At NOMO, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. 

Remember that your use of NOMO'S Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. 

You may print a copy of this Privacy Policy by clicking here[1] .

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. Upon such changes, we will alert you to any such changes by placing a notice on the NOMO website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. 

Privacy Policy Table of Contents 

What this Privacy Policy Covers 

Personal Data 

Categories of Personal Data We Collect 

Categories of Sources of Personal Data 

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data 

How We Disclose Your Personal Data 

Tracking Tools and Opt-Out 

Data Security 

Personal Data of Children 

California Resident Rights 

Virginia Resident Rights 

 

Exercising Your Rights under CCPA and VCDPA 

Other State Law Privacy Rights 

Contact Information 

What this Privacy Policy Covers 

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. 

Personal Data 

Categories of Personal Data We Collect 

This chart details the categories of Personal Data that we collect and have collected over the past 12 months: 

Category of Personal Data	Examples of Personal Data We Collect	Categories of Third  Parties With Whom We Share this Personal Data:
Profile or Contact Data	First and last name  Email	Service Providers  Analytics Partners
Device/IP Data	IP address  Device ID  Domain server  Type of device/operating  system/browser used to access the Services	Service Providers  Analytics Partners
Web Analytics	Referring webpage/source  through which you accessed  the Services	Service Providers  Analytics Partners
Geolocation Data	IP-address-based location  information  GPS data	Service Providers  Analytics Partners

Categories of Sources of Personal Data 

We collect Personal Data about you from the following categories of sources: 

You 

When you provide such information directly to us. 

When you create an account or use our interactive tools and Services. 

When you send us an email or otherwise contact us.  

When you use the Services and such information is collected automatically. 

Through Cookies (defined in the “Tracking Tools and Opt-Out” section below). 

If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable. 

Third Parties 

Vendors 

We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support. 

Our Commercial or Business Purposes for Collecting or Disclosing Personal Data 

Providing, Customizing and Improving the Services 

Creating and managing your account or other user profiles. 

Providing you with the products, services or information you request. 

Meeting or fulfilling the reason you provided the information to us. 

Providing support and assistance for the Services. 

Improving the Services, including testing, research, internal analytics and product development. Personalizing the Services, website content and communications based on your preferences. Doing fraud protection, security and debugging. 

Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020 (the “CCPA”). 

Corresponding with You 

Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about NOMO or the Services. 

Sending emails and other communications according to your preferences or that display content that we think will interest you. 

Meeting Legal Requirements and Enforcing Legal Terms 

Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities. 

Protecting the rights, property or safety of you, NOMO or another party. 

Enforcing any agreements with you. 

Resolving disputes. 

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice. 

 

 

 

 

How We Disclose Your Personal Data 

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below. 

Service Providers. These parties help us provide the Services or perform business functions on our behalf. They include: 

Hosting, technology and communication providers. 

Support and customer service vendors. 

Marketing providers. 

Analytics Partners. These parties provide analytics on web traffic or usage of the Services. They include: Companies that track how users found or were referred to the Services. 

Companies that track how users interact with the Services. 

Legal Obligations 

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above. 

Business Transfers 

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices. 

Data that is Not Personal Data 

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.  

Tracking Tools and Opt-Out 

 

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies 

are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s). 

We use the following types of Cookies: 

Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable. 

Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.[GDSVF&H4] [GDS5] 

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work. 

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking here. [GDS6] To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/. 

Data Security 

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure. 

Data Retention 
 

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally. 

For example: 

We retain your profile information and credentials for as long as you have an account with us. Personal Data of Children 

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 13 years of age; if you are a child under the age approved to use the Services in the Terms of Services, please do not attempt to use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 13 years of age, we will delete that information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at help@yesnomo.com. 

California Resident Rights 

If you are a California resident, you have the rights set forth in this section. Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. 

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at help@yesnomo.com. 

Access 

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with the following information: 

The categories of Personal Data that we have collected about you. 

The categories of sources from which that Personal Data was collected. 

The business or commercial purpose for collecting or selling your Personal Data. 

The categories of third parties with whom we have shared your Personal Data. 

The specific pieces of Personal Data that we have collected about you. 

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient. 

Deletion 

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your 

Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request. 

Correction 

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request. 

