Our digital etiquette

Last updated on 15 March 2024

1. Introduction

1.1 Scope of Application

This Privacy Notice applies to the products, services, websites, and apps offered by Nine Wisdoms B.V. In this notice, we refer to these products, services, websites, and apps collectively as "services." Unless otherwise stated in your contract, our services are provided by Nine Wisdoms B.V. in the Netherlands.

2. Personal Information We Collect About You and the Sources

2.1 What Do We Mean by Personal Data?

References in this Privacy Notice to data, personal information, or ordinary information all refer to Personal Data. Personal Data refers to information about a living person whose identity can reasonably be determined either alone or in combination with other data (a “Data Subject”).

2.2 Who Do We Collect Data About?

We group consumers or businesses into the following categories:

• Business: The organization whose details have been entered into one of our assessments.

• Respondent: The individual who receives an assessment, form, application, or questionnaire sent via our service.

• Visitor: You are visiting one of our websites because you are curious or have heard about us through our marketing and sales channels.

2.3 Types of Personal Data We Collect

(a) Contact Information. You may provide us with your contact information (such as your name or email address) when using our services, via a form on our website, during a conversation with a sales representative or our support team, or in response to one of Nine Wisdoms’ assessments or forms.

(b) Cookie Information. We use our own tracking services and those of third parties that use cookies and page tags (also known as web beacons) to collect data about visitors to our websites. This data includes usage and user statistics. Emails sent by Nine Wisdoms or sent by users through our services contain page tags. These allow the sender to gather information about who opened the emails and who clicked on links in those messages. See our Cookie Statement for more information about cookies.

(c) Support Information. We collect information submitted through the website, such as name, email address, and message content.

(d) Usage Information. We collect information about your usage when there is interaction between you and our websites and services. Examples include the web pages you visit, where you click, the timing of these actions, your language preferences, and more.

(e) Device and Browser Data. We collect information about the device and application you use to access our services. Device data includes your IP address, your operating system version, device type, device ID/MAC address, system and performance data, browser type, and other device, network, and browser signals. If you use a mobile device, we also collect the UUID of that device. We also derive your geographic location based on your IP address.

(f) Event Data. Like most websites, our web servers keep log files that record each access of a device to those servers. These log files include information about the nature of the access, including originating IP addresses, internet providers, files viewed on our site (such as HTML pages, images, etc.), operating system versions, and timestamps.

(g) Referral Information. If you land on a Nine Wisdoms website via an external source (such as a link from another website or in an email message), or if you are invited to view a survey as a guest, we record information about the source that referred you to us.

(h) Integration Data. We collect information from third parties with whom Nine Wisdoms enables integrations so that you can use both services together.

(i) Assessment/Form/Application Data. We store your data in assessments/forms/applications (questions and responses) for you. The analysis is then sent to you in a report.

3. How We Use the Personal Information We Collect

3.1 Company

We process Personal Data about you as an employee of your Company when:

• You have consented to it;

• We need to fulfill our contractual obligations;

• We have a legitimate interest; and

• We have a legal obligation.

3.1.1 Consent

We require your consent to process the following elements of data:

(a) Cookies and similar technology.

We, or third-party data and advertising platforms we work with, collect data and advertising cookies, page tags, mobile IDs, and IP addresses. We use this data to derive common user identities across services and multiple devices. For example, we may do this to tailor advertisements, customize marketing, or to enable us to assess and improve the success of our ad campaigns. You can withdraw your consent at any time.

These third-party data and advertising platforms may also use data we provide to improve their technology and their ability to match common devices to users.

To learn more about interest-based advertising and how to opt out, refer to our Cookie Statement in Section 6. If you clear cookies in your browser settings, you will no longer see personalized messages. However, you may still see general advertisements not based on information provided to Nine Wisdoms. Depending on your geographic location, you may also withdraw your consent using the cookie management tools in our products.

(b) Contact Information.

We use contact information to respond to your inquiries, provide service-related information, and send you marketing communications. In jurisdictions where opt-in is required, we will send marketing materials only based on your consent.

