Privacy Policy

PRIVACY POLICY

1. Introduction

This Privacy Policy explains how Nobel, LTD., a company organized and existing under the laws of Bermuda, with registered number 33115 and registered address at 7 Church Street, Dorchester House, Hamilton, Pembroke, HM 11, Bermuda (“Nobel,” “we,” “us,” or “our”), collects, uses, discloses, retains, and safeguards personal information in connection with:

• your access to and use of our website (the “Website”);
• information submitted through inquiry or contact forms;
• communications with Nobel; and
• interactions relating to Nobel’s B2B, enterprise, and carrier business activities.

This Privacy Policy is intended to describe Nobel’s privacy practices in accordance with the Bermuda Personal Information Protection Act 2016 (“PIPA”) and, where applicable, other data protection and privacy laws.

This Privacy Policy applies to personal information collected through the Website and related communications. It does not govern the processing of personal information in connection with commercial services provided under separate agreements, which may contain additional or different data protection provisions, including a data processing agreement (“DPA”) where applicable.

Nothing in this Privacy Policy shall be construed as modifying, superseding, or limiting any data protection terms contained in such separate agreements.

2. Information We Collect

2.1 Information You Provide

When you contact Nobel or submit an inquiry through the Website, we may collect information such as:

• name;
• company name;
• business email address;
• business telephone number;
• job title or position;
• information contained in your inquiry or message; and
• other information you voluntarily provide.

We use this information primarily to respond to inquiries, evaluate potential business relationships, provide requested information, and communicate with you regarding your inquiry.

2.2 Information Collected Automatically

When you access the Website, we may automatically collect certain technical and usage information, including:

• IP address;
• browser type and version;
• device type;
• operating system;
• approximate geographic location derived from IP address;
• pages visited and interactions with the Website;
• referring website or source;
• date and time of access; and
• other technical or usage information necessary for Website operation, security, analytics, or improvement.

The Website may use cookies and similar technologies for functionality, security, preferences, and analytics. Your browser settings and any applicable cookie consent mechanism may provide controls over certain cookies.

2.3 Business Contact Information

Certain information relating to individuals acting in their capacity as employees, representatives, or officials of an organisation may be subject to specific treatment under applicable privacy laws.

Nobel may use business contact information for legitimate business communications and relationship management in accordance with applicable law.

2.4 Commercial Services

Where Nobel provides commercial services under a separate agreement, additional technical, operational, or account-related information may be processed in accordance with the applicable commercial agreement and, where applicable, a DPA.

Depending on the services involved, such information may include:

• call detail records (“CDRs”);
• message or traffic metadata;
• routing information;
• account and billing information;
• service usage information; and
• fraud, security, or traffic-management signals.

Such information may be processed for purposes including service delivery, billing, network operations, security, fraud prevention, regulatory compliance, dispute management, and protection of Nobel’s rights.

This Privacy Policy does not replace, modify, supersede, or limit any applicable data protection provisions contained in separate commercial agreements.

3. How We Use Personal Information

Nobel may use personal information for purposes including:

• responding to inquiries and requests;
• evaluating and managing prospective business relationships;
• providing information or communications requested by you;
• communicating with business contacts;
• sending marketing communications where permitted by applicable law;
• operating, maintaining, securing, and improving the Website;
• detecting, preventing, and investigating fraud, misuse, security incidents, or other unlawful activity;
• complying with legal, regulatory, or governmental requirements; and
• establishing, exercising, or defending Nobel’s legal rights and interests.

Nobel does not sell, rent, or trade personal information to third parties for their own marketing purposes.

4. How We Determine the Appropriate Basis for Processing

Nobel uses personal information only where permitted by applicable law.

Depending on the circumstances, Nobel may rely on:

• your consent, where consent is required or appropriate;
• a legitimate and reasonable purpose permitted by applicable law;
• steps taken at your request in connection with a potential contractual or business relationship;
• performance of a contract;
• compliance with a legal or regulatory obligation;
• protection or defence of legal rights; or
• another basis permitted by applicable law.

Where Nobel relies on consent, you may withdraw that consent where permitted by applicable law. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

5. Contact Forms and Marketing Communications

When you submit an inquiry through the Website, Nobel may request information reasonably necessary to respond to your request.

Nobel may contact you by email, telephone, or other appropriate business communication channels to respond to your inquiry, provide requested information, clarify your requirements, or discuss a potential business relationship.

You may request that Nobel cease further inquiry-related communications at any time by contacting legal@nobelglobe.com. If you request that Nobel cease communications necessary to respond to your inquiry, Nobel may be unable to provide a complete response to that inquiry.

Where marketing communications are subject to consent requirements, Nobel will obtain the required consent. Marketing communications may include an unsubscribe mechanism or other means of withdrawing consent where required by applicable law.

6. Disclosure of Personal Information

Nobel may disclose personal information to:

• service providers, contractors, and other third parties that provide services on Nobel’s behalf;
• professional advisers, auditors, insurers, and similar service providers;
• regulators, governmental authorities, courts, or law enforcement where required or permitted by law;
• third parties where necessary to protect Nobel’s rights, property, security, or the safety of individuals;
• parties involved in a merger, acquisition, restructuring, financing, sale, or other business transaction; or
• other persons where you have provided appropriate consent or directed Nobel to make the disclosure.

Where appropriate, Nobel may create aggregated, anonymised, or de-identified information from personal information. To the extent such information no longer identifies an individual and is not reasonably capable of being re-associated with an individual, Nobel may use such information for purposes including analytics, reporting, service improvement, benchmarking, and business planning.

7. Security

Nobel maintains reasonable administrative, technical, and organisational safeguards designed to protect personal information against loss, unauthorised access, destruction, use, modification, disclosure, or other misuse.

Depending on the circumstances, safeguards may include:

• access controls;
• authentication and authorisation measures;
• encryption or secure transmission technologies, including HTTPS where applicable;
• need-to-know access restrictions;
• security monitoring and related controls; and
• appropriate security requirements for relevant service providers.

No method of transmission or storage can be guaranteed to be completely secure, and Nobel does not guarantee absolute security.

8. Retention

Nobel retains personal information only for as long as reasonably necessary for the purposes for which it is used, or as required or permitted by applicable law.

Retention periods may vary depending on the nature of the information, the purpose for which it was collected, the existence of an ongoing business relationship, legal or regulatory requirements, and legitimate business, security, or dispute-management needs.

Contact-form and inquiry information may typically be retained for up 24 months following the last relevant interaction, unless a longer retention period is reasonably required for legitimate business, legal, regulatory, security, or dispute-related purposes.

9. International Transfers

Nobel operates internationally and may use service providers, infrastructure, or other third parties located outside Bermuda. As a result, personal information may be transferred to or accessed from jurisdictions outside Bermuda.

Where personal information is transferred to an overseas third party, Nobel will take steps required by applicable law to assess the level of protection provided and to implement appropriate safeguards.

Depending on the circumstances and applicable legal requirements, such safeguards may include contractual protections, standard contractual clauses, binding corporate rules, recognised certification mechanisms, or other approved transfer mechanisms or safeguards.

10. Your Privacy Rights

Subject to applicable law, you may have rights relating to your personal information, including the right to:

• request access to personal information held by Nobel about you;
• request correction of inaccurate or incomplete personal information;
• request that Nobel cease or not begin certain uses of your personal information, including for advertising, marketing, or public relations;
• request erasure or destruction of personal information where applicable;
• request information about the purposes for which your personal information is used and the persons or types of persons to whom it may be disclosed; and
• make a complaint to the relevant privacy or data protection authority.

You may also have additional rights under other applicable data protection laws.

Requests should be submitted in writing to legal@nobelglobe.com. Nobel may take reasonable steps to verify your identity before processing a request.

Nobel will respond to valid requests within the timeframes required by applicable law.