Processing of Sensitive Personal Information Opt-Out 

Consumers have certain rights over the processing of their sensitive information. However, we do not collect sensitive categories of personal information. 

Personal Data Sales Opt-Out and Opt-In 

We will not sell your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell the Personal Data of minors under 16 years of age. 

Personal Data Sharing Opt-Out and Opt-In 

Under the CCPA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. 

We will not share your Personal Data for cross-contextual behavioral advertising, and have not done so over the last 12 months. To our knowledge, we do not share the Personal Data of minors under 16 years of age for purposes of cross-contextual behavioral advertising. 

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA 

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you. 

Virginia Resident Rights 

If you are a Virginia resident, you have the rights set forth under the Virginia Consumer Data Protection Act (“VCDPA”). Please see the “Exercising Your Rights” section below for instructions regarding how to exercise these rights. Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request. 

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a Virginia resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at help@yesnomo.com.

Access 

 

You have the right to request confirmation of whether or not we are processing your Personal Data and to access your Personal Data. 

Correction 

You have the right to correct inaccuracies in your Personal Data, to the extent such correction is appropriate in consideration of the nature of such data and our purposes of processing your Personal Data. 

Portability 

You have the right to request a copy of your Personal Data in a machine-readable format, to the extent technically feasible. 

Deletion 

You have the right to delete your Personal Data. 

Opt-Out of Certain Processing Activities 

You have the right to opt-out of the processing of your Personal Data for targeted advertising purposes. We do not process your Personal Data for targeted advertising purposes. 

You have the right to opt-out to the sale of your Personal Data. We do not currently sell your Personal Data as defined under the VCDPA. 

You have the right to opt-out from the processing of your Personal Data for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects to you, if applicable. 

Appealing a Denial 

If we refuse to take action on a request within a reasonable period of time after receiving your request in accordance with this section, you may appeal our decision. In such appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under the VCDPA. We will respond to your appeal within 60 days of receiving your request. If we deny your appeal, you have the right to contact the Virginia Attorney General using the methods described at https://www.oag.state.va.us/consumer-protection/index.php/file-a complaint. 

You may appeal a decision by us using the following methods: 

Email us at: help@yesnomo.com (title must include “VCDPAAppeal”) 

Exercising Your Rights under CCPA and VCDPA 

To exercise the rights described in this Privacy Policy, you or, if you are a California resident, your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request. 

We will work to respond to your Valid Request within the time period required by applicable law. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly 

unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. 

You may submit a Valid Request using the following methods: 

Email us at: help@yesnomo.com 

If you are a California resident, you may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. 

Other State Law Privacy Rights 

California Resident Rights 

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; however we do not currently disclose your Personal Data for such marketing purposes. 

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com. 

Nevada Resident Rights 

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. However, we do not currently sell your Personal Data to third parties. 

Contact Information: 

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: 

help@yesnomo.com 

Note to NOMO: The California Privacy Act (CCPA) regulations state that privacy policies and other required notices should comply with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1, which means that this Privacy Policy should be readable by text-to-speech software when posted on your 

site. The American with Disabilities Act (ADA) also requires that all websites (in their entirety) must comply with the Web Content Accessibility Guidelines, so you should design and build your site with these guidelines in mind. 

 

Additionally, per our comment above about ADA accessibility compliance requirements, we recommend using HTML markup that indicates header cells and data cells and defines their relationship so that assistive technologies (such as screen-readers for the visually impaired) can provide context to the reader. 

Cookie compliance has become increasingly burdensome under applicable laws, and it’s easiest to use a cookie management vendor to comply with such requirements. If you are not working with a cookie management provider, please reach out to your Gunderson team. We are happy to provide referrals to trusted providers. 

Note to NOMO: The VCDPA requires controllers to enable an appeal process. This should be customized to your preferred mechanism. 

Note to NOMO: this needs to be updated to state the specific pieces of information a user must provide to allow you to verify the request (by verify, we mean allow you to confirm that the person who is submitting the request – or the person who is the subject of the request, if it is submitted by an agent on someone’s behalf – is the same 

person about whom you have collected data). Ideally, the information required to verify a request will be information that you have previously collected, as opposed to new information that you have not previously collected. If users have password-protected accounts, you can use those login credentials to verify requests.