Overview
NoMachine S.à r.l., 21, Rue Philippe II, L-2340, Luxembourg and all its affiliates  (“NoMachine”) expects its employees, including those of its subsidiaries worldwide and third parties with whom NoMachine does business, to maintain the highest standards of ethics and compliance with applicable laws and rules. This Privacy Policy will help you understand what Personal Data NoMachine collects; how it collects, holds, uses, discloses and deletes that information, and the purposes of collection and disclosure. The processing of your Personal Data is carried out in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and related implementing legislation (hereinafter, jointly, the “GDPR”).

Controller
NoMachine S.à r.l., 21, Rue Philippe II, L-2340, Luxembourg is controller pursuant to Art. 4 para. 7 General Data Protection Regulation (“GDPR”) concerning any processing of personal data for which we determine the purpose and means of processing.

Personal Data
The term “Personal Data”, as used in this Policy, refers to any data (whether by itself or when linked with other information in the possession of, or likely to come into the possession of, NoMachine) that can be used to identify a specific person. Below we provide information about the collection of personal data when using this website and the NoMachine product. Personal Data is any data that can personally reference you. Personal Data does not include information that has been aggregated or made anonymous such that it can no longer be reasonably associated with a specific person.

Some specific examples of how we use or may receive your Personal Data:

• - Provide access to the User Area and Support services.
• - Give you access to the NoMachine Network service.
• - Send you information about the products and services that you have purchased from us.
• - Perform direct sales activities in cases where legitimate interest is established.
• - Reply to a ‘Contact Request’ or other web forms you have completed on our website.
• - Follow up on incoming requests (customer support, emails, chats, or phone calls).
• - Perform contractual obligations such as technical assistance, order confirmation, license details,
    accounting activities, subscription reminders.
• - Notify you about any disruptions to our services.
• - Contact you to conduct surveys about your opinion on our products and services.
• - Process a job application if you have sent us your CV.

What NoMachine products or services does this Privacy Policy apply to?
This Policy applies to your use of: (a) NoMachine software that we make available to you; (b) the NoMachine.com website, including the NoMachine User Area website, the NoMachine Forum website and the online store (collectively referred to as the “Website”); (c) all services that we offer in connection with your relationship with us as a customer, including through your use of our Website, your specific User Area and associated support services, and mailing lists; (d) automatic software updates, and (e) your use of NoMachine Network, all collectively referred to as the “Services”.

This Policy does not apply to any website, product or service of any third-party company even if the website links to (or from) our Website. Please always review the privacy practices of any third-party company before deciding whether to provide any information.

Collection and use of your Personal Data
By using the NoMachine Services, NoMachine collects data as deemed appropriate for the fulfillment of the service as described below.

NoMachine Software
NoMachine software is a self-hosted remote access software installed and managed by you. It does not contain analytics tools which gather or log your click activity from your use of the NoMachine software, including “NoMachine Mobile Apps”, collectively “Software”. Furthermore, we explicitly do not log or collect your passwords, mouse clicks, keystrokes, audio, video and other data such as files through your use of the Software. When using the Software, end-to-end encryption means that this data is never available either to NoMachine or to third parties.
For more information about NoMachine Security and Encryption please consult: 

NoMachine Security Statement 
https://www.nomachine.com/AR04S01121

Downloading the Software
NoMachine Software is freely available on our Website and does not require a NoMachine account to install it. There are free standalone applications which can be used without a specific license and that do not require registering for a NoMachine account. The standalone NoMachine Enterprise Software, instead, must be activated with a specific license file for that product which is obtained either by registering for an evaluation license on the Website, or by purchasing a subscription. To do either requires having a NoMachine account.

NoMachine Mobile Apps can be downloaded from Google Play as well as on the Apple App Store (collectively “App Stores”). The App Stores usually provide the app developers (in this case, NoMachine), with statistics of the downloads including ratings of the relevant app. Please note, that this data is provided to NoMachine within the app-store directly based on download and ratings of the users of our app, including you. 

Automatic Updates
NoMachine provides an automatic software update service, so that the Software can notify you if any software updates are available for download. The service of automatic updates can be disabled by the user on each computer where the Software is installed. NoMachine update servers are physically located in multiple datacenters. To provide these updates, NoMachine receives specific information from your device: the version of the Software you are using, the device’s UUID, its system name, OS version and your IP address. 

NoMachine Account
The Software and the Website may be used by you to create a NoMachine account (hereinafter your “NoMachine Account”). This account can be used to access NoMachine Network through the Software. It can also be used to login on the Website to access your User Area and other related services provided through the Website. When you sign up for an account, NoMachine collects your e-mail address (your User Id), along with time, date, and time zone of you signing in and creates a unique identifier for your NoMachine Account. All user credentials are stored and transferred as hashes. When logging in to access the Services through the Software or the Website, your User Id credentials are securely transmitted to our NoMachine servers. More information is available in our Security Statement. None of the data used or generated in relation to your NoMachine Account is made available to third parties or published in public directories. 