11. Children

The Website and Nobel’s business activities are directed primarily toward businesses, enterprises, and carrier or telecommunications customers.

The Website is not intended to be directed at children. Nobel does not knowingly seek to collect personal information from children through the Website.

If Nobel becomes aware that personal information has been collected from a child in circumstances where applicable law requires additional protections, Nobel will take appropriate steps in accordance with applicable law.

12. Third-Party Websites and Services

The Website may contain links to third-party websites, platforms, or services.

Nobel is not responsible for the privacy practices, security, content, or policies of third parties. Any use of third-party websites or services is subject to the terms and privacy policies applicable to those third parties.

13. Changes to This Privacy Policy

Nobel may update this Privacy Policy from time to time to reflect changes in its practices, services, technology, or applicable legal requirements.

The updated version will be posted on the Website with a revised “Last Updated” date. Where required by applicable law, Nobel will provide additional notice or obtain consent for material changes.

14. Contact and Privacy Officer

For privacy-related questions, requests, or complaints, you may contact Nobel’s designated privacy officer at:

Nobel, LTD.

7 Church Street, Dorchester House Hamilton, Pembroke, HM 11 Bermuda

Company Registration No.: 33115

Privacy Email: legal@nobelglobe.com

COOKIE POLICY

1. Introduction

This Cookie Policy explains how Nobel, LTD., a company organized and existing under the laws of Bermuda, with registered number 33115 and registered address at 7 Church Street, Dorchester House, Hamilton, Pembroke, HM 11, Bermuda (“Nobel,” “we,” “us,” or “our”), uses cookies and similar technologies on our website (the “Website”), and how you can control them.

This Cookie Policy should be read together with our Privacy Policy, which explains more generally how we collect, use, disclose, retain, and safeguard personal information, and our Terms & Conditions / Terms of Use, which govern your use of the Website.

This Cookie Policy applies to the Website only. It does not govern cookies or similar technologies used in connection with commercial services provided under separate written agreements or in third-party platforms operated by Nobel’s partners.

2. What Are Cookies and Similar Technologies?

Cookies are small text files that are stored on your device when you visit a website. They allow a website to recognise your device, remember certain preferences, support functionality, and understand how the Website is used.

Cookies may be session cookies, which generally expire when you close your browser, or persistent cookies, which remain on your device for a defined period or until they are deleted or expire.

We may also use similar technologies, including:

• Pixels or web beacons — technologies that may help us understand whether a webpage or communication has been accessed or viewed;
• Local storage or session storage — technologies that allow information to be stored locally on your device; and
• Tags and scripts — technical elements used to provide functionality, analytics, security, or other Website features.

In this Cookie Policy, we refer to cookies and similar technologies collectively as “cookies,” unless otherwise stated.

3. Categories of Cookies We May Use

The cookies used on the Website may fall into the following categories.

3.1 Strictly Necessary Cookies

These cookies are necessary for the operation, security, and basic functionality of the Website.

They may be used for purposes such as:

• enabling page navigation and core Website functionality;
• maintaining security and preventing misuse;
• supporting network and load management; and
• remembering your cookie preferences.

These cookies generally do not require consent where they are strictly necessary for the operation or security of the Website, subject to applicable law.

A current list of strictly necessary cookies used on the Website, together with their purposes and retention periods, is available through the Website’s cookie settings panel where technically and practically available.

3.2 Performance and Analytics Cookies

These cookies may help us understand how visitors use the Website and improve its performance, usability, and content.

They may collect information such as:

• pages visited;
• approximate time spent on pages;
• referring websites or traffic sources;
• Website interactions;
• error or performance information; and
• aggregated usage information.

Where required by applicable law, these cookies will only be used after obtaining your consent.

3.3 Functional Cookies

These cookies may allow the Website to remember choices or preferences, such as language, region, or display settings, and may support enhanced Website functionality.

Where required by applicable law, these cookies will only be used after obtaining your consent.

