Privacy Policy — NuVerge, LLC

NuVerge, LLC Privacy Policy

We have taken great measures to ensure that your visit to our website and your interactions with NuVerge are satisfying and that your privacy is respected. Because NuVerge is a professional services firm focused primarily on serving other businesses, NuVerge may have access to our clients personal data that belongs to the data subjects and consumers who are associated with those clients.

Effective as of February 15, 2020

1. Introduction

NuVerge, LLC (“NuVerge” or “we” or “our” or “us”) are committed to protecting your privacy when you interact with us.

This Privacy Statement (“Privacy Statement or “Statement”) sets out the privacy practices for NuVerge with respect to Personal Data and Personal Information (which means any information that relates to, identifies, describes, or can be reasonably associated or linked with a natural person or household) we obtain from and about individuals interacting with NuVerge and its websites, mobile applications, and services. All Personal Data that we collect, other than information collected in the employment context, is subject to this Privacy Statement.

Please read the information below to learn about the Personal Data collected about you and how it is used. Please note that there is a separate Terms of Use found in the “Terms & Conditions” hyperlink located at the bottom of our website. We may revise this Privacy Statement from time to time and will do so by posting additions or modifications to this page. The most current version of the Statement can always be reviewed by clicking on the “Privacy Statement” link located at the bottom of our website. If you are a resident of California, please see the section below titled, “Additional Information for Residents of California.”

2. Types of Personal Data Collected

The type of Personal Data we collect depends on how you use this website or interact with NuVerge.

When you visit our publicly available website, we may collect the following types of information, including Personal Data, from you:

Contact information
Event registrations and preferences
Feedback and reviews or request for support
Log files, information collected by cookies and similar technologies about the pages viewed, links clicked and other actions taken when accessing our website, which may be considered Personal Data under applicable laws (see our Cookie Policy for more information)
Activities, interactions, preferences, transaction information and other computer and connection information (such as IP address) relating to the use of our website and our services

When you conduct business with NuVerge, we may collect the following types of Personal Data:

Contact information

Financial and billing information
Event registrations and preferences
Feedback and reviews or request for support
Activities, interactions, preferences, transaction information and other computer and connection information
Resumes and information relevant to our market research activities that: you provide to us directly; we receive about you from referrals; or we collect from publicly available sources and websites

If you are being considered for employment with NuVerge, we may collect and process the following types of Personal Data:

Resume, application, candidate profile, or interview logistics information during the recruiting process. The sources of employment application information include yourself (when you provide information directly to us, for example, through our job postings portal on this website), publicly available information (such as information on job posting websites), and external recruiting sources (such as professional recruiting or placement agencies)

NuVerge may collect Personal Data from service providers who provide services to us, such as web analytics providers.

3. How We Use Personal Data

NuVerge collects and uses Personal Data for our legitimate interests as set out herein, or based on your consent (in which case we would ask you separately to provide your consent to a particular processing activity) through:

Personalizing information about our services
Personalizing your experience on our website, such as providing recommendations based on your industry or past behavior on the website
Providing services, training and education, tools (such as NuVerge NuView and NuTrax products), and support to our customers, which may also be necessary for the performance of a contract with you
Conducting business with our suppliers and other entities, including market research activities
Considering candidates for job vacancies with NuVerge entities, including all elements of the procedure leading up to making a decision whether to offer, subject to any appropriate background checks, the applicant a position. Some job applicant data processing may also be necessary to comply with legal obligations
Other purposes disclosed at the time of collection or otherwise compatible with the above and applicable law

In instances where information is transferred to NuVerge through a client data controller and NuVerge is acting as the processor, the processing is necessary for the performance of a contract or for our legitimate interest to provide the requested services to our clients. NuVerge will assist the client data controller in complying with its legal obligations.

