Summary presentation (pdf)

Introduction: Anonymisation and pseudonymization of personal data

At N.Rich (N Technologies Inc.) we take end-user privacy seriously. N.Rich collects and retains personal data in the form of cookies from end-users, our clients want to target, or whose behavior they wish to understand better. We focus strictly on B2B clients, so our objective is to only track and target people based on their association with a company (legal entity).

N.Rich is fully EU General Data Protection Regulation (GDPR) and California Consumer Protection Act (CCPA) Compliant.

We do not want to find out the exact identity of an individual and take active measures to preventing such identification. However, we do have from time to time a possibility of identifying a person through email address for example. In such cases, we never store any such information as such, but take measures to prevent identifying the person through a pseudonymization process (for example discarding or obfuscating the personally identifying part of the data). We honor information requests from end-users bearing in mind that it may be difficult or impossible for us to verify the association of the individual to the data (e.g. in the case of cookie it is expected to require extraordinary measures for a person to verify a one-to-one relationship of his/hers to the cookie).

Understanding N.Rich contractual framework for end-user privacy

The contractual foundation of N.Rich privacy are the following documents:

1. N.Rich Privacy Notice is the agreement between the end-user and N.Rich about the processing of personal data. It is mandatory that end-users accept the terms of N.Rich privacy notice when browsing your website.

2. Section 8, “Data Processing” of N.Rich General Terms, which is a part of N.Rich customer agreement, defines the roles and responsibilities of end-user privacy protection between N.Rich and the customer. A valid agreement between N.Rich and the Customer is mandatory for these roles and responsibilities to be defined.

8. Data Processing

Client warrants that it has the right to disclose the Client Data for the performance of the Service for further Processing by N.Rich in the manner described herein and on N.Rich Privacy Notice.

The Client warrants that when Client website loads the N.Rich Standard Tag, the visiting user has provided Cookie Consent and has had a reasonable possiblity for reviewing the terms of N.Rich Privacy Notice prior to providing the consent, for example through a link on the Client website’s cookie notice. If Cookie Consent has not been provided, the Client must use N.Rich Cookieless Tag. 

In accordance with the Privacy Notice (and unless otherwise set out therein), if the data N.Rich receives includes information that could allow N.Rich to identify the natural person(s) concerned, N.Rich shall, before any further use of the information, take measures to transform the data so that it can either be no longer attributed to a specific Data Subject at all (“anonymization”) or so that it can be attributed to a specific Data Subject only with additional information that is kept strictly separate from and never combined with the said Personal Data (“pseudonymization”). For the avoidance of doubt, if and to the extent any data that has undergone pseudonymization may still be considered as Personal Data, N.Rich shall be considered the Controller for such data, and the data shall be Processed as described in the Privacy Notice. 

To the extent the Service includes the use of Facebook’s Custom Audiences feature, and any personal data received from Client is shared with Facebook for that purpose, Client shall hereby accept and be bound by the Facebook Custom Audiences Terms as available and updated at Facebook’s website (https://www.facebook.com/legal/terms/customaudience).

N.Rich warrants that is shall use Client Data and Other Data only for the purpose of ad targeting, advertisement delivery, audience measurement, traffic analysis or demographic analysis, all to be carried out through the use of the Service. 

Anything herein to the contrary notwithstanding, it is hereby acknowledged that N.Rich does not sell any Personal Data which may derive from such Client Data and/or Other Data to third parties and shall only use it for purposes described in the paragraph above. Without derogating from the generality of the foregoing, in the event that N.Rich sells such Personal Data, it may only do so subject to providing a valid right to Opt-Out.

Legal basis of processing personal data

N.Rich operates using opt-in or “legitimate interest” as the purpose of processing end-user personal data. The main sources for opt-ins are IAB Transparency and Consent Framework (TCF) and client website “cookie consent”.

Cookie consent

N.Rich endorses a best practice of websites to require cookie consent before setting any cookies, which is also going to be a highly likely requirement of the upcoming ePrivacy directive in the EU. The challenge with this approach, however, is that unless consent is given immediately on the landing page tags that are setting cookies won't "fire". This leads into major challenges with analytics especially since the UTM tag and page referrer data is only available on that very first page-load. This is why N.Rich has developed a "cookieless" website tag, which enables getting analytics on the end-user behavior without setting a cookie, by only identifying the IP address and potentially existing cookies set on the browser. 

Once the cookie consent is provided, you should use the standard N.Rich tag that will create a cookie to the user's browser. At the time of creating a cookie, it is mandatory that end users are provided a clear access to N.Rich’s Privacy Notice (https://n.rich/privacy-notice) and to the possibility to opt-out (https://n.rich/optout), for example through the site’s cookie notice or privacy policy.

VARIANT 1:

We work with our partners to provide targeted advertising and behavioural analytics of our current and potential customers. When you visit our website, or engage with a marketing email sent by us, your browsing activities may be tracked through cookies. Cookie-based data may be shared and exchanged with our partners for the aforementioned purposes. You can discontinue this data collection at any time by adjusting your browser settings or by opting out at our partner's site (see below).

Advertising and analytics partner[s]

N Technologies Inc. (https://n.rich) | Privacy notice: https://n.rich/privacy-notice | Opt-out: https://n.rich/optout

VARIANT 2:

N.Rich— These cookies allow us to analyse how you use our website and to show you ads across the internet so that we can provide more relevant content for you. N.Rich permits you to opt out from use of these cookies here and you can read N.Rich Privacy Notice here.

VARIANT 3:

Use of N.Rich ABM Tag On our website we use a N.Rich ABM Tag from N Technologies Inc. (https://n.rich). N.Rich associates end user behaviour data to the specific company's IP address, which is being used for the website visit or that the visitor has used before browsing other websites including N.Rich Tag. Furthermore, N.Rich associates your behaviour to a cookie stored to your browser enabling tracking you on consecutive sessions on our website and on other websites including N.Rich Tag. N.Rich enables us to gather analytical data about your interests towards our content and offerings on our website and on other websites with N.Rich tag. N.Rich further enables us to target personalised advertising to you based on your company association and other data that could help us deliver more relevant content and advertising. The data gathered remains anonymous for us, offering us no way to determine the identity of the users. The data is saved and processed by N Technologies in accordance to N Technologies Privacy Notice: https://n.rich/privacy-notice. You can opt-out at any time from being tracked by N.Rich Tag either by using N.Rich Opt-out form: https://app.nrich.ai/optout/ or by enabling your browsers Do Not Track feature.

Here are some examples of how the recommended information has been added to some of our client's Privacy Notices (in order to review the relevant section, please use find functionality for term: "N.Rich")

• Wärtsilä: https://www.wartsila.com/legal-privacy/cookies

• GE Healthcare: https://www.ge.com/privacy#_Cookies_and_Similar (open "Consent Tool")

When creating or updating our cookie on the end users browser we also create an additional informational cookie that contains a link to our Privacy Notice and Opt-Out ensuring that they are always available for the end-user, regardless of the circumstances. Additionally N.Rich respects browsers' "Do Not Track" (DNT) standard (https://en.wikipedia.org/wiki/Do_Not_Track). N.Rich is also part of IAB’s Transparency & Consent Framework (TCF) (http://advertisingconsent.eu/) and a signatory of IAB CCPA Compliance Framework.

Technical details

Details of the Cookies N.Rich ABM Tag sets

If you have any questions about N.Rich approach to end-user privacy, please feel free to contact: privacy@n.rich