3.4 Marketing and Advertising Cookies

If Nobel uses marketing or advertising technologies on the Website, these cookies may be used for purposes such as:

• measuring the effectiveness of marketing activities;
• understanding interactions with marketing content;
• supporting remarketing or retargeting; or
• delivering advertising or content that may be relevant to business users.

Where required by applicable law, these cookies will only be used after obtaining your consent.

If Nobel does not use marketing or advertising cookies on the Website, this category will not be activated.

4. Third-Party Cookies

Certain cookies may be placed by third-party service providers whose technologies are integrated into the Website.

Depending on the technologies actually used by Nobel, these may include providers supporting:

• analytics;
• Website security;
• hosting or content delivery;
• customer relationship management;
• marketing automation; or
• advertising and remarketing.

The specific third-party cookies currently used on the Website, together with their purposes and retention periods, should be identified in the Website’s cookie consent mechanism or cookie settings panel.

Third-party providers may process information in accordance with their own privacy and cookie policies. Nobel does not control the privacy practices of third parties and encourages you to review their applicable policies.

Where Nobel has entered into appropriate contractual arrangements with relevant third-party service providers, Nobel will seek to ensure that personal information is processed in accordance with applicable data protection requirements.

5. Consent and Legal Basis

Nobel will use cookies in accordance with applicable privacy and data protection laws.

Where applicable law requires consent for the use of non-essential cookies, Nobel will request your consent before placing or accessing those cookies.

Depending on the circumstances and applicable law:

• strictly necessary cookies may be used without consent where they are necessary for the operation or security of the Website;
• analytics, functional, marketing, and other non-essential cookies may require consent;
• consent will be requested through an appropriate cookie consent mechanism where required;
• you may withdraw or change your consent at any time through the available cookie settings; and
• withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Nobel will seek to provide clear information about the purposes of cookies and, where applicable, the third parties relying on consent.

6. How to Control Cookies

6.1 Through Our Cookie Consent Mechanism

Where a cookie consent mechanism is used, you may be provided with options to:

• accept all cookies;
• reject non-essential cookies; or
• customise your preferences by cookie category.

Where required by applicable law, Nobel will not set or access non-essential cookies before obtaining the required consent.

Where available, you may change your preferences at any time through the “Cookie Settings” link on the Website.

6.2 Through Your Browser

Most browsers allow you to:

• view cookies stored on your device;
• delete existing cookies;
• block cookies from particular websites;
• block certain or all cookies; and
• configure other cookie preferences.

Please note that disabling certain cookies may affect the functionality or performance of the Website.

7. Cookie Retention

Cookie retention periods depend on the type and purpose of each cookie.

• Session cookies generally expire when you close your browser.
• Persistent cookies remain on your device for a defined period or until they are deleted or expire.

The specific retention period applicable to each cookie should be identified in the Website’s cookie consent mechanism or cookie settings panel where technically and practically available.

Nobel will periodically review the cookies used on the Website and their respective purposes and retention periods.

8. Do Not Track and Similar Signals

Some browsers and devices may transmit “Do Not Track” (“DNT”) or similar preference signals.

There is no universally accepted technical standard governing DNT signals. Unless otherwise required by applicable law, the Website may not respond to DNT signals.

Where applicable law requires Nobel to recognise a legally recognised privacy or opt-out preference signal, Nobel will take reasonable steps to comply with that requirement.

9. Changes to This Cookie Policy

Nobel may update this Cookie Policy from time to time to reflect changes in technology, applicable law, our practices, or the cookies and similar technologies used on the Website.

The updated version will be posted on the Website with a revised “Last Updated” date.

Any changes to the categories of cookies used on the Website will be reflected in the cookie settings panel, where applicable.

Where required by applicable law, Nobel will provide additional notice or obtain consent in connection with material changes.

10. Contact

For questions about this Cookie Policy or Nobel’s use of cookies, you may contact:

Nobel, LTD.

7 Church Street, Dorchester House

Hamilton, Pembroke, HM 11

Bermuda

Company Registration No.: 33115

Privacy Email: legal@nobelglobe.com