NoMachine Two-factor Authentication
Should you choose to add the additional security option of two factor authentication (“2FA”) to your NoMachine Account or use 2FA to protect remote access to your computer, you will need to install the NoMachine Mobile App in order to receive push notifications. We will process the data required to provide this option and to maintain your account and connection security including: push notification identifier, your IP address, User Id used for the login attempt and location, target device name, and Machine and User books information associated to the account logging in. When using 2FA to authorize a remote desktop connection, we will also process the system username of the user connecting. 

NoMachine Network
NoMachine Network is an additional service (“NoMachine Network”) accessible to all Software users with a NoMachine Account.When you login or connect using NoMachine Network or publish a computer on NoMachine Network, we log certain usage information on our NoMachine Network servers which we store only for the time strictly necessary in order to be able to operate and optimize the NoMachine Network Service, gather usage statistics and diagnostic data. NoMachine may collect technical information about your connection to detect possible problems, for example about your specific network connection, and help improve our software and our NoMachine Network Service infrastructure. The following information is logged: your User Id, Machine Id, IP address or hostname, port number, operating system, computer model and system UUID. 

When you choose to connect to the remote desktop using NoMachine Network, the contents of any remote desktop connection, including files you exchange, are not accessed nor collected. This includes key strokes, mouse input and screen content. The credentials you use to login on the desktop are not collected and cannot be seen. Peer-to-peer encryption means that it is therefore impossible for anyone, including NoMachine, your Internet Provider or local authorities, to inspect or record the data travelling between client and server hosts. 
For more information about NoMachine Security and Encryption please consult:

NoMachine Security Statement 
https://www.nomachine.com/AR04S01121

NoMachine VPN
NoMachine doesn't track your activities through the NoMachine VPN and does not store any data related to the traffic going through the VPN service.

NoMachine Software Logs
When you submit a support enquiry, or a request for assistance via any of the applicable contact channels, including the public NoMachine Forums, we may request logs and other attachments such as screenshots to allow our support team and developers to investigate thoroughly. NoMachine logs come from the Software and are not shared with NoMachine unless explicitly submitted by you. These logs may contain IP addresses, usernames and computer names of the affected user sessions. It is possible to blank out the sensitive information before submitting for analysis. By uploading these logs to our secure file server or sending them to us through email, you authorize us to use your personal data exclusively for the requested purpose. 

NoMachine Logs from Mobile Devices with the NoMachine App installed
In the case the user has explicitly enabled logs from the device (e.g crash logs) to be transmitted to the App Store (Google Play or Apple Store), this information is impersonal and for troubleshooting purposes. In that case, NoMachine may collect and process the following information about your device and the NoMachine Software:

• - Non-personal information, such as: brand, manufacturer, model & operating system version.
• - Version and subscription information.

Customer e-mail notifications
When you purchase an Enterprise or Network Subscription, the e-mail address associated to your NoMachine Account is used by us to notify you of important service communications related to your subscription, security advisories or important changes regarding our products and terms of service. It is not possible to unsubscribe from these communications. By submitting your email address, you authorize us to send these e-mail communications. There are other types of e-mails that we send out such as renewal reminders, software update news or information about upcoming products. If you wish to opt out of this type of notifications, please use the unsubscribe link at the end of the respective email.

Payment Information
When purchasing NoMachine products, NoMachine receives your billing address which is stored in your customer area and can be edited at any time. When paying with credit card, your credit card details are handled only by our external online payment provider. We do not store these details and we do not have access to them. 

Support Enquiries
By submitting an enquiry via your User Area in the support section (“Support Portal”), you are authorizing us to correspond with you and accept that we may receive personal information that you decide to include in correspondence with us as content of your support ticket. This may also include logs from the Software and other attachments already mentioned is NoMachine Software Logs. Anything communicated by you online through the Support Portal is stored as part of the online support services we offer.

Contact Request & Report Issues Forms
When you contact us using the form here: https://www.nomachine.com/contact-us we ask for information such as name, email address, phone number, and other details which are optional. By sending a request for contact, you authorize us to use your personal data exclusively for the requested purpose. 

When you submit a bug report via the link https://www.nomachine.com/report-an-issue, you can choose whether to provide us with an email address. By providing us with a valid email address, you authorize us to contact you regarding the issue you wish to report and to use the email address exclusively for the requested purpose. The personal data transferred to us in this context will only be used to process the respective inquiries. 

Mailing Lists
If you sign up to any of our mailing lists, NoMachine Announce and NoMachine News which are used to communicate software releases and company news via email, we may also occasionally email you with information about offers or new services. You can also opt out of these email communications by using the unsubscribe link included in such communications.

NoMachine Forums
By creating a NoMachine Account you are also allowed access to the NoMachine Forum by selecting a nickname or username. If you add topics or comments, upload photos, logs or videos, etc on https://forum.nomachine.com, this information is public and can be read by anyone. If you wish to remove any data from https://forum.nomachine.com, please contact us.

