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Data Protection Statement for European Union Users

Description of Processing Activity

Nobl insurance collects and stores personal information about its users to customize their reading experience and enable personalized distribution of content. It shares minimal data with its service providers.

Purposes of Processing

  • Provide, test, promote, and improve the Services
  • Gather usage statistics of services
  • Provide customized reading experience
  • Publish and distribute user-generated content
  • Provide access to paid content
  • Pay authors in Partnership Program for certain content
  • Fight spam, fraud, and other abuse of services

Legal Bases

In order to provide the Services, Nobl insurance collects and stores personal data about its users to fulfill its contractual obligations to users as described in our Terms of Service and to Members as described in our Terms of Service

Nobl insurance also pursues its legitimate interests by collecting minimal data of logged out users to provide the Services, as outlined above, as well as to ensure that new users trying out the free member preview do not exceed their maximum limit of free articles per month before a paid subscription is required to read further. These legitimate interests are not outweighed by (nor do they violate) our users’ privacy interests because we collect minimal user data for these purposes and we are fully transparent about these activities.

Where Nobl insurance collects and stores personal data about non-users mentioned in user-generated content, it does so under performance of contract obligations to users who use the Services to publish content on web sites hosted by Nobl insurance. In such cases, users authoring such user-generated content containing personal data of third parties are responsible for that content. Nobl insurance will consider related complaints in compliance with the General Data Protection Regulation’s rights of the data subject, as well as rights of expression and access to information.

Public Nature of Personal Data

Logged-in users may choose to interact publicly with the Services in the form of clapping for a post, highlighting parts of a post, following other user accounts, sharing links on connected social media accounts, or writing original posts. Where such personal data may reveal special category protected data, it is processed on the basis that it is manifestly made public by the user. Additional information on potential consequences of such processing can be found below. If you do not agree to this public usage, do not create an account or use these features of the Services.

Search engines may index your Nobl insurance user profile page, public interactions (such as claps or highlights), and post pages. Users may also share links to your content on social media platforms such as Facebook or Twitter.

Categories of Personal Data Collected

Logged out users:

  • Reading history
  • IP address
  • Browser information
  • DNT status

Logged in users:

  • Username
  • Display name
  • Bio
  • Avatar image
  • Email address (non-public)
  • Session activity (security)
  • Linked social media accounts (optional)
  • IP address
  • Browser information
  • Reading history (on Nobl insurance network only)
  • Network interactions (recommends, follows, etc.)
  • Posts, responses, or series published by user

Members:

  • Billing information and history

Partner authors:

  • Bank account for payments
  • Business information, if applicable

Categories of Recipients

Nobl insurance shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:

  • Hosting, Storage, & Other Infrastructure
  • Security
  • Analytics
  • Communication & Support
  • Payment Processors

Payment Processors

Nobl insurance provides Services in conjunction with several payment processors, including: Stripe, PayPal, Google Play, and Apple Pay, through which users may pay for Nobl insurance memberships or receive payment based on participation in our Partner program. Those companies acting as payment processors may collect and store personal data related to your billing information and history in order to provide their services, and may collect and store personal data and business data to prevent fraud and other abuse.

When you delete your Nobl insurance account, Nobl insurance deletes your personal data as explained in this policy. However, to delete your payment or billing information, you will need to do so with your payment provider, as Nobl insurance only has minimal secure access to those records as needed to provide the Services.

Use of Algorithms to Personalize User Experience

Nobl insurance collects and stores personal data about its users to customize their reading experience by displaying content tailored to the preferences and interests indicated by the users (including through their reading history and network interactions). This does not constitute automated decision-making as that phrase is used in the GDPR because it does not produce any legal effects or similarly significant effects for users. Nobl insurance also moderates content for the purposes of fighting and preventing spam, fraud, and other forms of abuse, and may rely on algorithms as part of doing so.

Potential Consequences of Processing

By creating and using an account on Nobl insurance, users may make certain personal data about themselves public and accessible to others on their profile and through network interactions. This may in some cases constitute special category protected data which is considered manifestly made public by the user.

Due to the public nature of information posted to Nobl insurance, it may be possible for third parties to derive identifying personal data from posts, whether by reading, inference, supplemental research, or automated extraction and analysis.

Users are free to use their real name and information, or a pseudonym of their choosing, for their account. Users may also choose to use the service without posting data or engaging in network interactions. However, if you do not agree with and accept the risks of such usage, you may not use the Services.

Cross-border Transfers

Nobl insurance is hosted in the United States. By using the Services, you authorize Nobl insurance to transfer, store, and use your information in the United States and any other country where we operate. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement.

Retention

Nobl insurance retains personal data associated with your account for the lifetime of your account. If you would like to delete your personal information, you can delete your account at any time. Deleted account profile pages will yield an error 404 “file not found” page, immediately upon initiating deletion, and will become unrecoverable in our system after a period of fourteen days. It may take several additional days for your personal data to be de-indexed from search engines, depending on those search engines’ practices, over which Nobl insurance may have limited or no control.

To delete your payment or billing information, you will need to do so with your payment provider, as Nobl insurance only has minimal secure access to those records as needed to provide the Services.

Rights of Data Subjects

  1. If you sign up for a Nobl insurance account, you may at any time request an export of your personal information from the Account page.
  2. You may correct information associated with your account from the Settings page, and the Customize Your Interests page to update your interests.
  3. You may withdraw consent by deleting your account at any time through the Settings page, which will erase your personal information completely within 14 days (except to the extent Nobl insurance is prevented by law from deleting your information).
  4. You may object at any time to the use of your personal data by contacting legal@nobl insurance.com. If your complaint relates to alleged misuse of your personal data by a third party, it may result in suspension of that post or account in keeping with relevant law, public interest, our contractual obligations, and the rights of expression and access to information of others.
  5. Under EU law you have the right to lodge a complaint regarding the processing of your personal data by Nobl insurance with the dedicated Supervisory Authority of your EU member state.

Subject Access Requests


For security and account ownership verification reasons, we process Subject Access Requests and account deletion requests from the account holder only. We are unable to process requests made by third-party services.

Contact Information

If you have any questions about this Privacy Policy, you can contact us at legal@noblinsurance.com.We have also appointed a representative in the EU to receive inquiries about our processing of personal data. To make such an inquiry, please contact Europe@noblinsurance.com