NNERB Privacy Policy
Last Updated: March 3rd, 2025
1. Introduction and Scope
NNERB ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our website, mobile applications, or related services (collectively, the "Service").
This policy applies to all users of the Service, including Business Owners, Administrators, Employees, and their end-user Clients (as defined in our Terms of Use). By using the Service, you consent to the data practices described in this policy. If you do not agree with the terms of this policy, please do not access or use the Service.
2. Our Role as Data Controller and Data Processor
It is important to understand our role regarding your data:
- NNERB as Data Controller: We act as the "Data Controller" for the personal information of our Business Owners, Administrators, and Employees. This includes account registration data, billing information, and direct communications with us.
- NNERB as Data Processor: When a Business Owner uses our Service to manage their business, they are the "Data Controller" for the personal information of their Clients. In this capacity, NNERB acts as a "Data Processor," processing Client data on behalf of and at the direction of the Business Owner.
3. Information We Collect
We collect information in the following ways:
3.1. Information You Provide to Us Directly
For Business Owners, Administrators, and Employees:
- Account and Profile Information: Name, email address, phone number, business name, username, and encrypted password.
- Financial and Billing Information: Payment card details (processed securely by our third-party payment gateways), billing address, and transaction history related to your NNERB subscription.
For Clients (Collected by Business Owners via the Service):
- Personal Identification Information: Name, email address, phone number, date of birth, and any other information the Business Owner requires for program enrollment.
- Payment Information: Details required to pay for programs or services, processed securely by our integrated payment gateways.
3.2. Information We Collect Automatically (Usage Data)
When you use the Service, we automatically collect certain information:
- Log and Device Information: Your IP address, device type, operating system, browser type, and unique device identifiers.
- Interaction Data: Information about your interactions with the Service, such as pages visited, features used, clicks, time spent on pages, and referring URLs.
- Location Data: We may infer your general geographic location from your IP address.
3.3. Cookies and Tracking Technologies
We use cookies and similar tracking technologies to operate and analyze the Service. For more details, see Section 7 ("Cookies and Your Choices").
4. How We Use Your Information
We use the information we collect for the following purposes:
- To Provide and Maintain the Service: To create and manage accounts, process transactions, facilitate communication between users, and provide customer support.
- To Improve and Personalize the Service: To understand how users interact with our platform, develop new features, and provide a customized experience.
- For Security and Compliance: To monitor for and prevent fraudulent activity, enforce our Terms of Use, and comply with applicable legal obligations.
- To Communicate with You: To send administrative messages, service updates, and, with your consent, promotional materials and newsletters. You can opt out of marketing communications at any time.
- For Aggregated Analytics: To create anonymized, aggregated data for business intelligence and statistical purposes. This data does not identify any individual.
5. How We Share and Disclose Your Information
We do not sell your personal information. We may share it under the following limited circumstances:
- With Service Providers: We share information with third-party vendors who perform services on our behalf, such as payment processing (e.g., WiiPay Caribbean), cloud hosting, data analytics, and email delivery. These providers are contractually obligated to protect your data and use it only for the services they provide to us.
- Between Users: Information is shared between Business Owners and their Clients as a core function of the Service (e.g., an enrollment confirmation shares a Client's name with the Business Owner).
- For Legal Reasons: We may disclose your information if required by law, subpoena, or other legal process, or if we have a good-faith belief that disclosure is necessary to protect the rights, property, or safety of NNERB, our users, or the public.
- In Case of a Business Transfer: If NNERB is involved in a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control of your personal information.
- With Your Consent: We may share your information for other purposes with your explicit consent.
6. Data Security and Retention
6.1. Security Measures
We implement administrative, technical, and physical security measures designed to protect your information from unauthorized access, use, or disclosure. These include data encryption, access controls, and secure server infrastructure. However, no method of transmission over the Internet is 100% secure, and we cannot guarantee absolute security.
6.2. Data Retention
We retain your personal information for as long as your account is active or as needed to provide you with the Service. We may also retain information to comply with our legal obligations, resolve disputes, and enforce our agreements. When data is no longer needed, it is securely deleted or anonymized.
7. Cookies and Your Choices
Cookies are small text files stored on your device. We use them to make the Service work and to gather analytics.
- Essential Cookies: These are necessary for the Service to function, such as for user authentication and security.
- Performance and Analytics Cookies: These help us understand how you use the Service so we can improve it.
- Marketing Cookies: These are used to deliver relevant advertising (if applicable) and track the effectiveness of campaigns.
Your Choices: Most web browsers are set to accept cookies by default. You can usually choose to set your browser to remove or reject cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Service.
8. Children's Privacy
While our Service is not directed at children under the age of 13, we understand that Business Owners may use the Service to manage programs for minors. In such cases:
- Responsibility of the Business Owner: The Business Owner, as the Data Controller, is solely responsible for complying with all applicable laws regarding minors' data, including obtaining verifiable parental consent before collecting any personal information from children.
- Our Role: We rely on the Business Owner to obtain this consent. If you are a parent or guardian and believe a Business Owner has collected your child's information without your consent, please contact the Business Owner directly. If you believe NNERB has unknowingly processed such data, please contact us at support@nnerb.com to request its removal.
9. Your Data Protection Rights
In accordance with the Data Protection Act of Trinidad and Tobago and other applicable laws, you have the following rights regarding your personal information:
- Right to Access: You can request a copy of the personal data we hold about you.
- Right to Rectification: You can request that we correct any inaccurate or incomplete data.
- Right to Erasure (Deletion): You can request that we delete your personal data, subject to certain legal exceptions.
- Right to Restrict Processing: You can request that we limit the way we use your personal data.
- Right to Object: You can object to our processing of your data, such as for direct marketing purposes.
- Right to Withdraw Consent: Where we rely on your consent to process data, you can withdraw it at any time.
To exercise these rights, please contact us at support@nnerb.com. We will respond to your request within a reasonable timeframe. If you are a Client, please direct your requests to the relevant Business Owner (the Data Controller) first.
10. International Data Transfers
Your information may be transferred to, and maintained on, computers located outside of Trinidad and Tobago where the data protection laws may differ. By using the Service, you consent to this transfer, storage, and processing of your information in other jurisdictions.
11. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on this page and, where appropriate, by notifying you via email or a platform announcement. Your continued use of the Service after such changes constitutes your acceptance of the new policy.
12. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:
