Privacy Policy

Privacy Policy
Nicole Consultancy Pte Ltd (NICOLE CONSULTANCY) believes strongly that every person has the right to privacy. When accessing our website, services and/or products, you may be required to give us certain information. NICOLE CONSULTANCY asks for and maintains information on its visitors and customers to provide a better, more personal experience. This privacy statement describes the conduct and practices of NICOLE CONSULTANCY as it applies to all our clients and visitors.
1. User Information
1.1 NICOLE CONSULTANCY collects User Information when you use certain NICOLE CONSULTANCY solutions, products and/or services, when you visit our web pages or micro site web pages.
1.2 ”User Information” means any information that may be used to identify an individual or entity, including, but not limited to:
(a) Identification data (for example, first and last name, email address, home, postal or other physical address, e-mail address, mobile phone number, telephone number, other contact information, title, birth date, gender, personal interests, other information needed to provide a service you requested;
(b) Electronic identification data (for example, IP addresses, cookies phone information, country information and network information;
(c) Payment related information;
(d) Survey results;
(e) Information about your usage of and interaction with the NICOLE CONSULTANCY website, solutions, products and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our websites;
(f) Solutions, products and/or services ordered and delivered;
(h) List of your contacts;
(i) Your user profile including your username and password;
(j) If you give us your username and password for other email accounts where you have provided this to us and requested us to search for your friends on NICOLE CONSULTANCY (Please note that NICOLE CONSULTANCY does not retain this information or use it for any other purpose);
(k) Correspondence between you and NICOLE CONSULTANCY
(l) Traffic data (data processed for the purpose of the conveyance of communications or the billing thereof, including, but not limited to, the duration of the call, the number calling and the number called);
(m) Transaction data including without limitation, data relating to the consumption, top-up, expiry and transfer of credits;
(n) Business financial information; and
(o) Any content that is required by any applicable laws or regulatory authorities.
1.3 When you browse our website, you do so anonymously, unless you have previously indicated that you wish NICOLE CONSULTANCY to remember your login and password. We do not automatically collect User Information, including your email address. Like many other commercial website, the NICOLE CONSULTANCY website may use a standard technology called a “cookie” to collect information about how you use the site. Please go to “Cookies and Tracking Technology” below for more information.
1.4 NICOLE CONSULTANCY collects certain User Information when you register with NICOLE CONSULTANCY for an NICOLE CONSULTANCY account, when you use certain NICOLE CONSULTANCY solutions, products and/or services, when you ask to be included in an email or other mailing list, or when you submit User Information to NICOLE CONSULTANCY for any other reason. From time to time, NICOLE CONSULTANCY receives User Information from business partners and vendors. NICOLE CONSULTANCY only uses such information if it has been collected in accordance with acceptable privacy practices consistent with this Privacy Policy and applicable laws.
1.5 Access to certain NICOLE CONSULTANCY web pages may require a username and a password. The use of those web pages, and the information or programs downloadable from those sites, and solutions, product and/or services available from NICOLE CONSULTANCY’s web pages shall be governed by the Terms of Use and this Privacy Policy. Unless you request deletion of User Information as specified below, User Information may be retained by NICOLE CONSULTANCY to verify compliance with the Terms of Use and this Privacy Policy, log software licenses granted, to track software, solutions, product and/or services downloaded from those web pages, or track usage of other applications, solutions, product and/or services available on those web pages.
1.6 When you install certain NICOLE CONSULTANCY mobile applications, you may be asked to provide your phone number and to allow us access to your address book. A copy of your address book will be stored on our servers and will be used strictly for the following purposes:
(a) notify you when your contacts become active on NICOLE CONSULTANCY;
(b) indicate which of your contacts are already NICOLE CONSULTANCY users;
(c) correctly display the name of each contact as it appears in your address book when a call or SMS is received;
(d) synchronize your contacts between various NICOLE CONSULTANCY applications to provide contacts suggestions when you need to make a call or send an SMS.
1.7 You may have the right to access and, if necessary, to rectify your User Information.

