This document ("Privacy Policy") is divided into general part ("General Privacy Policy") and product-related privacy notices ("NordPass Business Privacy Notice" and "NordLocker Business Privacy Notice"), which altogether constitute the entire Privacy Policy and explain the privacy rules applicable to personal data and other information relating to identified or identifiable natural person ("personal data" or "personal information") collected or submitted when you access, install, or use NordPass Business or NordLocker Business services, which include relevant software and any services that Nord provides to Customer through its business-related software, applications or otherwise (all of which are collectively referred to as the Services) and websites ("Website") regardless of the device (computer, mobile phone, tablet, etc.) you use.

Personal data provided in this Privacy Policy is processed by (i) until December 31, 2022 – nordvpn s.a. (ii) from January 1, 2023 – Nord Security Inc. ("Nord", "we", "us", or "our") as a data controller when the data is collected by us (e.g., when you access our Website, contact our customer support) or as a data processor when the data of the End Users is provided by our Customers and processed according to the instructions issued by them.

The capitalized words used in this Privacy Policy as definitions are defined here or in our Terms of Service.

Please acknowledge this Privacy Policy before using our Services, accessing or interacting with our Website.

Product-specific Privacy Notices. As Nord Business products cater to different customer needs, they may process different personal data points during their performance. The following links provide further information about:

• NordPass Business Privacy Notice (additional terms)
• NordLocker Business Privacy Notice (additional terms)

Additional information on your personal data may also be indicated in contractual terms, supplemental privacy statements, or notices.

1. NOTICE TO END USERS

   Our Services are intended for use by organizations (businesses) and are provided on the basis of the Terms of Service. In addition, Nord receives information (including some personal data of End Users) from Customers’ while operating the Services. If your organization (e.g., employer or other entity that entered into the agreement with us) provides you with access to our Services (e.g., create an account or connect to the Services by other means), you are identified as an end user ("End User") and your use of our Services is subject to your organization's policies (if any). Please note that in such a case your organization (our Customer) is the data controller of your personal data.

   Nord processes the End User’s personal data to provide the Services to the Customer and, in some cases, for Nord’s business operations related to providing the Services as described in this Privacy Policy. Nord acts only as a data processor and processes your personal data according to the instructions issued by your organization. Nord is not and cannot be responsible for the privacy or security practices of its Customers, which may differ from those set forth in this Privacy Policy.

   The following information about the End User is provided to us when the Customer uses our Services:

   Account information. On behalf of our Customers, we process: End Users’ full name, telephone number, email, professional information (position, represented entity’s information) account registration, login information, subscription information, basic device information (e.g., device name, IP address, OS, advertising id), application diagnostics, connection timestamps, IP addresses. Please note, that Nord receives this information as a data processor from the Customer and processes this personal data on behalf of the Customer instruction (which in this case acts as a data controller) and in order to ensure proper Service provision, e.g., to send you important updates and announcements related to the use of our Services.

   As mentioned above, if you have questions about the processing of your personal data by Nord in connection with providing Services to your organization, please contact your organization (the Customer). If you have questions about other business operations mentioned in this Privacy Policy when Nord acts as a data controller, please contact us as provided below (Section "Contact Us").
2. PROCESSING OF PERSONAL DATA – NORD AS DATA CONTROLLER

   We collect (directly from you, third parties or your interactions, use, and experiences with our Services/Website) and use the information for the following purposes:

   Information related to the conclusion and performance of the Agreement

   • Personal information. In order to conclude and perform a business agreement with the Customer, we may process Customer’s representatives’ contact information (full name, telephone number, and/or email address) and professional information (position, represented entity’s information).

   Payment related information

   • Payment data. If you have provided payment information to us, such as basic billing information belonging to a natural person (date of purchase, IP address, postal (ZIP) code, billing address, credit card owner’s full name, and credit card information, its expiration date, subscription details), we will process this information (i) to verify payment’s information and prevent fraudulent payments for the Services; (ii) to collect payments to the extent that doing so is necessary to complete a transaction.
   • Country details. When making a purchase as a natural individual, we process the information on the country the purchase takes place. This information is necessary for VAT calculation purposes.