3.1.2 Contract

We collect and use the following data elements because they are necessary to fulfill our contractual obligations to you:

(a) Account Information.

We require your account information to manage your account, provide our services, bill you, support you, and contact you or your organization about your service or account. These are transactional messages (e.g., service announcements, billing issues, changes to our services or policies, welcome email upon registration). You cannot opt out of these communications as they are essential for delivering our services.

We may also use aggregate billing data to manage or adjust pricing at an individual or service-wide level.

(b) Customer Support Information.

We use information submitted via our support channels, such as your name, email, and message content, to provide customer support.

(c) Usage Information.

Usage and performance data allow us to meet our Service Level Agreements (SLAs) or other contractual obligations.

(d) Device and Browser Data.

We use device data to troubleshoot and improve our services. This data also helps with account verification, logins, enforcing password sharing and security policies, and ensuring optimal site display across different devices/browsers.

(e) Integration Data.

We collect and use information from third parties and integration partners where applicable, such as:

• Signing into our service via LinkedIn/Microsoft/Google;

• Using our service alongside other services.

(f) Assessment Questions and Responses.

We use machine learning on survey data to provide users with useful statistics and relevant insights based on data collected via our services.

(g) Aggregated or De-Identified Survey Questions and Responses.

We use this data to offer users useful benchmarks and insights, and to enforce applicable agreements.

3.1.3 Legitimate Interests

We process your personal information in the following categories for legitimate interests pursued by us. We place clear limits on how this information is used to respect your privacy:

(a) Contact Information.

Where consent is not required, we use contact information to send marketing messages based on our legitimate interests until you opt out. You can unsubscribe at any time by clicking the Unsubscribe link in our emails.

(b) Customer Support Information.

We may use information provided to support, customer success, and sales teams (e.g., name, email, message content) to train machine learning systems to better predict and answer support queries, and identify support trends. Where possible, this data is de-identified.

(c) Usage Information.

We use this data to improve our services and provide recommendations about other services to you and your organization.

(d) Event Data.

We use log event data for various business purposes including:

• Developing new services, features, and content;

• Monitoring behavior at an aggregated/de-identified level to identify and understand service interaction trends;

• Resolving product issues and defects;

• Investigating security issues.

(e) Proprietary Information.

We use other account data (e.g., job details, marketing preferences) and public data to provide a personalized experience, relevant marketing, and service recommendations.

(f) Third-Party Information.

We combine data from third parties (e.g., LinkedIn, Chamber of Commerce) with our data to build user profiles and improve our marketing relevance.

(g) Referral Data.

We use referral data to assess the success of our referral and integration processes.

(h) De-Identified Device Data.

We use aggregated or de-identified device data to understand usage patterns and improve services.

(i) De-Identified Survey Data.

We use machine learning on aggregated/de-identified data to gain insights and improve services.

3.1.4 Legal Obligation

(a) If we are required to respond to legal requests, we may need to use and disclose information we hold about you. If we receive a subpoena or another legal request, we may need to review the data we hold to determine how to respond.

(b) We may also use usage data, event data, and aggregated or (where possible) de-identified survey questions and responses to:

• Monitor compliance with our contracts, where applicable;

• Investigate security issues;

• Prevent potentially unlawful activities; and

• Monitor and prevent unwanted and harmful activities.

3.2 Respondent

We process Personal Data about you as a Respondent in the following cases:

• We need to fulfil our contractual obligation to deliver services to your company;

• We have a legitimate interest; and

• We have a legal obligation.

3.2.1 Contract

(a) Contact Information
We only use contact information to respond to customer inquiries if you, as a Respondent, contact us.

(b) Cookies
We use required cookies to ensure the proper functioning of an assessment or other Nine Wisdoms product delivered by your company. These cookies ensure that all aspects of the survey function correctly and optimally.
Examples include: Page tags that allow email senders (e.g., surveys or forms) to track email performance to increase deliverability and open rates. We also use cookies to ensure respondents can only complete an assessment once. We track the number of completed assessments.
After completing an assessment, you are typically redirected to our website and treated as a website visitor, which may involve the use of other cookies. See the "Visitor" section if you are interested in this.