2. Notice
2.1 When User Information is collected, we will inform you at the point of collection the purpose for the collection.
2.2 NICOLE CONSULTANCY will not transfer User Information to third parties without your consent, except under the limited conditions described under the discussion entitled “Information Sharing and Disclosure” below.
2.3 If you choose to provide us with User Information, we may only transfer that information, within NICOLE CONSULTANCY or to NICOLE CONSULTANCY’s third party service providers with your permission.
2.4 Upon receiving your permission, we may transfer your information across borders and from your country or jurisdiction to other countries or jurisdictions around the world.

3. Opt-Out Policy
3.1 We will always give you the opportunity to “opt out” of receiving direct marketing or market research information. This means we assume you have given us your consent to collect and use your information in accordance with this Privacy Policy unless you take affirmative action to indicate that you do not consent, for instance by
(a) clicking or checking the appropriate option or box at the point of collection; or
(b) by e-mailing us at [email protected].
3.2 In some cases, when applicable, we will provide you with the opportunity to “opt in.” This means we will require your affirmative action to indicate your consent before we use your information for purposes other than the purpose for which it was submitted.
3.3 NICOLE CONSULTANCY is not responsible for removing User Information from the lists of any third party who has previously been provided your information in accordance with this Privacy Policy.
3.4 You may also ask NICOLE CONSULTANCY and its group of companies to stop processing User Information. However, please note that this will most likely prevent you from using some or all of our solutions, products and/or services since NICOLE CONSULTANCY must use User Information in order to provide you with our solutions, products and/or services. You can exercise your right to prevent further processing of User Information by contacting NICOLE CONSULTANCY at [email protected].

4. Cookies and Tracking Technologies
4.1 NICOLE CONSULTANCY automatically receives and records information on our server logs from your browser. NICOLE CONSULTANCY employs cookies in order for its server to recognize a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
4.2 Cookies are small text files placed in the ‘Cookies’ folder on a visitor’s hard disk and allow for NICOLE CONSULTANCY to remember the visitor. The cookies placed by the NICOLE CONSULTANCY server are readable only by NICOLE CONSULTANCY, and cookies cannot access, read or modify any other data on a computer. All web-browsers offer the option to refuse any cookie, and if a visitor refuses the NICOLE CONSULTANCY cookie then NICOLE CONSULTANCY does not gather any information on that visitor.
4.3 NICOLE CONSULTANCY cannot and will not gather information about other sites the visitor has been on. At times, NICOLE CONSULTANCY may ask for more specific contact information to be entered as a means of registration before accessing a certain part of the site. NICOLE CONSULTANCY uses this information to understand its visitors and, with permission, to provide visitors with updates on the company and its solutions, products and/or services.

5. Information Usage
5.1 Our primary purpose in collecting User Information is to provide you with a safe, smooth, efficient, and customised experience. NICOLE CONSULTANCY collects and uses, or has third party service providers acting on NICOLE CONSULTANCY’s behalf collecting and using, User Information relating to you, as permitted or necessary to:
(a) provide communication products, in particular to convey the communications you make by means of our solutions, products and/or services;
(b) process transactions and payment for the purchase of credits;
(c) offer or provide other solutions, products and/or services to you from time to time;
(d) provide you with customer support and troubleshoot problems;
(e) compare information for accuracy;
(f) inform you about service updates and faults;
(g) request feedback or participation in on-line surveys;
(h) resolve disputes;
(i) verify your identity;
(j) customize, measure, and improve our website, solutions, products and/or services;
(k) to improve our search functionality and help you find contacts more easily;
(l) organise and carry out marketing or promotional operations, offers, contests, games and similar events; and
(m) protect both yours and NICOLE CONSULTANCY’s interests, including fraud detection and enforcement of our Terms of Use.
5.2 NICOLE CONSULTANCY and, where relevant, the NICOLE CONSULTANCY group companies will retain User Information for as long as is necessary to carry out any of the purposes set out in this Privacy Policy and to comply with applicable laws and orders of competent authorities.