   Online activities

   • Access logs. To ensure Website support and security we collect access logs, such as your IP address, operating system, and browser information. This information is essential for fighting DDoS attacks, scanning, and similar hacking attempts. We also use this information to help us to better design our site, help diagnose problems with our server, and administer our Website.
   • Information received from analytics service providers. To analyze and improve our Website and users’ experience, we use analytics service providers (e.g., Google Analytics) to help us collect aggregated information that does not directly identify you, but provides us with various statistics, such as, which pages visitors visit the most and for how long they stay there. We may also see the following: your device’s IP address, device type, browser information, geographic location (country only), preferred language, the title of the page being viewed, screen size and resolution, out links, referrers, page and website speed. For the collection of such information, our service providers mostly use cookies.
   • Cookies. Cookies, pixels, and other similar technologies are usually small text or image files that are placed on your device when you visit our Website. Some cookies are essential for our Website to operate smoothly; others are used to improve the Website’s functionality, analyze aggregated usage statistics to improve the Website’s performance, and for advertising purposes. Our Website may include social media features, such as the Facebook like and/or share buttons, to help you share our content more easily. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. We also use affiliate cookies to identify the Customers referred to our Website by our partners so that we can grant the referrers their commission. You can check what cookies we use in our Cookie Policy.

   Communication data

   • Communication optimization data. We use various tools to help us optimize our email campaigns. These tools may track actions you perform with an email, such as open rates, click-through rates or unsubscribes from further communication. We may also be able to see the user device’s operating system (e.g., Windows, Mac, iOS, Android), End User custom properties (such as user status, email, member level, which organization the End User belongs to, etc.), End User events (such as, End Users account creation date) and country in order to optimize push and email notifications and automatically set the language.
   • Social media. When you interact with us via social media, we may process information available on your social media profile, also your inquiry or post information, and other information you provide us with.
   • Other communication means. When you contact us to inquire about our Services, we process your full name, email address, entity’s information you contact on behalf of (if provided), and/or other information you provide us with.

   Marketing

   • Information related to marketing activities. We may receive certain data about you (i) directly from you, if you subscribe to marketing communications, complete surveys, or sign up for our events or webinars, publicly available material prepared by Nord or (ii) from certain advertisers and other partners which we use for advertising purposes. Those partners help us deliver more relevant ads and promotional messages to you, which may include interest-based advertising (also known as online behavioral advertising) and account-based advertising. We may also receive your personal data from the organizers of events that you and Nord participate in, or promotions that we sponsor or participate in. Such data may include your contact and professional data (e.g., name, company, position, email address, preferences, and/or interests), cookie id, mobile device id, and inferences about your interests and preferences. We use this information in order to send you offers, surveys, and other marketing content (in line with applicable law) and to manage your participation in our events or seminars. You can easily opt-out of future marketing communications using the opt-out link provided in the emails sent to you.
   • Referrals data. Participation in referral programs maintained by Nord requires referrers to submit personal data (e.g., full name, e-mail address, phone number, relationship with the referred party) about themselves and a referred party so that we could (i) reach out to the referred party; (ii) contact referrers with regards to their participation in referral programs and/or provision of rewards. It is the referrer’s responsibility to abide by applicable privacy laws when disclosing third parties’ personal data to Nord, including informing third parties that they are providing referred parties’ personal data to Nord and how it will be used and processed. Referred parties may unsubscribe from any future communication at any time. If you believe that one of your contacts has provided us with your personal data and you would like it to be removed from our database, please contact us as provided below (Section "Contact Us").
3. GROUNDS FOR PROCESSING OF PERSONAL DATA

   Nord processes personal data to a limited scope and based on the following legal grounds:

   • To fulfill contractual obligations. The information provided might be required for the performance of a contract, i.e., (i) to provide Services and customer support; (ii) to process your purchase transactions; (iii) to ensure the secure, reliable, and robust performance of our Services and Website.
   • To ensure legal obligation. We might be required to use your information as per legal requirements, e.g., to keep and process records for tax purposes and accounting.
   • Your consent. We might use your information where you have given your consent to us, i.e., (i) to send marketing communication (unless applicable law permits us to contact you without prior consent); (ii) to communicate with you and manage your participation in our contests, offers, referrals, or promotions. Please note that although we may also process your personal data for marketing purposes when applicable law permits us to contact you without your separate consent, if you choose not to receive marketing communication from us (i.e., if you opt out), we will honor your request.
   • Legitimate interest. We sometimes may process your personal data under the legitimate interest, i.e., (i) to properly administer business communication with you; (ii) to detect, prevent, or otherwise address fraud, abuse, security, or technical issues with our Services and Websites; (iii) to protect against harm to the rights, property, and safety of Nord, our Customers, End Users, or third parties; (iv) to improve or maintain our Services and provide new products and features; (v) to receive knowledge of how our Website and application are being used.
4. SHARING YOUR PERSONAL DATA

   Only where permitted by applicable laws and for the purposes listed in this Privacy Policy we share, to the extent necessary, the information with:

   Service providers. We use third-party service providers to help us with various operations, such as IT, servers, marketing, customer support, data storage, website customization, website analytics, accounting, legal, agency, and others. As a result, some of these service providers may process your personal data.

   Partners. Sometimes our partners, for example, distributors, resellers, managed service providers, and app store partners might also process your personal data. In such cases, the procedures established by them (e.g., terms of service and privacy policies) will apply to such relationships.

   We also partner with third parties to display advertising on our Website or to manage our advertising on other sites. These partners help us deliver more relevant ads and promotional messages to you, which may include behavioral, contextual, and generic advertising. We and our advertising partners may process certain personal data to help us understand your preferences so that we can deliver advertisements that are more relevant to you.

   Your personal data may be processed in any country in which we engage service providers and partners. When you use our Services and Website, you understand and acknowledge that your personal data may be transferred outside of the country where you reside.

   Other Nord group companies. We share your personal data with other Nord group companies to carry out our daily business operations and to enable us to maintain and provide our Services to you. In accordance with applicable law, we may also share your contact information with Nord group companies for the marketing of their products’ purposes (you have a right to object to such transfer at any time).

   Protection of our rights. We may disclose your data to establish or exercise our legal rights or defend against any legal claims or other complaints. We may also share such information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, and violations of our Terms of Service.

   Business transfers. We may share your personal data in those cases where we sell or negotiate to sell our business or go through a corporate merger, acquisition, consolidation, asset sale, reorganization, or similar event. In these situations, Nord will continue to ensure the confidentiality of your personal data.

   Requests from law enforcement institutions. Any request for data should follow an appropriate official legal process recognized by the laws of incorporation (e.g., mutual legal assistance treaty, letters rogatory). We carefully review each request to make sure it satisfies laws applicable to our company, laws of requesting country, international norms, and our internal policies.

   Cross-border transfers of personal data. To facilitate our Services and Website, we may store, access, and transfer personal data from around the world, including in countries where Nord has operations. These locations may not guarantee the same level of protection of personal data as the one in which you reside. We assess the circumstances involving all cross-border data transfers and have suitable safeguards in place to require that your personal data will remain protected in accordance with this Privacy Policy. For example, in case personal data is transferred to countries outside the EEA, we make sure there is an adequacy decision from the European Commission with regards to the recipient country or we use standard contractual clauses approved by the European Commission for such transfer of your personal data.
5. CHOICES RELATED TO YOUR PERSONAL DATA

   Please note that there are various data protection laws across different jurisdictions that provide privacy rights to you as a data subject. If you are interacting with the Services or Website in a territory governed by those data protection laws under which consent is required to process personal data, your acceptance of Terms of Service or visit of our Website will be deemed as your consent to the processing of personal data for purposes provided in this Privacy Policy. Subject to applicable data protection laws, among others, you may have the following rights:

   • Delete: request us to erase your personal data;
   • Access: know and access personal data Nord has collected about you;
   • Rectify: rectify, correct, update, or complement inaccurate/incomplete personal data Nord has about you;
   • Object: object to the processing of your personal data which is done on the basis of our legitimate interests (e.g., for marketing purposes);
   • Portability: request us to provide you with a copy of your personal data in a structured, commonly used and machine-readable format or to transmit (if technically feasible) your personal data to another controller (only where our processing is based on your consent, and carried out by automated means);
   • Restrict: restrict the processing of your personal data (when there is a legal basis for that);
   • Withdraw consent: withdraw your consent where processing is based on the consent you have previously provided;
   • Lodge a complaint: exercise your rights by contacting us directly or, if all else fails, by lodging a complaint with a supervisory authority.

   Rectification. If you’d like to edit your information (e.g., change your email address), please contact our support team at [email protected].

   Access/Deletion. If you wish to delete your personal data that we process or request to provide you with a copy of your personal data, please contact us at [email protected].

   Opt-out. If you wish to unsubscribe from our marketing communication, you can opt-out at any time by clicking the "unsubscribe" link at the bottom of each email or contacting us at [email protected].

   You can control the use of cookies at the individual browser level on your device. To disable cookies, follow your browser’s instructions on how to block or clear cookies.

   If you do not agree with the processing of your personal data by Nord, please do not use our Services and Website. You can request us to discontinue processing your personal data, in which case your data will be processed only as much as it is necessary to affect the discontinuation of your use of the Services (e.g., final settlement or deleting all personal data), or finalizing other our legal relationship with you (e.g., record keeping, accounting, processing refunds). Please note that we or our third-party service providers may be obliged to retain your certain personal data as required by law.

   If you are using Nord Services as an End User and you want your personal data to be no longer processed by us, you should contact the Customer that granted you access to our Services.

   To raise any other questions, concerns, or complaints about our privacy practices or about our processing of your personal data, please contact us as provided below (Section "Contact Us").
6. DATA SECURITY

   We maintain tight controls over the personal data we collect. Our dedicated IT security team has implemented appropriate physical, technical, and organizational measures to protect information about you against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure, or access and against all other unlawful forms of processing:

   • Physical Measures. We control access to our facilities with access cards. We also use security alarm systems and CCTV. We store devices with personal data information only in locked rooms or cabinets. Our printers are protected by access control measures. A clean desk policy is implemented.
   • Technical Measures. We use layered defense with firewalls, anti-malware protection, intrusion detection, and prevention systems. Our infrastructure is regularly updated and regular vulnerability scans are in place to detect possible vulnerabilities. We have security event and incident management solutions to correlate and investigate signals in security tools. Servers are hardened and automated configuration tools are used to manage them. All workplaces are managed from a centralized endpoint management tool. Data at rest and in transit are encrypted. Encryption protocols are used according to the newest security practices.
   • Organizational Measures. We adopted information security and data processing policies according to best practices. We have external audits to prove our information security and data processing policies are up to standards. We adopted a constant development culture of security and data protection awareness among our employees (including organizing regular and ongoing training and other awareness activities). We analyze the threat landscape and attack surface and constantly update our security measures. Access to databases containing personal data is granted on a need-to-know basis.

   We maintain tight controls to protect information about you against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access, and against all other unlawful forms of processing. However, no company can guarantee the absolute security of internet communications as no technology is completely bulletproof. By using the Services and Website, you expressly acknowledge that we cannot guarantee the 100% security of personal data provided to or received by us through the Services and that any information received from you through Websites or our Services is provided at your own responsibility. If you have any reason to believe that your interaction with us is no longer secure, please notify us at [email protected].
7. DATA RETENTION

   Nord will retain End Users’ data in accordance with the Customer’s instructions.

