Introduction
When you use Nobli, you trust us with your personal data. We are deeply committed to maintaining that trust. This commitment starts with helping you understand our privacy practices.
This notice explains the personal data (“data”) we collect, how it’s used and shared, and the choices you have regarding your data. We encourage you to read this carefully.
Overview
This notice applies to users of Nobli’s services worldwide, including users of Nobli’s app, website, features, or other services.
This notice describes how Nobli and its affiliates collect and use data. It applies to all Nobli users globally. Specifically, this notice applies to:
This notice also governs Nobli’s collection of data in connection with its services.
All those subject to this notice are collectively referred to as “users” in this document.
Our privacy practices comply with applicable laws in the regions where we operate. We engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.
A. Data controller and transfer
1. Nobli LTD as the Data Controller
Nobli LTD (4 Panteli Katelari, Egkomi, Nicosia 2413, Cyprus) is the data controller for the personal data collected in connection with the use of Nobli’s services.
Nobli operates and processes personal data globally. Wherever and whenever you use our services, your data travels with you to provide a seamless experience. We respect your data protection rights regardless of your location, whether you are in your home country or abroad.
This means that we may transfer personal data to countries other than your home country in order to provide our services in another region at your request. We may also transfer personal data to another country to respond to customer support requests made outside your region. Additionally, data such as shared files or family tree connections may be accessed by authorized users in different countries.
We undertake these transfers to fulfill our agreements with our users or based on users’ instructions or prior consent. These transfers are conducted in compliance with adequacy decisions for the relevant countries or other transfer mechanisms provided under applicable laws, such as the Standard Contractual Clauses.
We may also transfer data to other countries in response to legal requests from law enforcement agencies. Nobli ensures compliance with the regulatory requirements of applicable laws, including the EU GDPR, and applies a rigorous internal procedure to process such requests. Nobli only discloses personal data to law enforcement in cases where disclosure is required by applicable law, there is imminent risk of serious harm to individuals, or the user has provided consent.
To provide consistent and robust data protection worldwide, Nobli has implemented the following measures:
Policies and procedures that limit access to and processing of personal data for specific purposes.
Specialized training for personnel managing personal data.
A government data access policy that ensures access is refused unless disclosure is mandated by law, there is imminent risk of harm, or consent is provided by the user.
Secure data transfer protocols, including encryption and pseudonymization, to protect personal data while in transit or during processing on our servers.
With these safeguards, Nobli is committed to protecting your personal data and ensuring compliance with applicable data protection regulations, including the GDPR.
Data collections and uses
The Data We Collect
Nobli collects data to provide and enhance our services. This includes data:
Provided by users to Nobli, such as during account creation or updating profiles.
Created during the use of our services, such as activity logs, app usage, and device data.
Obtained from other sources, such as trusted contacts, business partners, and government authorities.
Data Provided by Users
User Profile Information:
We collect data when users create or update their Nobli accounts. This includes:
Name, email, phone number, login credentials, and profile picture.
Files and documents uploaded to Vaults, such as photos, videos, legal documents, and medical records.
Family tree data, including relationships, names, and chosen designations for family members.
Emergency contact information.
User preferences and account settings.
Identity Verification:
Users may be required to verify their identity, which can include providing photos of government-issued identification (such as passports or ID cards) and/or selfies. These may be used for security and account verification purposes.
Demographic Data:
We may collect demographic data, such as age, gender, or occupation, when required for certain features or programs. This data may also be inferred from user input or collected through surveys.
Data Created During Use of Our Services
Activity Data:
We collect data about user activity within the Nobli app, such as:
Vault creation and sharing preferences.
Tags and categorizations of uploaded files.
Interactions within the Family Tree feature, such as relationships established and Cube highlights selected.
Public content shared via the Feed.
Usage Data:
We collect data on how users interact with Nobli’s features. This includes:
Access dates and times.
Pages or app features viewed.
App crashes and other system activities.
Preferences set for visibility and sharing.
Device Data:
We collect data about the devices used to access Nobli, including:
Device hardware models, operating systems, and versions.
Device IP address, unique device identifiers, and mobile network data.
Browser types and preferred languages.
Communications Data:
We may collect data regarding in-app communications, such as messages exchanged within Nobli, including timestamps and content where necessary.
Data from Other Sources
We may collect data from the following sources:
Trusted contacts who receive or share Vaults or Family Tree connections.
Users participating in referral programs, where the referring user provides the referred user’s data.
