Last updated: December 1, 2023
The privacy of your data—and it is your data, not ours!—is a big deal to us. In this policy, we lay out: what data we collect and why, how your data is handled, and your rights with respect to your data. We promise we never sell your data: never have, never will
This policy applies to our handling of information about site visitors, prospective customers, and customers and authorized users (in relation to their procurement of the services and management of their relationship with Noustro). We refer collectively to these categories of individuals as “you” throughout this policy.
What we collect and why
Our guiding principle is to collect only what we need. Here’s what that means in practice:
Identity and access
When you sign up for a Noustro product, we ask for identifying information such as your name, email address, and other information. That’s so you can personalize your new account, and we can send you product updates and other essential information. We may also send you optional surveys from time to time to help us understand how you use our products and to make improvements. We can send you our newsletter and other updates. We sometimes also give you the option to add a profile picture that displays in our products.
We’ll never sell your personal information to third parties outside Noustro companies, and we won’t use your name in marketing statements without your permission, either.
The app allows you to add contacts to seek feedback from them and also to provide feedback to others.
Noustro applies a patent-pending anonymous assessment processing algorithm to ensure anonymity to increase the data’s trust, veracity, and credibility. As soon as the assessment data is processed, the score and the individual identity of the assessment provider are separated, and store those records separately. The scores are also available to preview as an average of all the scores. We ensure at our level that the users can’t exactly know the identity of the assessment provider with the provided score.
We store the content you upload, receive, or maintain on servers provided by AWS and Azure in your Noustro product accounts. This is so you can use our products as intended, for example, to create accounts, or request feedback, or view scores. We keep this content as long as your account is active. We don’t have account deletion functionality as of yet.
General Geolocation data
For most of our products, we log the full IP address used to sign up a product account and retain that for use in mitigating future spammy signups. We also log all account access by full IP address for security and fraud prevention purposes, and we keep this login data for as long as your product account is active.
We collect information about your browsing activity for analytics and statistical purposes, such as conversion rate testing and experimenting with new product designs. This includes, for example, your browser and operating system versions, your IP address, which web pages you visited and how long they took to load, and which website referred you to us. If you have an account and are signed in, these web analytics data are tied to your IP address and user account until your account is no longer active. The web analytics we use are described further in the Advertising and Cookies section. We also use 3rd party service providers in this regard, such as Google Analytics and Mixpanel. They store that analytics data on their servers for which they have their own policies.
We may use CAPTCHA services across our applications to mitigate brute force logins and as a means of spam protection. We have a legitimate interest in protecting our apps and the broader Internet community from credential-stuffing attacks and spam. When you log into your Noustro accounts, the CAPTCHA service may evaluate various information (e.g., IP address, how long the visitor has been on the app, mouse movements) to try to detect if the activity is from an automated program instead of a human. The CAPTCHA service then provides Noustro with the spam score results; we cannot access the evaluated information. These services are also provided from 3rd party service providers.
Advertising and Cookies
Noustro runs contextual ads on various third-party platforms such as Google, Reddit, and LinkedIn. Users who click on one of our ads will be sent to the marketing site. Where permissible under law, we may load an ad-company script on their browsers that set a third-party cookie and send information to the ad network to enable evaluation of the effectiveness of our ads, e.g., which ad they clicked and which keyword triggered the ad, and whether they performed certain actions such as clicking a button or submitting a form.
We also use persistent first-party cookies and some third-party cookies to store certain preferences, make it easier for you to use our applications, perform A/B testing, and support some analytics.
A cookie is a piece of text stored by your browser. It may help remember login information and site preferences. It might also collect information such as your browser type, operating system, web pages visited, duration of visit, content viewed, and other click-stream data.
When you email Noustro with a question or to ask for help, we keep that correspondence, including your email address, so that we have a history of past correspondence to reference if you reach out in the future.
We also store information you may volunteer, such as written survey responses. If you agree to a customer interview, we may record the conversation for future reference or use.
How we approach mobile app permissions
We may offer optional desktop and mobile apps for some of our products. Because of how the platforms are designed, our apps typically must request your consent before accessing contacts, calendars, cameras, and other privacy-sensitive features of your device. Consent is always optional; our apps will function without it, though some features may be unavailable. A few exceptions exist where the mobile OS doesn’t force the app to ask for permission.