6. Information Sharing and Disclosure
6.1 User Information may be stored and processed in any country in which NICOLE CONSULTANCY and its group companies maintain facilities. In this regard, or for purposes of sharing or disclosing User Information in accordance with this Privacy Policy, NICOLE CONSULTANCY reserves the right to transfer User Information outside of your country of residence. By using NICOLE CONSULTANCY’s website, solutions, products and/or services you consent to any such transfer of User Information outside of your country of residence. Such User Information may be subject to supervision by the regulatory authorities in each jurisdiction where Services are performed or User Information resides, as well as in the jurisdiction of your residence or citizenship. If you are a resident of the European Union, such other countries may not offer adequate protection for the purposes of Directive 95/46/EC of the European Union.
6.2 In order to provide you with NICOLE CONSULTANCY solutions, products and/or services you have requested, NICOLE CONSULTANCY may sometimes, if necessary, share some of User Information and traffic data with NICOLE CONSULTANCY group companies, carriers, partner service providers and/or agents, for example the PSTN-VoIP gateway provider, Wifi access services providers, distributors of NICOLE CONSULTANCY solutions, products and/or services, and/or the third party banking organizations or other providers of payment, email delivery, analytical services, customer support, or hosting services. NICOLE CONSULTANCY will always require these third parties to take appropriate organizational and technical measures to protect User Information and traffic data and to observe applicable laws. NICOLE CONSULTANCY group companies are governed by this Privacy Policy or are bound by appropriate confidentiality and data transfer agreements.
6.3 Some NICOLE CONSULTANCY solutions, products and/or services may be co-branded and offered together with or via a partner company. If you register for or use such solutions, products and/or services, you consent to both NICOLE CONSULTANCY and the partner company’s use of some of the User Information collected in connection with the co-branded product, as necessary. NICOLE CONSULTANCY may offer its website, solutions, products and/or services in connection with other websites, solutions, products and/or services or may team with other online services to give you the combined results of both solutions, products and/or services or additional solutions, products and/or services and benefits. To determine whether you would benefit from the combined offer, if you have provided your consent, NICOLE CONSULTANCY may match your email address and/or phone number, and email addresses and/or phone number of your contacts against email addresses and/or phone number you have provided to the third party website/service provider.
6.4 Within NICOLE CONSULTANCY, User Information and traffic data are stored in controlled servers with limited access. NICOLE CONSULTANCY shall not share, sell, rent, trade or otherwise transfer any personal and/or User Information, traffic data and/or communications content to any third party without your explicit permission, except as provided in this Privacy Policy.
6.5 NICOLE CONSULTANCY may send User Information to other companies or people under any of the following circumstances:
(a) when we have your consent to share the User Information;
(b) we need to share your information to provide the solutions, products and/or services that you have requested; and
(c) we need to send the User Information to third parties who on behalf of NICOLE CONSULTANCY provide solutions, products and/or services to you (we will only provide such third parties the relevant information required for the delivery of the solutions, productions and/or services, and the third parties are prohibited from using such User Information for any other purpose).
6.6 NICOLE CONSULTANCY considers any and all messages transmitted via our webpages, solutions, products and/or services to be private communication between our customer and the recipient. You agree that NICOLE CONSULTANCY may monitor, edit or disclose the content of our customer’s private communications, and/or disclose User Information to third parties:
(a) as required by applicable laws, to comply with legal process or by the order of competent authorities;
(b) where necessary to enforce the Terms of Use and/or this Privacy Policy;
(c) to respond to legal claims that the customer violated the rights of third parties; or
(d) to protect the safety, interests, rights or property of NICOLE CONSULTANCY or others.
6.7 You acknowledge, understand and agree that NICOLE CONSULTANCY may in its sole discretion cooperate with any affected third party by providing information and/or data in either a civil or criminal forum if you violate the provisions of the Terms of Use and/or the Privacy Policy. You acknowledge, understand and agree that NICOLE CONSULTANCY does not endorse the content of any customer communications and NICOLE CONSULTANCY is not responsible or liable for any unlawful, harassing, libellous, privacy invading, abusive, threatening, harmful, vulgar, obscene, tortuous, or otherwise objectionable content, or content that infringes or may infringe upon the intellectual property or other rights of another.
6.8 We also may use User Information to keep you updated on our latest solutions, products and/or services announcements, software updates and special offers or other information you may be interested to hear about from us unless you have opted out of these types of communications.
6.9 As NICOLE CONSULTANCY continues to develop its business, NICOLE CONSULTANCY may sell or buy subsidiaries or business units. In such transactions as well as in the event that all or substantially all of NICOLE CONSULTANCY’s assets are acquired by a third party, User Information of NICOLE CONSULTANCY users will generally be one of the transferred business assets. We reserve the right to include User Information, collected as an asset, in any such transfer to a third party.