(c) Device and Browser Data
We use device data to troubleshoot service issues and to make improvements.
We use your device and browser data to deliver our services to your company. For example, your IP address helps prevent duplicate submissions if the assessment creator has set such restrictions.

(d) Inferred Geolocation
We infer your geographic location based on your IP address. Note: We do not collect exact (GPS) location.

(e) Event Data
We use event data for various business purposes, including:

• Creating, improving, or recommending services, features, or content;

• Tracking behaviour on an aggregated/de-identified level to identify and understand trends in interactions with our services; and

• Troubleshooting product issues and bugs.

(f) Third Parties and Integration Data
We collect and use information from third parties and integration partners, allowing companies to send you assessments/forms/applications/questionnaires.

(g) Assessment Response Data
Nine Wisdoms may use its own machine-learning systems or third-party AI tools to process data related to the assessment your company sent you, including question types and device and event data linked to responses, in order to fulfil our contract with your company. Specifically, we use these systems to help companies by:

• Identifying trends in their responses;

• Continuously training models to optimize outcomes;

• Making recommendations and offering guidance on the most effective actions in different scenarios.
  For example, we might identify usage patterns that suggest respondents prefer multiple-choice questions over open-ended ones and provide predictive answer suggestions for selected question types. We may also use this data to enhance response analysis.

• Improving the user experience (e.g., by collecting and using device and browser data to enhance how our assessments function across platforms, or by adapting questions based on respondent input); and

• Identifying insightful data trends (not revealing Personal Data) and using them to provide recommendations to companies.

3.2.2 Legitimate Interests

We process your personal information in the following data categories under legitimate interests pursued by us. We place clear limits on how this information is used to respect your privacy and only use the necessary information to fulfil these legitimate purposes.

(a) Usage Information
We use information about how you use our services to improve them for all users and to provide recommendations to our customers about service usage.
For example: We collect information about the types of questions you answer. This data is, where possible, aggregated and/or de-identified to help us identify respondent preferences when submitting responses. We use all this data to improve our product, making questions easier to answer and increasing completion rates for surveys/forms.
Additionally, we use information such as the type of assessment, form, questionnaire, or application you participated in to personalize products we show you after completion and to identify trends in service usage.

(b) Responses (in aggregated and/or de-identified form)
Used for building new product features.

(c) Inferred Geolocation
We may infer your location from your IP address to produce aggregated data on respondent location trends. We use this to compare usage trends across different browsers and devices. Note: We do not collect exact (GPS) location.

(d) Customer Support Information
We may use information provided to our support, customer success, and sales teams—such as name, email, and message content—to train machine-learning systems. This allows better prediction and handling of customer support queries, improves responses, and generates insights into support trends. Where possible, this data is de-identified.

3.2.3 Legal Obligation

(a) If we are required to respond to legal requests, we may need to disclose information we hold about you. If we receive a subpoena or other legal request, we may need to review the data we hold to determine how to respond.

(b) We may also use usage data, event data, and aggregated or de-identified survey questions and responses to:

• Monitor compliance with our contracts, where applicable;

• Investigate security issues;

• Prevent potentially unlawful activities; and

• Monitor and prevent unwanted and harmful activities. For example, we use automated systems to detect phishing, spam, and fraud.

3.3 Visitor

We process Personal Data about you as a Visitor if:

• You have given your consent;

• We need to fulfill our contractual obligations;

• We have a legitimate interest; and

• We have a legal obligation.

In some cases, we may not have any personal information about you as a previous website visitor (for example, if you have not interacted with our site or have cleared your cookies).

3.3.1 Consent

If you have given us consent, we collect and use the following information about you:

(a) Contact Information
We use contact information to respond to your inquiries or to send you information about our services if you consented when providing your information or if you work for a company that may be interested in our services. You may unsubscribe from this marketing at any time.

