Privacy Policy
This policy covers the two NakamaCyber services: the application dev.nakamacyber.com, which provides the service (accounts, assessments, subscriptions), and the website nakamacyber.com, which presents it and receives your requests. Each has its own part; the sections on transfers outside the European Union and on your rights apply to both.
Data controller
Nakama, Sociedade por Quotas, Lda, Rua Arca de Noé, n.º 494, R/C Esq., 4400-367 Vila Nova de Gaia, Portugal, represented by its managing director, Azziz ERRIME.
The application (dev.nakamacyber.com)
The following sections concern accounts created in the application: developers, companies and subscribers.
Data we collect
Account data (email, name, optional info), quiz results and statistics. We never sell your data.
Purposes
To provide the quiz service, track your progress, and — for company accounts — let your company administrator view aggregated team results.
Legal basis
Performance of the service you requested and of the contract, compliance with our legal obligations and, for optional uses, your consent.
Hosting & processors
Data is processed through Google Firebase (Google Cloud): Authentication and the Firestore database are provided by Google. Payments for the paid plans are processed by Stripe, which receives only the data necessary for payment and invoicing; NakamaCyber retains no card data.
Retention
Account data is kept while your account remains active. Billing records are kept for the statutory retention period for accounting documents, even after your account is closed.
The website (nakamacyber.com)
The following sections concern the public website, which you can browse without an account.
Contact requests and waiting lists
When you write to us through the website form, we receive what you enter: for example your name, work email address, company, team size, the plan you are considering and your message. For a waiting list, we receive your email address and the information requested on the form.
The form also sends the address of the page you sent it from and, if you accepted audience measurement, the identifier stored in the hubspotutk cookie, which links your request to your visits.
This information is stored in HubSpot, our customer relationship management tool, in an account hosted in HubSpot’s European Union data centre (Germany).
Required fields are marked on the form: without them, we cannot handle your request. The others are optional.
Purposes and legal bases
- Answering your request (question, quote, subscription): steps taken at your request before entering into a contract (Article 6(1)(b) GDPR) or, for a simple question, our legitimate interest in answering the messages we receive (Article 6(1)(f)).
- Letting you know when an offer announced on the website launches, if you join its waiting list: your consent (Article 6(1)(a)), which you can withdraw at any time by writing to us.
- Measuring the website’s audience (pages viewed, where visits come from) and linking your visits to your contact request: your consent (Article 6(1)(a)), collected through the cookie banner. Details are in the Cookie Policy.
- Serving the website’s pages and protecting it against abuse: our legitimate interest (Article 6(1)(f)). To do so, the hosting provider processes your IP address and technical connection data.
Recipients
- HubSpot: forms, customer relationship management, consent banner and audience measurement.
- Google, through Firebase Hosting: hosting and delivery of the pages.
- Google, through Google Analytics 4: audience measurement, only if you accept it.
- At Nakama, only the people who handle your request can access it. We never sell your data.
Retention periods
- Contact requests: three years after our last exchange, then deleted. If you become a customer, the application’s rules apply.
- Waiting list: until the announced offer launches, or until you withdraw your consent if that happens first, and no longer than 24 months after you sign up; then deleted.
- Trackers: their lifetimes are listed in the Cookie Policy. Your choice in the banner is remembered for six months.
- IP address and technical connection data: processed by Google while serving the pages; we do not keep them.
Transfers outside the European Union
Some of our providers are US companies. As a result, part of the data from the application and the website is processed, or may be accessed, outside the European Union:
- Google (Firebase), for the application: Firebase Authentication, which handles sign-in, processes login data (email address, password) exclusively in the United States. The Cloud Firestore database stores the application’s data (profile, results, statistics) in the European Union (eur3 multi-region: Belgium and the Netherlands), and the application’s server functions also run in the European Union (Belgium).
- Google (Firebase Hosting), for the website and the application: pages are delivered from Google’s worldwide infrastructure, which may process your IP address and technical connection data in any of its data centres.
- Stripe, for payments on the paid plans: Stripe may transfer payment and invoicing data to other countries, including the United States.
- HubSpot, for the website’s forms and audience measurement: the account is hosted in the European Union (Germany), but HubSpot, Inc. and its affiliates may access or process part of the data outside the European Union (support, security, service usage statistics).
- Google, through Google Analytics 4, for the website’s audience measurement, only if you accept it: data may be processed in the United States.
These transfers rely on the EU–US Data Privacy Framework, which the European Commission found adequate on 10 July 2023 and to which Google LLC, Stripe, Inc. and HubSpot, Inc. have signed up, and on the European Commission’s standard contractual clauses included in their data processing terms. To obtain a copy of these safeguards, write to us at contact@nakamacyber.com.
Your rights
You may access, rectify or request deletion of your data and object to processing by contacting the DPO.
For both the application and the website, you may also ask us to restrict processing, request the portability of your data, and withdraw any consent at any time, without affecting processing already carried out. Write to the Data Protection Officer at contact@nakamacyber.com: we reply within one month. If we have reasonable doubts, we may ask you to confirm your identity.
Complaints
If you believe your rights are not being respected, you can lodge a complaint with the Comissão Nacional de Proteção de Dados (cnpd.pt), the data protection authority of Portugal, where our company has its registered office, or with the authority of the country where you live or work (see the list on the European Data Protection Board website).
Contact
Data Protection Officer: Azziz ERRIME.
Contact: contact@nakamacyber.com.
Changes
We update this policy when our processing changes. The date at the top of the page is that of the version in force.