Terms and Conditions and Privacy Policy

This Privacy Policy describes the way in which Nubo scrl-sf/cvba-so uses and protects any information provide while using the website accessible from the domain nubo.coop and all its subdomains (hereinafter reffered to as “the Site”).

Please note that this Privacy Policy may be modified or supplemented at any time by Nubo scrl-sf/cvba-so, particulary in order to comply with any legislative, regulatory, legal, or technological developments. In the case of of any modifications, the date of the update will cleary indicated at the top of the present policy. Any modifications will be binding for the user as soon as they have been posted online. It is therefore adviseable for the User to consult the present Terms and Conditions and Privacy Policy on a regular basis in order to check for changes.

Download the terms and Conditons and Privacy Policy as PDF, in French and Dutch

More information

If after reading this page you still have questions or you wish to modify your data, please contact us.

Terms of use

Headquarters: Nubo scrl-fs/cvba-so, Rue Van Elewyck 35, 1050 Ixelles, Belgique / Van Elewyckstraat 35, 1050 Elsene, België.

Contact: hello@team.nubo.coop

Belgian Law applies

Last modified: This page was last modified on 20/09/2020. Changes approved by the GA on 20/09/2020 (Last change of the data protection officer on 18/06/2021)

Terms and Conditions and Privacy Policy

I. Introductions

Use of the services of Nubo scrl-fs/cvba-so (hereinafter reffered to as Nubo) is subject to unconditional acceptance of the rules set out in this document, which combines the Privacy Policy and the General Terms and Conditons of Nubo. Together with the price list (available here), these documents govern the interactions between Nubo and the users of its services.

For the sake of transparency and ease of access, we have compiled all of the rules into a single document. However, this has resulted in long document that contains some complex language. For this reason, a simplified, educational version will be put online as soon as possible.

For questions or comments, contact us ; to request access or enforce your rights, contact our protections officer.

Object

These rules apply to all Nubo services. If you do not agree with any of the Terms and Conditions, do not use our services.

Nubo reserves the right to update and modify these rules at any time through the decisions of its General Assembly. Any modification will be announced on the Nubo website.

Nubo’s services

Nubo offers services that include both its own communication tools (website, CRM) and Nubo’s paid services (mainly mail and cloud), without this list being exhaustive. These rules apply to all Nubo services.

Exceptions

The purchase of shares is subject to the rules of the Companies and Associations Code. The data collected during the purchase of shares is used only to enable you to exercise your rights as a shareholder.

If, in addition ot to the purchase of shares, you purchase another service or provide information while using the website, your personal data will bes subject to the present regulations. Thid data will processed in the context of Nubo’s services.

Cookies deposited on the Nubo site may be modified without the approval of the General Assembly so long as they comply with the rules as set forth in this document.

II. General

II.1. General principle

Nubo is committed to protecting the privacy of its users. This general principle applies to all of Nubo’s operating rules and procedures.

Nubo does not claim any rights to user data or data transmitted from an account hosted by Nubo. Your content belongs to you.

This means among other things that:

  • Nubo will never pass on or resell its users’ data;
  • Nubo tries to collect the smallest amount of data possible, only that which is required to guarantee operational performance;
  • Nubo does not engage in tracking in the sense that Nubo does not measure individual activity that is not necessary for the management of its services and in no way processes or cross refernces this data for any other purpose;
  • Nubo only monitors its services and the use of its website for technical and financial management purposes.

Nubo will not use its users’ data for any purpose other than to provide its services.

II.2. Charters

Nubo agrees to adhere to the charter published by the CHATONS Collective and to put what is required o respect these rules in place as quickly as possible.

Nubo also wishes to respect the rules set out in the charter of the Libre Hosters.

II.3. Transparency Report

Nubo undertakes to regulary publish an anonymous report on all requests made to it by the judiciary and authorities. This report will discose what action has been taken on these requests.

II.4. Hardware and software infrastructure

Nubo’s services and web sites are hosted, managed and operated by Nubo on its own servers. The servers are located in a data center in Belgium.

The Board of Directors maintains and will publish a list of the location of its servers.

The software infrastructure used by Nubo is based as much as possible on software published and documented under an open source license: (link to documentation).

III. Privacy Policy

In accordance with the General Data Protection Regulation (GDPR) adopted by the European Parliament on April 14, 2016, Nubo informs you of the points contained in this chapter.

If you have any comments or wish to enforce your rights (see below, section III.4. « Rights related to the General Data Protection Regulation »), please contact the Data Protection Officer:

Jean-Luc Manise - Contact: gdpr@team.nubo.coop

III.1 Identification and personal information

In general, Nubo strives to collect as little personal data about its users as possible. The limit lies with service provision: Nubo collects data in order to provide you with a service. If you do not provide the necessary data, Nubo cannot offer you the service.