(b) Cookies and Similar Technologies
We, or third-party data and advertising platforms we work with, may use or combine various technologies such as non-essential cookies, page tags, mobile IDs, and IP addresses to derive common user identities across services and devices, including tablets, mobile phones, and browsers.
We may use this to personalize advertisements, tailor marketing efforts, and measure the effectiveness of advertising campaigns so we can improve them.
We use this data to tailor online marketing campaigns to match your interest in our services. You may withdraw your consent at any time via our cookie banner.
These third-party platforms may also use data we provide to improve their technologies and capabilities to match users across commonly used devices.

3.3.2 Contract

(a) Device and Event Data
We use device data to troubleshoot bugs and issues with our service and to make improvements.

(b) Comments/Content
Any comments or content linked to you that you share as a guest invited to collaborate on an assessment.

3.3.3 Legitimate Interests

We also process your personal information for legitimate business interests we pursue. We place clear limits on how this information is used to respect your privacy and ensure only the necessary data is used to achieve these purposes.

(a) Third-Party Profile Information
Where legally permitted, we combine information about you from third parties with information we already have to build a user profile. This profile helps make our sales and marketing efforts more relevant to you and improves our campaigns and website.

(b) Usage Information
We use information about how you interact with our websites to improve them for all users.
Examples: We collect aggregated data about the web pages you visit and your activities on our sites. This helps us identify the most visited and useful sections of our website and determine our most popular services.

(c) Event Data
We use event data for various business purposes, including:

• Monitoring abuse and troubleshooting issues;

• Tracking preferences and developing new services, features, or content, or making personalized recommendations;

• Analyzing behavior on an aggregated/de-identified level to identify and understand interaction trends with our services; and

• Resolving product issues and defects.

(d) Customer Support Information
We may use information provided to our support, customer success, and sales teams—such as name, email, and message content—to train machine-learning systems. These systems can better predict and answer support-related questions, provide responses, and generate insights about customer support trends. This information is de-identified where possible and also used to improve our customer support.

(e) Referral Information
We use referral information to evaluate the success of our integration and referral processes.
For example, if you clicked on an ad served by one of our partners that led you to our site, we record this to track the effectiveness of our advertising campaigns.

3.3.4 Legal Obligation

(a) If we are required to respond to legal requests, we may need to disclose information we hold about you. If we receive a subpoena or other legal request, we may need to review the data we hold to determine how to respond.

(b) We may also use event data to:

• Monitor compliance with our contracts, where applicable;

• Prevent potentially unlawful activities; and

• Monitor and prevent unwanted and harmful activities. For example, we use automated systems to detect phishing, spam, and fraud.

4. How We Share or Disclose Personal Data

4.1 Information You Share
Many of our services allow you to share information with others. Please note that any information you share publicly may be indexed by search engines. We cannot remove content from search engines, so please be cautious about sharing information publicly.

4.2 Information We Share
We do not share your information or data with third parties outside of Nine Wisdoms, except in the following limited circumstances:

(a) If you are a Company participating in a Nine Wisdoms team assessment, your data will be shared with the team members you specify. Please consult your organization’s internal policy if you have questions about this.

(b) To provide certain aspects of our services, we work with affiliated companies and trusted partners. Specifically, we rely on third parties for the following:

• We use SurveyMonkey for data collection.

• We use Microsoft services for storing, analyzing, and processing data.

• We use Hubspot to support our sales and service departments.

(e) We enter into confidentiality and data processing agreements with partners to ensure they comply with the highest confidentiality levels and follow best practices for privacy and security standards. We regularly review these practices.

(f) Based on your instructions, we share your information or data if you choose to use an integration in combination with Nine Wisdoms services. We do this only to the extent necessary for the integration to function.

(g) In addition, we may share information or data to:

• Comply with applicable laws, regulations, legal processes, or enforceable governmental requests;

• Enforce applicable policies, including investigation of potential violations;

• Detect, prevent, or otherwise address fraud, security, or technical issues;

• Protect the rights, property, or safety of our users, the public, or Nine Wisdoms, as required or permitted by law; and

• Carry out a sale, merger, or change in control of part or all of our business or operations, or prepare for such an event.

