Nomadic Tribe

This Notice is issued by Nomadic Tribe LLC (“NomadicTribe”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, including customers, users of our Social Media Platform, visitors to our Sites, users of our Apps, other users of our services, and visitors to our premises (together, “you”). Defined terms used in this Notice are explained in Section (S) below.

This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

We collect or obtain Personal Data about you from the following sources:

• Data provided to us: We obtain Personal Data when those data are provided to us (e.g., where you contact us via email or by any other means, or when you provide us with your business card, or when you submit a job application).
• Relationship data: We collect or obtain Personal Data in the ordinary course of our relationship with you (e.g., when we provide our services to you, when you download and use our Apps, when you register to use our Social Media Platform, or when you make a booking with us)
• Data you make public: We collect or obtain Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us and the content that you make available on our Social Media Platform)
• App data: We collect or obtain Personal Data when you download or use any of our Apps.
• Site data: We collect or obtain Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
• Registration details: We collect or obtain Personal Data when you use, or register to use, any of our Sites, Apps, Social Media Platform or other services.
• Content and advertising information: If you interact with any third party content (including content of other users) or advertising on a Site, in an App or on our Social Media Platform (including third party plugins and cookies) we receive Personal Data from the relevant third party provider of that content or advertising.
• User generated content: we collect or obtain personal data contained in any content that you may post to our Social Media Platform (e.g., personal data contained in posts, photographs, videos, audio etc.) and in any content posted by other users which contains your personal data.
• Connections information: information about your connections on our Social Media Platform, such as the users with whom you have interacted and users you have blocked.
• Message information: information relating to messages or other communications made on or through our Social Media Platform, Sites and Apps, including the information contained in such messages and communications.
• Third party information: We collect or obtain Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; local tribes that you have visited and personnel associated with your visit to the tribes such as local guides etc.)

We also create Personal Data about you in certain circumstances, such as records of your interactions with us, details of your past interactions with us, details of your interactions with other users of our Sites, Apps and Social Media Platform. We may also combine Personal Data from any of our Sites, Apps, Social Media Platform or other services, including where those data are collected from different devices.

We Process the following categories of Personal Data about you:

• Personal details: given name(s); preferred name; photograph; audio of your voice; and videos containing your image.
• Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
• Contact details: correspondence address; telephone number; email address; details of personal assistants, where applicable; messenger app details; online messaging details; and social media details.
• Consent records: records of any consents you have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
• Booking details: records of bookings and prices.
• Payment details: invoice records; payment records.
• Data relating to our Sites and Apps: device type; operating system; browser type; browser settings; IP address; language settings; dates and times of connecting to a Site; App usage statistics; App settings; dates and times of connecting to an App; location data, and other technical communications information (some of which may constitute Personal Data); username; password; security login details; usage data; aggregate statistical information.
• Employer details: where you interact with us in your capacity as an employee of a third party, the name, address, telephone number and email address of your employer, to the extent relevant.
• Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (e.g., mouse hover, mouse clicks, any forms you complete in whole or in part) and any touchscreen interactions, and records of your interactions with content provided by other users of our Sites, Apps, Social Media Platform or other services.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on Social Media Platforms, including on our Social Media Platform (e.g., images, videos, posts and other content which may or may not relate to your travel experience with us). We also process opinions that others may choose to express about you whether on our Social Media Platform (e.g., in a user’s post on our Social Media Platform) or through our Sites and Apps.
• Reviews and feedback: information about you provided by the relevant tribe(s) that you have visited and/or other personnel who you have interacted with and who have provided feedback to us (e.g., local guides or liaison personnel). Please note that reviews which suggest your behaviour falls below expected standards of our customers when visiting tribes, can result in you being (i) suspended from making future bookings as per our Terms and Conditions and Community Standards; and (ii) removed from our Social Media Platform and/or prevented from using our Sites and/or the Apps as per our Terms and Conditions and Community Standards.
• Community Standards: information relating to your compliance with our Community Standards, including information relating to allegations of non-compliance and complaints made about content you have posted on our Social Media Platform, your behaviour on the Social Media Platform generally and information relating to any investigation conducted by us in response to any complaint about you or suspected breach by you of our Community Standards.
• Complaints: information relating to any complaint made by you whether in connection with the services we have provided, our Sites, Apps and/or concerning another user of our Social Media Platform.
• Settings information: information about your chosen settings on our Sites, Apps and/or Social Media Platform, as applicable.