By providing this information, you expressly agree to it being processed by Nubo for the purposes listed in section III.2. « Purposes  » below.

a. Visiting the Website

When you visit the Nubo site, you automatically communicate us your IP address (your computer’s automatic identifier). This IP address will not be cross-referenced with other personal data.

It is possible to visit the Nubo website without communicating any other personal information about yourself.

Nevertheless, Nubo may ask you for personal information in order to provide you with its services (for example, your e-mail address when you subscribe to our newsletter). The data thus collected will be used only for the purposes indicated below (point III.2.).

b. Use of services

To use Nubo’s services (e.g., e-mail and cloud), you must create an account. When you create an account, Nubo requests certain personal information: your first and last name, your mailing address, a valid e-mail address, and a password to protect your account from misuse.

This information is used solely to allow you to access the services and for billing purposes. Except with your explicit direct consent or by legal obligation (see section III.6. « Exceptional access by virtue of a court order »), this information will never be handed over to third parties.

Upon receipt of payment, Nubo will have access to the account data of the person making the payment (name, address and account number of the account holder).

This data will eventually be used to identify a payment, but will not be used for other purposes. Nubo will never use it to complete your profile information.

c. Metadata

With regard to e-mail and cloud services (and thus not just visiting Nubo’s website and communications), certain legal and technical obligations require Nubo to retain certain « metadata ».

This metadata correspond to all the information surrounding a message other than its content. It is not trivial, as is often sufficient to identify a person and even to infer their activities, interests, contacts, etc. Access to this metadata is described below.

Logs

For the proper functioning of the services, the various actions of users accessing the services are recorded in so-called “system logs”. This information is used by the technical team to ensure the proper functioning of the services and to protect them from fraudulent access attempts.

The logs contain various data: the IP address, the date of connection, the nature of the request and, for the Web, information related to the browser being used.

Example of a log from a webmail query:

mail.nubo.coop.xyz:443 91.258.236.199 - - [13/Aug/2020:15:39:16 +0200] "POST /?_task=mail&_action=refresh HTTP/1.1" 200 861 "https://mail.nubo.coop/?_task=mail&_mbox=INBOX" "Mozilla/5.0 (Windows NT 10.0; Win64; x64; rv:79.0) Gecko/20100101 Firefox/79.0"

Example log of an access to a mailbox:

2020-08-09 22:50:02 imap-login: Info: Login: user=<test@nubo.coop>, method=PLAIN, rip=22.58.36.84, lip=22.58.235.52, mpid=26651, TLS, session=<SjJl+3esRJwlu4tz>

This data will be accessible to the technical team for three months.

Metadata preservation and accessibility:

Transposition of the Data Retention Directive requires that we retain the history of this metadata for one year. This data can be requested based on a court request. Nubo undertakes to encrypt this data and make it unavailable for other purposes.

The data we need to keep are the user’s identifier and personal data, IP address, port and date of account creation, and payment details. For each connection, the IP address, port, date of connection and service used.

In case of legal requests, Nubo is committed to protect the privacy of its users as much as possible.

d. Cookies

The Nubo website does not use external cookies. The cookies used come from tools managed directly by Nubo and do not rely, for example, on third-party advertising agencies or audience metrics.

Browsers can be configured to accept or reject cookies, it is also possible to delete them through the software’s settings or configuration, see the software’s help or documentation for more information.

In exception to the rules outlined in this document whereby modifications must be approved by Nubo’s General Assembly, Cookie use can be modified by simple technical adjustmetn provided the modifications are outlined below (underthe subheadings « Necessary cookies » and « Analytical cookies »)and that they comply with all other rules established in this document.

Necessary cookies

Cookies are essential for the operation of certain features of the site:

  • newsletter registration and shareholding,
  • registration and use of the forum (« Nubo agora »).

The cooperative hosts and manages these services on its own servers. No data is transmitted to third parties.

crm.nubo.coop

On this sub-domain, Nubo hosts CiviCRM, an open-source software that manages newsletter subscriptions and shareholding forms. Two cookies are required for its operation.

Name Function Lifespan
has_js Determines whether the browser supports javascript in order to display forms correctly. It expires at the end of the session.
SSESS* Creates a unique identifier for each visitor, making it possible to link navigation from one page to another and ensure continuity in form filling. It expires after 23  days.

agora.nubo.coop

« Nubo agora » tourne grâce à Discourse, runs thanks to Discourse, a free software for discussion forums. Its operation requires several cookies, the creation of which depends on settings and configured connection modes.