Business partners that help facilitate services, such as payment providers or marketing services.
Publicly available sources for verifying information or enriching profiles.
Law enforcement or government authorities when required by applicable laws.
How We Use Personal Data
Nobli uses data to provide a secure, personalized platform for users to share their stories, organize their digital lives, and create a lasting legacy. We also use such data:
To enhance the safety and security of our users and services.
For customer support.
For research and development to improve the user experience.
To enable communications between users.
For marketing and advertising (with user consent where required).
To send non-marketing communications to users.
In connection with legal proceedings.
To Provide Our Services
Nobli uses data to provide, personalize, maintain, and improve its services. This includes:
Creating and updating user accounts.
Enabling core features, such as:
Creating and managing Vaults.
Establishing and interacting with Family Tree connections.
Uploading, tagging, and sharing personal files.
Highlighting specific memories within the Cube feature.
Processing permissions for sharing Vault content with trusted contacts.
Sending updates about changes to Nobli’s terms, services, or policies.
Performing necessary operations to maintain the app, such as troubleshooting software bugs and addressing operational issues.
Nobli performs the above activities to fulfill its agreements with users and to serve its legitimate interest in providing secure, high-quality services.
Safety and Security
We use data to help maintain the safety, security, and integrity of our platform and users. This includes:
Verifying user identities when necessary, such as through profile photo and identification checks.
Using device, location, and user activity data to detect and prevent fraud, unauthorized access, or misuse of Nobli services.
Identifying and addressing behaviors or activities that violate our terms of service.
These activities are performed to fulfill our agreements with users and to protect the legitimate safety and security interests of Nobli, its users, and the broader community.
Customer Support
We use the information we collect to provide customer support, including:
Investigating and addressing user concerns.
Monitoring and improving our support processes.
These activities are necessary to fulfill our agreements with users and to improve Nobli’s customer experience.
Research and Development
We use data for testing, analysis, and product development to:
Improve the user experience.
Enhance the safety and security of our platform.
Develop new features and services, such as enhanced sharing options or additional privacy tools.
These activities are performed to serve Nobli’s legitimate interest in continuously improving its services.
Enabling Communications Between Users
Nobli facilitates communication between users to enhance collaboration and connection. For example:
Trusted contacts may receive notifications when Vault content is shared with them.
Family Tree members may interact through the platform to share memories or updates.
These activities are necessary to fulfill agreements with users and enable key Nobli features.
Marketing and Advertising
Nobli may use data to market its services or those of its partners, including:
Sending emails, push notifications, or in-app messages about features, promotions, or events.
Displaying personalized advertising on third-party platforms, using data such as user preferences and activity within Nobli.
These activities are performed with user consent or to serve Nobli’s legitimate interest in promoting its services.
Non-Marketing Communications
We may use data to send surveys or other communications unrelated to marketing, such as:
Informing users about changes to features or policies.
Gathering feedback to improve our platform.
These activities are performed to fulfill agreements with users and for Nobli’s legitimate interests in improving user engagement and transparency.
Legal Proceedings and Requirements
We use data to:
Investigate claims or disputes related to Nobli services.
Comply with applicable laws, regulations, or legal requests from governmental authorities, including law enforcement.
These activities are performed to fulfill Nobli’s legitimate interests in resolving disputes and complying with legal obligations.
Data Sharing and Disclosure
Some of Nobli’s features and services require sharing data with other users or at a user’s request. We may also share data with our affiliates, service providers, and partners, for legal reasons, or in connection with claims or disputes.
Nobli may share data as follows:
With Other Users
This includes sharing:
For Vaults: Content shared by a user within a Vault (e.g., photos, documents, videos) with authorized recipients such as family members, trusted contacts, or public audiences based on the user’s sharing preferences.
For Family Tree: Users in your Family Tree may access your profile and highlights based on the permissions you set.
For users participating in referral programs: Certain data (e.g., referral activity) may be shared with the referring user to determine rewards or incentives.
At the User’s Request
This includes sharing data with:
Emergency Services: If a user opts to use Nobli’s emergency-sharing features, we may share the necessary data with police, medical personnel, or other emergency responders.
Trusted Contacts: Users can choose to share specific Vault content or Family Tree information with trusted individuals.
Here’s how the Data Sharing and Disclosure section would look for Nobli, customized for its context:
Data Sharing and Disclosure
Some of Nobli’s features and services require sharing data with other users or at a user’s request. We may also share data with our affiliates, service providers, and partners, for legal reasons, or in connection with claims or disputes.