   In cases when Nord acts as a data controller, it stores personal data only for as long as it is necessary for the original purpose of collection or legal requirements. We determine the appropriate retention period for personal data on the basis of the amount, nature, and sensitivity of the personal data being processed, the potential risk of harm from unauthorized use or disclosure of the personal data, if we can achieve the purposes of the processing through other means, and if the information is necessary for the execution of our legal rights, obligations and fulfillment of our other duties (for example, record and bookkeeping). When we no longer have a legal ground to keep your personal data, it will either be securely disposed of, or de-identified through appropriate anonymization means.

   For more information about specific retention periods, please reach out to us at [email protected].
8. COUNTRY-SPECIFIC PROVISIONS

   For users in European Economic Area ("EEA")

   If you are a resident of EEA countries, you can exercise your rights as provided in the European Union's General Data Protection Regulation ("GDPR") by contacting us at[email protected]. To comply with the GDPR, we have also implemented appropriate contracts for international transfers, on the basis of the standard contractual clauses approved by the European Commission and other international models as required by local law.

   For users in California

   If you are a California resident, you can exercise your rights as provided in the California Consumer Privacy Act ("CCPA") by contacting us at[email protected]. As per definitions in the CCPA, please note that Nord does not sell, share, lease, or rent your personal information.
9. MINORS’ DATA

   Nord does not knowingly collect or solicit personal data from anyone under the age of 18. If you are under 18, please do not attempt to send any personal data about yourself to us. If we acknowledge that we have collected and processed personal data from a minor under the age of 18, we will delete that data as quickly as possible.
10. CONTACT US

    If you have questions, requests, concerns, or complaints about how your data is being processed or personal data processing practices, please contact us via [email protected], or by writing to us at the following address:

    • until December 31, 2022: nordvpn s.a., PH F&F TOWER, 50th Street & 56th Street, Suite #32-D, Floor 32, Panama City, Republic of Panama.
    • from January 1, 2023: Nord Security Inc., Americas Towers, 1177 6th Avenue, 5th FLR, New York, NY 10036, United States of America.

    On matters related to the processing of personal data, you may also contact our representative VeraSafe in the European Economic Area using the following details:

    • via this contact form: https://verasafe.com/public-resources/contact-data-protection- representative
    • via telephone at: +420 228 881 031
    • via the postal address at: VeraSafe Ireland Ltd., Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P, Ireland.

    If you are located within the United Kingdom, you may also contact our representative VeraSafe in the United Kingdom:

    • via this contact form: https://verasafe.com/public-resources/contact-data-protection- representative
    • via telephone at: +44 (20) 4532 2003
    • via the postal address at: VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom.
11. OTHER TERMS

    Limitation of Liability. To ensure the security of personal data, we apply various technical, physical, and organizational security measures; however, it is your responsibility to exercise caution and reasonableness when using the Services and Website. You will be personally liable if your use of the Services or Website violates any third-party privacy, any other rights or any applicable laws. Under no circumstances is Nord liable for the consequences of your unlawful, willful, and negligent activities, and any circumstances that may not have been reasonably controlled or foreseen (please read the Terms of Service for more information).

    Links to other websites. Our Website may include links to other websites (e.g., social media websites) whose privacy practices may be different from ours. If you access any of those websites via such links and/or submit your personal data to any of those websites, your personal data is processed by the procedures established by those third parties and governed by their privacy policies. We encourage you to carefully read the privacy policy (or other respective privacy notices) of any website you visit.

    Updates to the Privacy Policy. We develop our Services and Website by introducing new features or modifying current ones constantly. Therefore, we may need to amend this Privacy Policy from time to time. If the amendments to the Privacy Policy materially affect the activities of our processing of your personal data, we will notify you in advance of such changes by reasonable means (e.g., notification through the respective applications, our Website, or via email), and we will always indicate the date of the last update. Unless it is stated by us otherwise, each update of the Privacy Policy comes into force as of the moment the amended Privacy Policy is published on this Website. You are expected to check this Privacy Policy regularly so that you are familiar with the most current wording of the Privacy Policy. Your continued use of the Services and Website will be deemed acceptance thereof.