4. With Whom We Share Personal Data

NuVerge may share Personal Data we collect with the following entities and for the following purposes:

Service providers contracted to provide services on behalf of NuVerge for discrete business purposes such as provision of IT related services, event planning, talent recruiting, market research interviewees and providers, and travel services
Other corporate entities when a business transaction occurs such as a merger or acquisition
Entities with whom NuVerge works in providing a service, such as educational establishments with whom NuVerge collaborates to provide training and certification, and organizations at which NuVerge arranges for students to obtain practical experience

NuVerge may disclose Personal Data in special cases when we have a good faith belief that it is necessary: (a) to conform to legal requirements or to respond to lawful requests by public authorities, including to meet national security or law enforcement requirements; (b) to protect and defend our rights or property; (c) to enforce the website Terms and Conditions; or (d) to protect the interests of our users or others.

5. Retention of Data

We will keep your Personal Data as reasonably necessary to fulfill the purposes for which Personal Data is collected as stated herein; for as long as is necessary for the performance of the contract between you and us, if any; and to comply with legal and statutory obligations, such as those required by tax, trade and corporate laws. When we no longer need your Personal Data for our purposes, we will destroy, delete or erase that Personal Data or convert it into an anonymous form.

6. Choices You Have About How NuVerge Uses Your Personal Data

We strive to provide you with as many choices and as much control as possible regarding the Personal Data you provide to us.

If you have questions, complaints or concerns regarding this Privacy Statement or wish to access your Personal Data, or update, change or remove your Personal Data, please contact privacy@nuverge.com, or send mail addressed to:

NuVerge, LLC
Attn: Chief Privacy Officer
12303 Airport Way, Suite 100
Broomfield, Colorado 8002

If you wish to opt out of receiving marketing or other communications, you can either respond using theopt-outt button in the relevant communication, or by contacting us by one of the methods listed above.

7. How NuVerge Protects Your Personal Data

NuVerge takes reasonable and appropriate measures to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the data.

8. External Links

This website may contain links to or from other websites. Please be aware that we are not responsible for the privacy practices of other websites. This Privacy Statement applies only to the information we collect on this Site or as otherwise described herein. We encourage you to read the privacy notices of other websites you link to from our Site or otherwise visit.

9. Children’s Privacy

This website is not intended for children under the age of 13. We will not knowingly collect information from website visitors in this age group. By using the Site, you represent that you are age 13 or over. If you believe that a child may have provided his or her Personal Data to us, please contact us using the contact information at the end of this Statement. In the event we become aware that we have collected Personal Data from a child under the age of 13, we will dispose of that Personal Data immediately.

Additional Information for California Residents

This supplemental section of NuVerg’s Privacy Statement is directed at and applies to a limited subset of individuals who interact with NuVerge, who are verifiable residents of the state of California, and who are not otherwise exempted from the California Consumer Privacy Act (CCPA). NuVerge is largely not subject to the requirements of the CCPA given the nature of our business (i.e., primarily business-to-business transactions as described below).

If you are a resident of California, who is neither (a) an employee, owner, director, officer, or contractor of an organization (i.e., company, sole proprietorship, non-profit, or government agency) whose communications or transactions with us occur solely within the context of us conducting due diligence regarding, or providing or receiving a product or service to or from your organization), or (b) a job applicant, you have the following specific additional privacy rights under the law:

Right to request access to personal information. California residents have the right to request that we disclose to them the categories and specific pieces of personal information we have collected about them. Upon submission and our receipt of a verifiable consumer request, and not more than twice in a 12-month period, we are required to provide such information directly to California consumers (if it is not already provided here or in another notice).

Right to request deletion of personal information.California residents have the right to request that we delete any personal information about them which we collected from them. Our obligation to delete personal information is limited by the law, and we are not required or able to comply with requests in all instances; for example, if it is necessary for us to maintain personal information in order to complete a transaction with the consumer, detect or protect against security incidents or other illegal or deceptive activity, exercise our free speech or other rights provided by law or protect the lawful rights of another consumer, comply with other legal obligations, or enable internal uses of the personal information in a lawful manner compatible with the context in which the consumer provided the information or would expect it to be used based on their relationship with us. For the full list of exceptions, see Cal. Civ. Code § 1798.105.

