GDPR

Have some questions about GDPR? Read below to find out everything you need to know. 1. What is the GDPR? Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”), is European privacy legislation that takes effect May 25, 2018. It will replace the existing EU member state laws that implement the EU Data Protection Directive, which has been in existence since 1995. 2. Is the GDPR applicable to Executive Nomad Limited? Executive Nomad Limited is covered by the GDPR in situations where Executive Nomad Limited processes personal data of Executive Nomad Limited customers, including but not limited to customer end users, if those individuals are located in the EU. 3. Is Executive Nomad Limited a Data Controller or a Data Processor? Executive Nomad Limited may operate as either a Data Controller or Data Processor depending on the circumstances. With respect to the personal data of its customers, Executive Nomad Limited generally is a Data Processor and Executive Nomad Limited’ customer is the Data Controller. Executive Nomad Limited customer, the Data Controller, determines the purposes and means of the processing of personal data. Specifically, Executive Nomad Limited customer decides what personal data to share with Executive Nomad Limited in order for Executive Nomad Limited to provide the customer with robust risk score information, certain licensed data, the ability to flag potentially fraudulent activity, and other services as purchased by the customer. In these situations, Executive Nomad Limited, as the Data Processor, processes personal data on behalf of the v customer Data Controller at that company’s direction. Executive Nomad Limited also operates as a Data Controller with respect to certain of its services and/or databases. When Executive Nomad Limited combines personal data from different customers, like many kinds of analytics services, it may do this both as a Data Processor at its customers’ instruction and as a Data Controller itself for the purpose of providing services to all of its customers. For example, Executive Nomad Limited may process and aggregate some of the personal data that a customer shares with Executive Nomad Limited in order to make that personal data part of another database for one or more other services provided to Executive Nomad Limited customers. The personal data shared may be combined with personal data elements chosen and provided by other customers. 4. How does Executive Nomad Limited handle data subject requests to exercise their rights under the GDPR? Where v operates as a Data Processor, Executive Nomad Limited will notify its customer if Executive Nomad Limited receives a request from a data subject to exercise the data subject’s right of access, right to rectification, restriction of processing, erasure (“right to be forgotten”), data portability, objection to processing, or right not to be subject to automated individual decision making (“Data Subject Request”). Executive Nomad Limited will also assist its customer in responding to a Data Subject Request, where legally required and permissible. Executive Nomad Limited’ customer is responsible for any costs arising from Executive Nomad Limited’ assistance with Data Subject Requests. Where Executive Nomad Limited operates as a Controller, the data subject may contact Executive Nomad Limited directly to exercise their Data Subject Request. Further information is set forth in Executive Nomad Limited’ privacy policy. 5. Where can I find more information about Executive Nomad Limited privacy practices? In Executive Nomad Limited privacy policy, available here. The Policy will be updated before May 25, 2018, to include additional provisions relevant to the GDPR. 6. How may I execute a Data Processing Addendum with Executive Nomad Limited? Customers who have agreed to our online End User License Agreement (EULA) do not need to execute a separate Data Processing Addendum. The online EULA contains GDPR provisions.