We do not seek to collect or otherwise Process Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to Process your Sensitive Personal Data for any reason, we rely on one of the following legal bases, as required by applicable law:

• Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations);
• Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (e.g., the prevention of fraud);
• Establishment, exercise or defence of legal rights: We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights;
• Consent: We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way); or
• Manifestly made public: We may Process your Sensitive Personal Data where such data have been manifestly made public by you.

If you provide Sensitive Personal Data to us, you must ensure that it is lawful for you to disclose such data to us, and you must ensure a valid legal basis applies to the Processing of those Sensitive Personal Data.

The purposes for which we Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

• Provision of Sites, Apps, Social Media Platform and services: providing our Sites, Apps, Social Media Platform or services; providing promotional items upon request; communicating with you in relation to those Sites, Apps, Social Media Platform or services; facilitating connections between users of our Social Media Platform; enabling users of our Social Media Platform to create and share content.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, Social Media Platform or services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Operating our business: operating and managing our Sites, our Apps, our Social Media Platform and our services; providing content to you; allowing third parties to make content available to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our Apps, our Social Media Platform; or our services; and notifying you of changes to any of our Sites, our Apps, our Social Media Platform, or our services.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, our Social Media Platform, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; maintaining and updating your contact information where appropriate; and obtaining your prior, opt-in consent where required.
  • The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or
  • We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, our Social Media Platform, or our services to you (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
• Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • The Processing is necessary to protect the vital interests of any individual.
• Financial management: sales; finance; corporate audit; and vendor management.
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, our Social Media Platform , or our services.
  • We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
• Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
• Legal proceedings: establishing, exercising and defending legal rights.
  • The Processing is necessary for compliance with a legal obligation; or
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
• Legal proceedings: establishing, exercising and defending legal rights.
  • The Processing is necessary for compliance with a legal obligation
• Improving our Sites, Apps, Social Media Platform and services: identifying issues with our Sites, our Apps, Social Media Platform or our services; planning improvements to our Sites, our Apps, Social Media Platform or our services; and creating new Sites, Apps, or services.
  • We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our Apps, Social Media Platform or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Fraud prevention: Detecting, preventing and investigating fraud.
  • The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or
  • We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).
• Recruitment and job applications: recruitment activities; advertising of positions; interview activities; analysis of suitability for the relevant position; records of hiring decisions; offer details; and acceptance details.
  • The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or
  • We have a legitimate interest in carrying out the Processing for the purpose of recruitment activities and handling job applications (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or
  • We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
• Compliance with applicable terms: ensuring compliance with the Terms of Use, Community Standards and such other terms that may apply from time to time; investigating complaints relating to your use of our Sites, Apps, Social Media Platform or services; and investigating your compliance with the Terms of Use, Community Standards and such other terms that may apply from time to time.
  • We have a legitimate interest in carrying out the Processing for the purpose of ensuring that our Site, Apps, Social Media Platform and services are being used in compliance with the applicable terms (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).

If in the course of your use of our Social Media Platform you Process Personal Data relating to another individual, you must ensure that it is lawful for you to disclose such data on our Social Media Platform, and you must ensure a valid legal basis applies to the Processing of those Personal Data.

We disclose Personal Data to:

• you and, where appropriate, your appointed representatives;
• the local tribes that you will visit, and associated personnel such as local guides and liaisons, so that we can provide the relevant services to you;
• accommodation providers to facilitate your accommodation booking requests;
• to other users of our Social Media Platform, subject to your settings and the manner in which your share your content and information;
• legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
• accountants, auditors, lawyers and other outside professional advisors to Nomadic Tribe, subject to binding contractual obligations of confidentiality;
• third party Processors (such as payment services providers; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
• any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defence of legal rights;
• any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties;
• any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
• any relevant third party provider, where our Sites, our Apps or our Social Media Platform use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.