5. Data Retention

If you are a Company, we generally do not delete the data in your account as long as the account remains active. You are responsible for and in control of how long you retain this data.

We also encourage Companies to actively review their data retention practices within their accounts to ensure they do not retain data longer than necessary.

Our Cookie Statement describes the expiration periods for cookies on our websites.

6. Personalized Marketing and Cookies

We and our partners use cookies and similar technologies on our websites. Please refer to our Cookie Statement for more information. If you are a Nine Wisdoms customer and separately use cookies or similar technologies in conjunction with our products and services, you are solely responsible for complying with any applicable laws related to their use. This Privacy Notice does not apply to such usage by you.

Finally, you may clear cookies in your browser settings if you do not want to see personalized marketing content on the web related to our service.

7. Protection of Minors

Our services (including the creation of and responses to surveys) are not intended for or directed at Minors. Minors are individuals under the age of 16 (or older in certain countries or regions). Nine Wisdoms does not knowingly collect Personal Data from Minors or allow them to register. If we become aware that we have collected Personal Data from a Minor, we may delete the information without notice. If you believe this may have occurred, please contact our support team.

8. Data Transfers

Your information and data are processed in, and transferred to or disclosed in, the Netherlands and other countries where our service providers are located or have servers. We ensure that any recipient of your personal data offers an adequate level of protection, for example, by entering into appropriate agreements using Standard Contractual Clauses or other mechanisms approved by the European Commission or relevant data protection authority.

8.1 EU-U.S. Data Privacy Framework, UK Extension to the EU-U.S. Framework, and Swiss-U.S. Principles

Nine Wisdoms is self-certified under the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework principles. Nine Wisdoms is committed to subjecting all personal data received from EU Member States, the UK, and Switzerland to the framework in accordance with its principles.

Nine Wisdoms also complies with the accountability provisions of the Data Privacy Framework.

When Nine Wisdoms receives personal data under the framework and subsequently transfers it to a third-party service provider acting as an agent on its behalf, Nine Wisdoms may be held liable under the framework if (i) the agent processes the information in a way that violates the framework and (ii) Nine Wisdoms is responsible for the event causing the damage. In certain circumstances, Nine Wisdoms may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Please contact Nine Wisdoms as described in section 11 below if you have any concerns or complaints of any kind.

9. Who Is My Data Controller?

If you have responded to an assessment, completed a form, submitted an application, or provided website feedback to Nine Wisdoms, Nine Wisdoms is your data controller.

10. Your Rights

You may wish to exercise a right to receive information about yourself, or to correct, update, or delete such information. Some of these rights may be subject to exceptions or limitations under local law. Your rights and choices depend on your location. We take reasonable steps to verify your identity and respond to your request within a reasonable timeframe (and in all cases within 30 days of receipt), as outlined below for specific categories of individuals.

10.1 Company
If you are a contract holder of a Nine Wisdoms service, you have the right to obtain a copy of any personal data we hold about you. You may also have the right to ask us to restrict how we use your data or to object to certain aspects of our processing. You can access much of your data by logging into your account. If you would like to exercise your rights, please contact us.

10.2 Respondent
If you have responded to an assessment, form, or application sent to you by a company via a Nine Wisdoms service, any request to manage, delete, review, restrict access to, or otherwise withdraw your consent regarding that data should be directed to that individual or organization. Nine Wisdoms does not control your response data and is not in a position to handle such requests directly.

10.3 Visitor
If you have visited our website and wish to exercise any of the rights described above, you may contact our support team. Alternatively, if your request relates to the right to be forgotten specifically with regard to our use of cookies, you can achieve this by clearing your browser cookies.

10.4 Contact Information
Unless otherwise stated in this document, use the following contact details for privacy-related questions:

Nine Wisdoms B.V.
Chamber of Commerce number: 91229278
📧 info@ninewisdoms.com

11. Complaints

If you are an EU resident and are not satisfied with how we have handled a complaint you submitted, you have the right to contact your local data protection supervisory authority.

12. Changes to Our Privacy Notice

We may occasionally update this Privacy Notice.