7. Data Security
7.1 NICOLE CONSULTANCY account information is password-protected for your privacy and security. NICOLE CONSULTANCY has implemented reasonable security policies, rules and technical measures to safeguard the security of User Information and the data you send us with physical, electronic, and managerial procedures. While NICOLE CONSULTANCY strives to protect User Information, we cannot ensure the security of the information you transmit to us, and we urge you to take every precaution to protect your personal information when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
7.2 You undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorized person, and to inform us as soon as reasonably practicable at [email protected] if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorized transactions have taken place. NICOLE CONSULTANCY is not liable for any damages resulting from any security breaches, on unauthorized and/or fraudulent use of your username and password.

8. Anti-Spyware Policy
8.1 NICOLE CONSULTANCY believes that spyware is a threat to customer privacy and a customer’s experience online.
8.2 Spyware refers to any executable software application that is installed on a user’s personal computer and covertly gathers and transmits User Information through the user’s Internet connection without the knowledge or consent of the user. Cookies and web beacons are not considered spyware. Spyware may gather User Information, such as e-mail addresses and credit card information, and may even alter personal computer settings.
8.3 Intentional use of spyware by any NICOLE CONSULTANCY employee, agent, partner, or affiliate on NICOLE CONSULTANCY’s behalf will not be tolerated and will be considered grounds for dismissal, contract termination, and/or loss of payment.

9. Anti-Spam Policy
9.1 NICOLE CONSULTANCY has zero tolerance for spam. If you receive spam messages and want to report it to NICOLE CONSULTANCY, please forward the message you have received to [email protected].

10. Third Party Sites
10.1 NICOLE CONSULTANCY’s website may contain links to other web sites operated by third parties.
10.2 NICOLE CONSULTANCY does not share User Information with those third party websites and is not responsible for their privacy practices. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
10.3 NICOLE CONSULTANCY will not be responsible for your actions or omissions on third party websites including without limitation your violation of any privacy policies of the third party website.

11. Contacting You
11.1 NICOLE CONSULTANCY may contact you to notify you of issues and faults with our solutions, products and/or services, and if you are considered to have breached any of the terms of the Terms of Use and/or Privacy Policy, or if another person makes a complaint about your use of our solutions, products and/or services.
11.2 NICOLE CONSULTANCY may occasionally ask you to provide information on your experiences with our solutions, products and/or services. Any such feedback will always be voluntary and will be used only for the purposes of measuring and improving the quality of our solutions, products and/or services and not stored as User Information or combined with other User Information.

12. Changes to Privacy Policy
12.1 NICOLE CONSULTANCY may, at its sole and absolute discretion, amend this Privacy Policy from time to time. If we make any substantial changes in the way we use User Information we will make that information available by posting a notice on this web site or by publishing the modified Privacy Policy.
12.2 It is your responsibility to review the terms of this Privacy Policy from time to time, particularly if the most recent revision date is after the date on which you last reviewed them.
12.3 Any changes will become effective as specified in the notice. If you access the web site and/or use the solutions, products and/or services after notification of a change in this Privacy Policy, you will be bound by all such changes.

Last modified date: 1st April 2015