Name Function Lifespan
email Used only during account creation. Expires at the end of the session.
destination\_url Retains the destination URL to redirect the user once logged in (if not already logged in). Expires at the end of the session.
\_t Stores the user’s connection information (so you don’t have to log in again each time you visit). Expires after 2 months (1440 hours).
\_forum\_session Temporarily keeps information about the current visit. Expires at the end of the session.
theme\_key Created only if the opiton « Make it my default them on all my devices » is disabled by the user (in his personal settings). It is permanent.
cn Manages the visibility of notifications in certian cases. It is permanent.
sso\_destination\_url Retains the target URL to redirect the user once he or she is logged in via the single sign-on system (when such a system is configured and the user is not yet logged in). Expires at the end of the session.
authentication\_data Stores the data sent to the javascript application when a connection is made through an external authentication system. Expires on the next page
fsl Holds the client settings when connecting through an external authentication system. Expires at the end of the session.
\_bypass\_cache Used together with the fsl cookie when logging in with a remote authentication system. Expires at the end of the session.
dosp A temporary cookie that informs the client that there is Denial of Service (DoS) protection (only if there is). Expires on the next page
Analytic cookies

Two cookies are used for analytical purposes. Nubo useMatomo, a free and open source statistical measurement software. Il est hébergé et géré par la coopérative. It is hosted and managed by the cooperative. The information stored is anonymized and no data is passed on to third parties.

Name Function Lifespan
_pk_id.* creates a unique identifier that connects a visitor to the pages they view and recognizes them on subsequent visits. Expires after 13 months.
_pk_ses.* Creates a session ID to track the pages visited. Expires after 30 minutes.

Matomo is configured to respect the (« do not track (DNT) ») signal. That is, if the option is activated in your browser, your visit is not tracked or recorded in the statistics.

III.2. Objectives

Nubo may process your personal data:

  1. to provide you with the information or services you have requested (including: sending you newsletters, email and cloud services, etc.); and/or

  2. to contact you about various events related to Nubo, including but not limited to product updates and technical support; and/or

  3. for the purpose of proper technical and financial management (in particular, monitoring the use of hard drives, billing, etc.); this includes the possibility of the Nubo team contacting you by email in case of a technical problem, but also simply to pass on information directly related to the service used; and/or

  4. for the purpose of strictly internal improvement of the user interface and the Nubo service tools and mainting a conistenet and reliable user experience

III.3. Retention Period

Your personal data will be kept by Nubo only for the time necessary to achieve the above-mentioned purpose.

III.4. Rights in connection with the General Data Protection Regulation (AVG)

You have the following rights regarding your Personal Data, which you may exercise by writing to us at avg@team.nubo.coop or at the postal address of Nubo scrl-fs/cvba-so, Rue Van Elewyck 35, 1050 Ixelles, Belgique / Van Elewyckstraat 35, 1050 Elsene, België.

a. Right to access your data

You have the right to access your personal information.

Due to Nubo’s commitment to security and confidentiality in the processing of personal data, requests can be made by e-mail, but if there is any doubt about the identity of the requester, proof of your identity may be requested.

If necessary, Nubo has the right to oppose clearly unlawful requests (due to their quantity of requests or thier repetitive or systematic nature).

Find more information about your rights at autoriteprotectiondonnees.be.

b. Right to change or delete your data

Under the law, you can request the correction, amendment or deletion of data relating to you.

Find more information about your rights at autoriteprotectiondonnees.be.

c. Right of opposition

The exercise of this right is only possible in one of the following two situations:

When the exercise of this right

  • is based on legitimate grounds; or
  • Is intended to prevent the data collected from being used for commercial prospecting purposes.

Find more information about your rights at autoriteprotectiondonnees.be.

d. Right to restriction of processing

You have the right to have the processing of your personal data restricted if you dispute the accuracy or processing of your personal data, or if you still have the use of your personal data but Nubo no longer does. In particular, you can prevent us from deleting your personal data while you still need to have it verified.

e. Right to portability

You have the right to receive all personal data Nubo holds about you in a usable, understandable and current format.

You have the right to withdraw your consent at any time to any processing that Nubo would do with your personal data, provided it is not necessary for the services to which you have subscribed.

g. Response deadlines

Nubo undertakes to respond to your request for access, modification or opposition, or any other additional request for information, within a reasonable time, not exceeding 1 month from the receipt of your request.

h. Authorized service providers and transfer to a third country of the European Union

With the exception of third-party payment systems, as specified below, Nubo does not transfer personal data either inside or outside the European Union.

Our only external payment system provider (see below) is Mollie NV, based in the Netherlands.

i. Payment Systems

Nubo relies on payment systems operated by a third party, namely:

  • Mollie N.V. : for all direct payments (Bancontact, banking apps, etc.) we depend on the Mollie terms of use available on this page. They are generally respectful and assure us that personal data will not be resold for marketing purposes.

j. Competent supervisory authority

The supervisory authority in Belgium is the DPA (The Data Protection Authority).