Website Visitors, Cookies and Logs
When you browse our Website, we log the IP address of your last access. We utilise other technologies to collect non-personally-identifiable information from our Website, such as the date and time of visits, the pages viewed, links to/from any page, and time spent at our site. This data is contained in our Web Server Logs to measure web traffic and usage activity on our Website for purposes of monitoring, troubleshooting and improving our Website and Services, to look for possible fraudulent activity, and to better understand the sources of traffic and transactions on our Website. We do not share this information with third parties or use it to target any advertisements to you.

We also let you set the language preference you prefer in order to browse the Website through the use of “Cookies”. Cookies are a feature of web browser software that allows web servers to recognise the computer used to access a website. Cookies can remember what information a computer accessed on one web page to streamline activities on related web pages and to make the online experience easier and more personalized.  When a user sets a language preference and request to remember this setting on our Website, we use a cookie.  This, along with other functional and strictly necessary Cookies in order to make our websites function properly and to display contents in accordance with your location, are the only cookies that NoMachine uses on its Website to customize your experience and keeps that setting for your next visit. You can choose to disable cookies for our Website if you prefer. In that case, your request for a specific language setting will last for the duration of the open browser session, and you can set it again next time you visit. We don’t use any other type of cookie that will ‘personalize’ the experience or target you during your time on our website. 

Storing, Sharing and Disclosure of your Personal Data
NoMachine does not sell or rent your Personal Data to marketers or third parties. NoMachine may disclose the Personal Data it collects about you to trusted third parties that are essential to the operation of our Services, for various purposes related to the provision of those Services. These third parties include our partners, contractors, financial institutions, payment processors, verification services and credit bureaus, as well as any third parties that you have directly authorized to receive your Personal Data. These third parties have access to Personal Information to the extent necessary to permit them to do their jobs, however, they are bound by confidentiality agreements before any Personal Information is provided to them, and they are restricted from retaining, using, or disclosing your Personal Data other than to provide the services requested by us.

We may also store your Personal Data in locations outside the direct control of NoMachine, for instance, on servers or databases co-located with hosting providers. Some of these hosting providers are located outside of Luxembourg. These countries may include the United States of America and the United Kingdom. Any related cross border data transfers will be in compliance with applicable law, and we will ensure that the transfer will be compliant with data protection law and all personal data will be secure.

We may also disclose your Personal Data if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements. We may share your Personal Data if you have violated the law or if it is necessary to protect the rights, property, and safety of NoMachine, our users, the public, or others. If we are going to disclose your Personal Data in response to a legal process, we will give you notice so you can challenge it (for example by seeking court intervention), unless we are prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our Services that we believe are improper.

If we are subject to a merger or acquisition with/by another company, we may share information with them in accordance with our global privacy standards. Should such an event occur, we will require that the new combined entity follow this privacy notice with respect to your Personal Data. If we intend to handle your Personal Data for any purposes not covered in this privacy notice, you will receive prior notification of the processing of your Personal Data for the new purposes. Any sharing or disclosure of your Personal Data will be in compliance with applicable EU data protection laws and regulations.

How Long We Keep Your Personal Data
We retain your personal information for as long as necessary to provide the Services you have requested, or for other essential purposes such as complying with our legal obligations, resolving disputes, and enforcing our policies. The exact retention period will thus depend on the categories of personal data and the processing purposes. For example, for bookkeeping and accounting, in some cases, we are legally required to retain personal data for a certain period of time, e.g., for invoices, or payment details, for up to 10 years for these purposes. With support ticket data, in order to protect our legitimate interests, we retain it for up to 10 years (duration of statutory limitation period). Once such period has lapsed, and there is no purpose to be fulfilled by the processing of personal data, we will delete or anonymize the data in accordance with data protection obligations. Inactive accounts older than 2 years are typically deleted unless subject to statutory retention periods or required for legal compliance.

Protection of Personal Data
Although no data transmission can be guaranteed to be 100% secure, we take all reasonable steps to ensure that the Personal Data we collect, use or disclose is accurate, complete, up-to-date, relevant and stored securely. We also take all reasonable steps to ensure that the Personal Data we hold is protected from misuse, interference, loss, unauthorised access, modification or disclosure by the use of various methods including access limitation, and industry-standard Secure Socket Layer (SSL) encryption technology to safeguard the account registration process and sign-up information. Other security safeguards include but are not limited to data encryption, firewalls, and physical access controls to building and files. NoMachine maintains strict administrative, technical and physical procedures to protect information stored in our servers. Access to information is limited to those authorised employees who require it to perform their job functions.

Changes to This Policy
We reserve the right to make changes to this Policy from time to time. If any changes are material and/or retroactive, we may provide additional notice and/or an opportunity to “opt-in” or “opt-out” as appropriate under the circumstances. We may also advise you of changes to this policy by emailing the revised policy to any email addresses you provide us. Any changes will be compliant with applicable EU data protection laws and regulations.

Access, Correction and Complaints – Contact Us
If you have any questions or suggestions about this Privacy Policy or would like to access, seek correction of or remove your Personal Data, or if you have complaints regarding our privacy practices, please contact us by emailing privacy@nomachine.com.