3rd Party service providers’ policies
We use some third-party services to help run our applications and provide the Services to you. This includes AWS, Azure Cloud, Google products, Mixpanel, and OpenAI.
Humans may rarely view some data
Noustro human looks at your content except for limited purposes, for example, if an error occurs that stops an automated process from working and requires manual intervention to fix. These are rare cases; when they happen, we look for root-cause solutions as much as possible to avoid them recurring. We do our best to balance the responsibility to fix the issue and how much data we need to access throughout the process. We may also access your data if required in order to respond to legal processes.
Your rights with respect to your information
At Noustro, we strive to apply the same data rights to all customers, regardless of their location. Some of these rights include:
Right of Access: This includes your right to access the personal information we gather about you, and your right to obtain information about the sharing, storage, security and processing of that information.
Right to Correction: You have the right to request correction of your personal information.
Right to Erasure / “To Be Forgotten”: This is your right to request, subject to certain limitations under applicable law, that your personal information be erased from our possession and, by extension, from all of our service providers. Fulfillment of some data deletion requests may prevent you from using Noustro services because our applications may then no longer work. In such cases, a data deletion request may result in closing your account.
Right to Complain: You have the right to make a complaint regarding our handling of your personal information with the appropriate supervisory authority.
Right to Restrict Processing: This is your right to request restriction of how and why your personal information is used or processed, including opting out of sale of your personal information. (Again: we never have and never will sell your personal data.)
Right to Portability: You have the right to receive the personal information we have about you and the right to transmit it to another party.
Right to Non-Discrimination: We do not and will not charge you a different amount to use our products, offer you different discounts, or give you a lower level of customer service because you have exercised your data privacy rights. However, the exercise of certain rights may, by virtue of your exercising those rights, prevent you from using our Services.
Many of these rights can be exercised by signing in and updating your account information. Please note that certain information may be exempt from such requests under applicable law. For example, we need to retain certain information in order to provide our services to you.
In some cases, we also need to take reasonable steps to verify your identity before responding to a request, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name and email address. If we are unable to verify you, we may be unable to respond to your requests. If you have questions about exercising these rights or need assistance, please contact us at [firstname.lastname@example.org](mailto:email@example.com), If an authorized agent is corresponding on your behalf, we will need written consent with a signature from the account holder before proceeding.
Depending on applicable law, you may have the right to appeal our decision to deny your request, if applicable. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority. If you are in the EU or UK, you can contact your data protection authority to file a complaint or learn more about local privacy laws.
How we secure your data
All data is encrypted via [SSL/TLS](https://en.wikipedia.org/wiki/Transport_Layer_Security) when transmitted from our servers to your browser or vice versa.
With regard to products, most data are not encrypted while they live in our database (since they need to be ready to send to you when you need them).
What happens when you delete content in your product accounts
In many of our applications, we give you the option to trash content. Anything you trash in your product accounts while they are active will be kept in the trash. The trashed content may remain on our active servers for another 180 days, and copies of the content may be held in backups of our application databases for up to another 180 days after that. Altogether, any content trashed in your product accounts should be purged from all of our systems and logs afterward.
We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collect and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Through this policy, we have provided specific retention periods for certain types of information.
Location of site and data
Our products and other web properties are operated in the United States. If you are located in the European Union, UK, or elsewhere outside of the United States, **please be aware that any information you provide to us will be transferred to and stored in the United States**. By using our websites or Services and/or providing us with your personal information, you consent to this transfer.
When transferring personal data from the EU
The European Data Protection Board (EDPB) has issued guidance that personal data transferred out of the EU must be treated with the same level of protection that is granted under EU privacy law. UK law provides similar safeguards for UK user data transferred from the UK.
There are also a few ad hoc cases where EU personal data may be transferred to the U.S. in connection with Noustro operations, for instance, if an EU user signs up for our newsletter, participates in one of our surveys, or buys swag from our company’s online store, etc. Such transfers are only occasional, and data is transferred under the [Article 49(1)(b) derogation](https://gdpr-info.eu/art-49-gdpr/) under GDPR and the UK version of GDPR.
Changes and questions
We may update this policy as needed to comply with relevant regulations and reflect any new practices. You can view a history of the changes to our policies since mid-2018 [on GitHub](https://github.com/basecamp/policies/commits/master). Whenever we change our policies significantly, we will refresh the date at the top of this page and recommend that our users review the policy from time to time. We may also take any other appropriate steps to notify users.