Right to request disclosure of what personal information we process, the source of it, the business or commercial purpose for processing it, and with whom (e.g., service providers) we share it. California residents have a right to request that we disclose to them (if we have not already in this or another notice): the categories of personal information collected about them, the categories of sources from which it was collected, the business or commercial purpose for collecting it, the categories of third parties (e.g., service providers) with whom we share it, and the specific pieces of personal information collected about them. A large portion of that information is provided here in this Privacy Statement, and we may direct you back here to make note of that information. It should also be noted that the disclosure right related to specific pieces of personal information is not absolute, and it is our responsibility to protect that sort of information from unauthorized disclosures. Please refer to the sections below on How to Submit and What to Expect for more information about the process.

Right to know that we do not “sell” personal information. We have not sold (neither under the ordinary meaning of the term “sale,” nor under the CCPA’s definition of “sale”) consumers’ personal information in the preceding 12 months.

HOW TO SUBMIT A REQUEST TO EXERCISE YOUR CCPA RIGHTS

If you are a consumer and resident of California who is not a job applicant or individual involved in business-to-business communications and transactions with NuVerge (as described in the Your California Consumer Privacy Rights section above), and you wish to exercise one of your CCPA rights, please send an email to privacy@nuverge.com and include your name, your specific request, and a preferred contact method (e.g., email or mail) for us to follow up with you.

You may call 1-720-574-1815 and ask to be connected to our Chief Privacy Officer. Ultimately though, we will instruct and require you to submit your request in writing, for us to keep appropriate records, and because the law requires us to respond to you in writing. Please start by contacting us at privacy@nuverge.com to expedite the process.

Please see the section below for what to expect once you contact us.

WHAT TO EXPECT WHEN YOU SUBMIT A REQUEST TO US

We are a professional services firm, dealing almost exclusively with other companies, as opposed to directly with consumers as that term is usually understood, in business-to-business transactions; and the protection of our clients’ information (past, present, and future) is paramount to our corporate values and our privacy program.

We take data security, in addition to privacy, very seriously, and California law is clear on the need for businesses to protect all consumers from fraudulent requests made by someone other than the actual individual.

We mention this to prepare you for the fact that if you request from us specific pieces of personal information collected about you, we will do whatever is reasonably necessary (as the law allows and requires) to verify that you are who you say you are; and as such, you should expect a thorough and personalized vetting process from us to ensure that we do not provide one individual’s personal information to an imposter. The process may take 45 days (or longer when reasonably necessary) depending on the request, and consistent with our obligations under the law.

CALIFORNIA DO NOT TRACK DISCLOSURES

When you visit a website (such as NuVerge’s website), your browser automatically shares certain information with that website, such as your IP address and other device information, which may also be considered Personal Data under applicable laws. Some of this data may also be sent to service providers (for example: advertisers, website analytic companies, etc.) that provide content on the website. Such sharing may allow the website and/or content providers to track you over time and across multiple websites. At this time, NuVerge’s website does not respond to Do Not Track beacons sent by browser plugins as there is not yet a common agreement about how to interpret Do Not Track signals from browsers. Please visit our Cookie Policy to learn even more about cookies and similar technologies.

PERSONAL INFORMATION WE COLLECT ABOUT CONSUMERS

We may collect the below categories of personal information about consumers.

In the table below, we have used the CCPA categories of Personal Information and provided basic explanations in plain English for each of those categories. Our responses are divided below into the three broad categories of individuals (or “consumers”) with whom we work every day, and to whom this Privacy Statement applies: (1) leads (a/k/a potential clients/customers), (2) clients/customers, and (3) job applicants.

Regarding any of the above categories of personal information that we process, NuVerge may disclose that information for a business purpose. NuVerge uses service providers, like all organizations. And those service providers may process Personal Information for operational purposes – such as detecting or protecting against security incidents, auditing, and performing services on behalf of NuVerge. For personal information that belongs to our clients, if the clients allow us to use “subcontractors,” then we may be disclosing personal information to those subcontractors which are acting as service providers, as part of our contractual performance on behalf of clients.