If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.

We Process Personal Data for the purposes of automated decision-making and Profiling, which is carried out for the following purposes:

Profiling activity

Customised content and/or discounts

Logic of the Profiling activity

Where we analyse your interactions with us, content on our Social Media Platform, other users and your interests. This information is analysed to determine the most appropriate content, promotions and discounts to offer you.

Consequences for you

This Profiling activity may mean that you receive content and discounts that are not available to others, and that others receive content and discounts that are not available to you.

Because of the international nature of our business, we transfer Personal Data to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we transfer Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.

Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. You are entitled to request a copy of our Standard Contractual Clauses using the contact details provided in Section (R) below.

Please note that when you transfer any Personal Data directly to us, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.

We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.

Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

We take every reasonable step to ensure that:

• your Personal Data that we Process are accurate and, where necessary, kept up to date; and
• any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.

From time to time we may ask you to confirm the accuracy of your Personal Data.

We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

1. we will retain Personal Data in a form that permits identification only for as long as:
   1. we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or
   2. your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your personal data have been provided in connection with a contract between us and you and we require this data for the purposes of fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

   plus:

2. the duration of:
   1. any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data are relevant); and
   2. an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

   and:

3. in addition, if any relevant legal claims are brought, we continue to Process Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.

Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:

• permanently delete or destroy the relevant Personal Data; or
• anonymize the relevant Personal Data.

Subject to applicable law, you may have the following rights regarding the Processing of your Relevant Personal Data:

• the right not to provide your Personal Data to us (however, please note that we will be unable to provide you with the full benefit of our Sites, Apps, Social Media Platform or services, if you do not provide us with your Personal Data – e.g., we might not be able to process your requests without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints regarding the Processing of your Relevant Personal Data with a Data Protection Authority (in particular, the Data Protection Authority of the EU Member State in which you live, or in which you work, or in which the alleged infringement occurred, each if applicable).

Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:

• the right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf; and
• the right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (R) below. Please note that:

• in some cases it will be necessary to provide evidence of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.

We utilize Mixpanel for tracking user-driven events in our App. Mixpanel collects information in accordance with its Mixpanel Privacy Policy. You can opt-out of Mixpanel’s automatic retention of data collected by clicking here: Mixpanel Opt-Out. If you get a new device, install a new browser, erase or otherwise alter your browser's cookie file (including upgrading certain browsers) you may also clear the Mixpanel opt-out cookie.

We use Stripe for payment services. Stripe collects identifying information about the devices that connect to its services. Stripe uses this information to operate and improve the services it provides to us, including for fraud detection. Read more about Stripe cookie policy and privacy policy. These cookies are used for legitimate business interest and cannot be disabled.

All use of our Sites, Apps, Social Media Platform or services is subject to our Terms and Conditions. We recommend that you review our Terms and Conditions regularly, in order to review any changes we might make from time to time. The use of our Social Media Platform is also subject to our Community Standards.

We Process Personal Data to contact you via email or other communication formats to provide you with information regarding Sites, Apps, our Social Media Platform or services that may be of interest to you. If we provide Sites, Apps, our Social Media Platform or services to you, we may send information to you regarding our Sites, Apps, Social Media Platform or services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us, subject always to obtaining your prior opt-in consent to the extent required under applicable law.

You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but in some circumstances we will continue to contact you to the extent necessary for the purposes of any Sites, Apps, Social Media Platform, or other services you have requested.

For the purposes of this Notice, the relevant Controller is:

Controller entity

Nomadic Tribe LLC

Contact details

850 New Burton Rd.
Suite 201
Dover, DE 19904
USA
support@nomadictribe.com

• “App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
• “Adequate Jurisdiction” means a jurisdiction that has been formally designated by the European Commission as providing an adequate level of protection for Personal Data.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's personal preferences, interests, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller.
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that are deemed to be sensitive under applicable law.
• “Social Media Platform” means the NomadicTribe social media platform which is accessible through our Apps and Sites.
• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• “Site” means any website operated, or maintained, by us or on our behalf.