Privacy Policy

Noctal is committed to protecting and respecting your privacy.

We at Noctal, Inc. (“Noctal,” “us,” “we,” or “our”) want you to feel safe when we process your personal data. This Privacy Notice (“Privacy Notice”) explains how we ensure that your personal data is handled in compliance with applicable legislation and it applies to our processing of personal data, in the capacity of data controller, relating to our customers and users of our services, visitors to our websites, and to other business contacts. We use your personal data to operate our business and meet our obligations and responsibilities in relation to applicable legislation and good industry practice.

If you are a user of our services, one of the following user categories applies to you:

1. a user that signed up for our services independently in our online purchasing portal or applied for our free services, including the free services we offer within the Civic Tier (“Self-Serve User”); or
2. a user invited to use a service by a company or other entity which is a customer of ours (“User of Company Subscriber”), for example if you are invited to use the services by your employer.
3. you applied for a job at Noctal, filled in a survey or otherwise communicate with Noctal — for example through email or social media platforms (“User of Communication Services”).

Please note that some of our processing of personal data differs depending on what User category applies to you, which is why we ensure to always state in our Privacy Notice if the processing only applies for a particular group of users. We only use your personal data for the purposes specified in this Privacy Notice and not in any manner that is incompatible with those purposes.

1. Noctal’s role when processing your data

If you are a User of a Company Subscriber, we process your personal data in the capacity of data processor or service provider, when providing our services to our customer that is a company subscriber (i.e., the entity that invited you to use the service, for example your employer). In relation to such processing, the company subscriber is data controller or business and hence responsible for providing information to you about its processing of personal data and addressing your rights as a data subject. We will endeavor to provide assistance to our customers to address any concerns you may have in accordance with the terms of our contract with such customer. Additionally, for any deidentified data that we collect from you on behalf of our customer or receive directly from a customer in our role as a data processor or service provider, we commit to processing that deidentified data only in a deidentified fashion and will not attempt to re-identify personal data.

Noctal is the data controller for the processing of your personal data other than when we act as a processor or service provider on behalf of a customer that is a company subscriber, as described above. Noctal is responsible for ensuring that the processing is carried out in accordance with applicable legislation. If you have any questions regarding the processing of your personal data, you will find our contact details at the end of this Privacy Notice.

2. Our use of your personal data

2.1 Collection of personal data

2.2 Personal data you provide to us

The personal data that we process about you is data that you have provided us with or that we have otherwise acquired as part of the provision of our services. We collect personal data:

• Business with company subscriber: If you are a User of a Company Subscriber, when we initiate a business relationship with a new company subscriber;
• Account Creation: When you create an account to use our services, create a new user for that account or complete transactions through our websites, such as fulfilling an order for our services;
• Content: When you provide content to our services, e.g. search queries or uploaded files.
• Interaction Data: When you submit user-interaction data, e.g. feedback ratings, to our services;
• Communication Services: When you contact our support team or otherwise communicate with us and share information with us through other means such as online forms, websites, emails sent to and from Noctal, or social media.
• Job Applications: When you apply for a job; or
• Other events: When you seek general information about the company, participate in events or surveys.

2.3 Personal data that we collect from other sources

We may also collect or receive information about you from other sources such as public registers. If you are a User of a Company Subscriber, we may collect personal data provided by the company subscriber, for example when the company subscriber invites you to use the service. We collect personal data from other sources such as:

• If you are a User of a Company Subscriber, the company subscriber;
• Public registers;
• LinkedIn Website Retargeting;
• Google Analytics (Google Ireland Limited);
• Google Workspace APIs (Google Ireland Limited);
• Google Tag Manager (Google Ireland Limited);
• G2 (G2.com);
• Clearbit (APIHub, Inc.);
• Bombora (Bombora, Inc.);
• Mutiny (Mutiny HQ Corporation); and
• Meta Ads conversion tracking (Meta pixel) (Meta Platforms Ireland Ltd).

2.4 The purposes of processing

We use your personal data for the following purposes:

• If you are a Self-Serve User, to provide and manage our services;
• If you are a User of a Company Subscriber, to administer the agreement with our subscriber;
• If you are a User of Communication Services, to communicate with you regarding job offerings, surveys and other communication initiated by you;
• Administration and provision of support services and account services;
• For statistics, analysis, business development and improvement of services;
• To market our services through newsletters, social media, publications, and events;
• To prevent fraud and other abuse;
• To comply with legal obligations;
• To establish and defend legal claims; and
• To reorganize or make changes to our business.

We may also aggregate or de-identify personal data so that it no longer identifies you, and use that information for the purposes described above, such as analyzing how our services are used, improving and adding features to them, and conducting surveys. We will store and use the de-identified information in de-identified form and will not attempt to re-identify it, unless required by law.

3. Contact

If you have any questions about this Privacy Notice or our processing of your personal data, please contact us at privacy@noctal.xyz.