relationship with us including the purposes set out below:

Identity, contact and financial data – title, first name, last name, date of birth, email address, telephone number, residential address and some financial details. The purpose of collection and processing of this data is so we can register you as a customer, so you can use our services and so we can contact you about any customer service issue.

Technical information – including the Internet protocol (IP) address used to connect your computer/ device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, and your operating system, platform and device. The purpose of the processing of this data is to support your access to our site and the performance of our app.

Marketing data – first name, last name, email address, telephone number. The purpose is to provide you with marketing and promotional material.

Usage information: information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our sites (including date and time), app downloads, app usage and engagement data (including, but not limited to, time on app, content viewed and engaged with), external link clicks out. The purpose is to understand how you use our site, in order to improve and develop the services we provide, and better inform our marketing strategies.

Analytics - includes third-party analytics services (such as Google Analytics) to evaluate your use of our site or app, compile reports on activity, collect demographic data, analyse performance metrics, and collect and evaluate other information relating to the site and internet usage. These third parties use cookies and other technologies to help analyse and provide us the data.

We do not seek to collect or process special categories of information about you such as your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data.

3. How we collect your information

Your information is made up of personal data we collect and hold about you and your transactions with us, and includes:

Information you give us;

Information we receive from third parties, including third parties who provide services to us and our commercial partners, typically your name and contact details;

Information we learn about you through our relationship with you and the way you operate your products;

Information that we gather from the technology which you use to access our services.

We also receive information from other sources, including information about you if you use any of the other websites we operate or the other services we provide.

Please note that if you do not agree to provide us with the information we request, it may not be possible for us to continue to operate your account and/or provide products and services to you.

4. How we use your information

We will only use and share your information where it is necessary for us to carry out our lawful business activities. The lawful bases for processing your data include as described below, and, in some cases, there may be more than one lawful basis for processing your information:

A. Contractual obligation

We may process your information where it is necessary to enter into a contract with you for the provision of our products and services or to perform our obligations under that contract. This may include:

registering you as a customer and providing and administering those products and services related to the App, communicating with you about the products and services you receive from us and any changes to the products or services provided to you, dealing with complaints and managing your account.

B. Legal obligation

When you apply for a product or service (and throughout your relationship with us), we are required by law to collect and process certain personal data about you. This may include processing to:

confirm your identity;

perform checks to detect and prevent financial crime;

investigate and resolve complaints;

establishment and defence of our legal rights;

comply with legal and regulatory requirements.

C. Legitimate interests

We may process your information where it is in our legitimate interests to do so as an organisation and without prejudicing your interests or fundamental rights and freedoms. This may include processing to:

make suggestions and recommendations to you about goods and services that may be of interest to you;

deliver relevant content to you via our App;

protect the security of our business, including information security, network security and business continuity;

monitor the performance and effectiveness of our products and services;

send you marketing communications relating to products or services that we believe may be of interest to you;

managing and maintaining our relationship with you;

enable us to create custom audiences and lookalike audiences.

5. How we use and share your information with other Group companies

Your information may be shared with and processed by associates of Loqbox Technology UK Limited and may be used in the ways described in section 4 above.

6. Sharing your information with third parties

We may share your information with anyone outside Loqbox Technology UK Limited and its associates under the following circumstances:

we have your permission;

where required for your product or service;

with third parties providing services to us, including commercial partners and service providers, such as for the purposes of securing payments, fulfilling orders, marketing and optimising our services;

with any third party that purchases, or to which we transfer, all or substantially all of our assets and business;

with law enforcement agencies, regulators, courts, government authorities, and or fraud prevention agencies or other third parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.

7. Your rights

We want to make sure you are aware of your rights in relation to the personal data we process about you, and these are described below. You have a:

right to access your personal data held by us;

right to have inaccurate personal data rectified;

right to have certain personal data erased where it is no longer necessary for us to process it, where you have objected, where your personal data has been unlawfully processed, or where erasing your personal data is required in accordance with a legal obligation;

right to request that we restrict processing of your personal data, if you believe that any of the information that we hold about you is inaccurate;

we no longer need to process your information for the purposes for which it was provided, but you require the information to establish, exercise or defend legal claims; or we are not using your information in a lawful manner;

right to receive certain personal data in a portable format (we will provide .csv readable on Microsoft Excel or equivalent);

right to object to processing where the lawful basis is that it is in our legitimate interests, but please note that we may still process your personal data where there are other relevant lawful bases or where we have compelling grounds to continue processing your personal data in our interests which are not overridden by your rights, interests or freedoms;

right to complain to the Information Commissioner’s Office (ICO), the UK data protection regulator (they can be contacted via their website www.ico.org.uk);

right to object to direct marketing, which can be done by opting-out of direct marketing via the communication itself.

Where you make a request in respect of your rights we will require proof of identification. We may also ask that you clarify your request.

Please note that in some cases if you do not agree with the way we process your information we may not be able to provide, or to continue to provide, a product or service to you.

If you wish to exercise any of these rights or have any questions about them, please contact us at hello@nooli.co.uk

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

8. How long we keep your information

We keep and maintain records to help us best serve users of the App, for example, in order to investigate and resolve queries relating to your use of the App, and in line with legal and regulatory requirements.

Records are retained for a period of five years after your relationship with us ends. This period may change based on changes in our business or our legal and regulatory obligations.

9. Transferring information overseas

In the event that we transfer information to countries outside of the United Kingdom and European Economic Area (which includes countries in the European Union as well as Iceland, Liechtenstein and Norway), we will only do so where:

The UK government has assessed a country as providing adequate protection for individuals’ rights and freedoms for their personal data and therefore adequacy regulations cover such a transfer;

the transfer has been authorised by the relevant data protection authority; and/or

we have entered into a contract with the organisation with which we are sharing your information (on terms approved under UK GDPR) to ensure your information is adequately protected.

10. Security

We strive to protect your personal data and our products and services from unauthorised access. This includes use of various security measures to protect your personal data held by or on behalf of us and ongoing review of our information collection, storage and processing practices.

Subject to the uses described in this Privacy Notice, we will endeavour to treat all of your personal data in strict confidence and endeavour to take all reasonable steps to keep your personal data secure once it has been transferred to our systems. However, the internet is not a secure medium and we cannot guarantee the security of any data you disclose online. You accept the inherent security risks of providing information and dealing online over the internet and will not hold us responsible for any breach of security unless this is due to our failure to ensure we have appropriate technical and organisational measures in place as required by GDPR and Data protection legislation.

If you link to another website or app from the App then your personal data will be governed by its Privacy Notice or Policy. We recommend that you always read any such Privacy Notice or Policy before interacting with a new website to ensure you understand how your personal data will be used.

11. Contact us

If you have any questions regarding this Privacy Notice or the way we use your personal data, please contact us at hello@nooli.co.uk