Nobli may share data as follows:
With Other Users
This includes sharing:
For Vaults: Content shared by a user within a Vault (e.g., photos, documents, videos) with authorized recipients such as family members, trusted contacts, or public audiences based on the user’s sharing preferences.
For Family Tree: Users in your Family Tree may access your profile and highlights based on the permissions you set.
For users participating in referral programs: Certain data (e.g., referral activity) may be shared with the referring user to determine rewards or incentives.
At the User’s Request
This includes sharing data with:
Emergency Services: If a user opts to use Nobli’s emergency-sharing features, we may share the necessary data with police, medical personnel, or other emergency responders.
Trusted Contacts: Users can choose to share specific Vault content or Family Tree information with trusted individuals.
With the General Public
Certain features may involve public sharing:
Content in Public Vaults or Public Feed is accessible to all Nobli users.
Questions or comments submitted by users on Nobli’s social media pages or public forums may be viewable by the general public, including any included data.
With Nobli Service Providers and Business Partners
These include:
Cloud Storage Providers: To securely store user data.
Payment Processors: To process transactions related to subscriptions or premium features.
Identity Verification Providers: To verify user identity and secure accounts.
Research Partners: To conduct surveys or research to improve Nobli’s services.
Social Media Platforms: When Nobli uses tools provided by platforms like Facebook, Instagram, or TikTok (e.g., for advertising or analytics).
Professional Service Providers: Such as consultants, lawyers, or accountants, for operational purposes.
For Legal Reasons or in the Event of a Dispute
Nobli may share data if required by:
Applicable law, regulation, or governmental request.
Enforcement of our Terms of Service, user agreements, or policies.
Protection of Nobli’s rights, property, or the safety of others.
This may include sharing data with law enforcement, public authorities, or other third parties. For example:
If a legal dispute arises, we may share relevant data to resolve claims.
In the event of a merger, acquisition, or sale of assets, data may be transferred as part of the business transaction.
With Consent
Nobli may share data in ways not described in this notice if the user is informed and consents to such sharing.
Cookies and Third-Party Technologies
Nobli and its partners use cookies and other identification technologies on our app, website, emails, and online advertisements for the purposes outlined in this notice.
Cookies are small text files stored on browsers or devices by websites, apps, online media, and advertisements. Nobli uses cookies and similar technologies for purposes such as:
Authenticating users.
Remembering user preferences and settings.
Analyzing app and site traffic to improve functionality.
Delivering and measuring the effectiveness of advertising campaigns.
Understanding user behaviors and interests to enhance the overall experience.
We may also partner with third parties to provide analytics and advertising services. These entities may use cookies, web beacons, SDKs, and other technologies to track and analyze activity across Nobli’s app, website, and other online platforms. They may also use these technologies to deliver targeted ads and measure their performance.
For more information about cookies and how to manage your preferences, you can adjust your browser settings or use in-app tools provided by Nobli.
Data Retention and Deletion
Nobli retains user data for as long as it is necessary to provide its services and comply with legal obligations.
The duration for which Nobli retains data depends on the type of data, its purpose, and the user category. Retention periods may also be influenced by legal and regulatory requirements, safety and security concerns, fraud prevention needs, or unresolved account issues.
For example:
Active Accounts: Data such as user profiles, Vault content, and Family Tree information is retained for the life of a user’s account to enable service continuity.
After Deletion Requests: Data may be retained after an account deletion request to comply with legal requirements, prevent fraud, ensure safety, or resolve outstanding issues such as unpaid credits or disputes.
Account Deletion Requests:
Users may request deletion of their accounts at any time through Nobli’s app or website contact form. Upon receiving a deletion request:
Nobli will delete the user’s account and associated data unless retention is necessary to:
Comply with legal or regulatory obligations.
Ensure safety, security, and fraud prevention.
Address unresolved account issues, such as outstanding credits or disputes.
Data that must be retained under these conditions will be securely stored and access will be restricted to the extent required by applicable laws.
For further information or to initiate a deletion request, users can contact us through Nobli’s support channels.
Updates to this notice
We may occasionally update this Privacy Notice. If significant changes are made, we will notify users in advance through the Nobli app or other means, such as email.
We encourage users to periodically review this notice to stay informed about our privacy practices.
Continued use of Nobli’s services after an update constitutes your acceptance of the updated notice, as permitted by applicable law.