For any complaint related to the processing of your personal data by Nubo, please do not hesitate to contact us directly. If your complaint is not resolved in this way, you may contact the Data Protection Authority by mail (Press Street 35, 1000 Brussels / rue de la Presse 35, 1000 Bruxelles), by telephone (02 274 48 00) or by e-mail (contact@apd-gba.be).

III.5. Personal Data

The personal data referred to here is any data you host or share using Nubo’s services (e.g., your emails, shared documents, address books, etc).

Nubo does not claim any rights to your data.

Nubo does not use its users’ personal data or content for any purpose other than providing services. In particular, Nubo only monitors its the use of its site and services for technical and financial management purposes.

a. Content copyrights

Nubo does not claim any rights to user content or data transmitted from a user account. You own your content.

b. Exceptional access for support

In the event of technical support for a problem with your account, we may access your cloud space or email account at your request. This access requires explicit consent from you and is limited to identifying and resolving the problem.

III.6. Exceptional access pursuant to a court order

Nubo may be required by court order to transmit certain data of some users to a judge. However, Nubo takes great care to ensure that such data is transferred only with the utmost care and only in cases where it is required to do so by law. As long as the law permits, the user concerned will be notified by Nubo.

As mentioned above (section “General”), Nubo will regularly report on the requests and court orders, as well as on the follow-up given to these requests and orders.

IV. Terms and conditions of use

This section applies to the use of Nubo services, with the exception of communication services concerning Nubo (visits to the website and information about Nubo and its services).

Thus, it primarily covers email and cloud services, but also other services that allow a user to manage personal content (for example, for sharing or collaborative editing of documents).

IV.1. User responsibilities

  • Accounts on Nubo can only be created and used by humans. In particular, to ensure the good reputation of our servers, it is forbidden to use Nubo’s services to send « spam » (i.e. unwanted mass mailings). Accounts in violation of this policy may be deactivated without notice.
  • You are responsible for the security of your account and password. Nubo shall not be liable for any loss or damage resulting from your failure to comply with this security obligation
  • You are responsible for all content and activities that occur under your account. You may not sell, trade or resell any account for the service you are using.

IV.2. Quality of Service

Nubo ensures that the server infrastructure and installed programs are up to date and as free as possible from errors and security leaks.

Nubo shall ensure the highest possible uptime.

Nubo undertakes, except in case of unforeseen circumstances, to warn users 4 days before any update or maintenance intervention that may affect the quality of service.

a. Support and guidance

Support for Nubo users will be as optimal as possible, within the resources of the cooperative. Except in exceptional cases, support will be provided primarily during business hours, excluding weekends and holidays.

b. Editing and sharing data

The service allows you to give access to your documents to one or more other users to work collaboratively. Nubo cannot be held responsible for problems resulting from sharing or publishing data.

c. Data integrity and backup policy

Data integrity and backup policy. Nubo provides a daily backup service to prevent data loss. Backups are kept for a minimum of 30 days.

Nubo cannot be held responsible for data integrity and the consequences of data loss.

Nubo recommends that its users perform a local backup to ensure the integrity of their data.

IV.3. Terms and Conditions

a. Tolerance

Nubo’s failure to act or respond promptly in accordance with the stated terms and conditions, or to permit a breach of any of them, does not constitute a waiver of their validity or mean that they no longer apply.

b. Prices

All of our prices and payment terms are available on the following page.

c. Payments and collections

Billing is monthly and payments are made in advance: users pay for the upcoming month

Upon registration, the account is immediately active. If the first payment is not received by the end of the month, the account will be blocked.

In the event of a reduction in disk space, changes in quota and pricing are applied the following month. However, it is not possible to use less than the basic package.

In the event of an increase in disk space, the change to the quota is immediate however the rate will not increases until the following month. Users recieve the benefit of the extra space without a price increase before the end of the current month (free period), however if they should reduce their quota before the new billing starts, their next months bill will still reflect the maximum quota amount used.

d. Cancellation

You may terminate your services with Nubo at any time by sending an email to hello@team.nubo.coop. Your termination request will be effective on the next business day.

Amounts paid at that time for the current month cannot be refunded. Amounts paid for subsequent periods will be refunded. Unless expressly requested, termination of services will occur at the end of the current month at the earliest. Nubo undertakes to facilitate your departure and to return your personal data.

e. Suspension of services

Without limiting your liability, Nubo has the right to interrupt your services if, in its reasonable opinion, your use violates some or all of these rules.

In such event, you will be expressly notified and have the non-suspensive right to contest the decision with Nubo’s Board of Directors.

V. Credits

This document was inspired by and taken from existing sections of other hosting providers’ terms of use:

It is published under the terms of the CC BY–SA 4.0.