NOBL Air Privacy Notice
NOBL Air™ Privacy Notice
This NOBL Air™ Privacy Notice ("Notice") explains how Nysonian, Inc. (d/b/a NOBL Travel) ("we", "us", or "our") processes Personal Data in connection with the NOBL Air™ Bluetooth tracking device and its associated services when used by individuals in the United Kingdom.
This Notice supplements our UK Privacy Section, which contains general information about our data processing. Where there is any conflict between the general policy and this Notice in relation to NOBL Air™, this Notice prevails.
1. About NOBL Air™
NOBL Air™ is a small Bluetooth tracking device designed to help you locate personal items such as luggage, bags, and belongings. The device emits a Bluetooth Low Energy (BLE) signal that can be detected by compatible smartphones and devices, including those participating in the NOBL Air™ network. Through this network, the approximate location of your NOBL Air™ device can be reported back to you when it is in range of a participating device.
2. Who Is the Data Controller?
Nysonian, Inc. is the data controller for Personal Data processed in connection with NOBL Air™. We have appointed a UK Representative under Article 27 of the UK GDPR. Their details are provided in Section 12 below.
3. Personal Data We Process
We process the following categories of Personal Data in connection with NOBL Air™:
3.1 Registered Owner Data
When you set up a NOBL Air™ device, we process information including:
- Your name and account details
- Contact information (email, phone)
- Device identifier(s) linking the NOBL Air™ to your account
- Purchase and warranty information
3.2 Location Data
We process approximate location data of NOBL Air™ devices in the following circumstances:
- From your own devices: When your smartphone or other devices report the location of your NOBL Air™.
- From the NOBL Air™ network: When another participating device in the network reports the presence of a NOBL Air™ in its vicinity. These reports are transmitted in an encrypted form and contributing devices are not identified to the NOBL Air™ owner.
- From devices that are not part of the network: Where third-party platforms (such as unwanted tracker detection on iOS or Android) interact with NOBL Air™ for safety purposes.
Location data is approximate and based on the location of the device that reports the NOBL Air's presence. We do not process continuous precise location streams.
3.3 Anti-Stalking Detection Data
To support anti-stalking and unwanted tracking detection, NOBL Air™ may transmit signals that allow detection by both iOS and Android devices, including detection by individuals other than the registered owner. This processing is described further in Section 7 below.
3.4 App and Network Interaction Data
When you use the NOBL Travel app or interact with the NOBL Air™ network, we process:
- Device information (operating system, app version)
- Interaction logs (login times, feature usage)
- Crash reports and diagnostic data
4. Lawful Bases for Processing
We rely on the following lawful bases under Article 6 of the UK GDPR:
| Processing Activity | Lawful Basis |
|---|---|
| Operating the location tracking service for registered owners | Performance of a contract (Art. 6(1)(b)) |
| Processing location data contributed by network participants | Legitimate interests (Art. 6(1)(f)) supporting lost item recovery |
| Operating anti-stalking and unwanted tracker detection features | Legitimate interests (Art. 6(1)(f)) protecting individuals from misuse |
| Account creation, billing, and customer support | Performance of a contract (Art. 6(1)(b)) |
| Compliance with legal obligations | Legal obligation (Art. 6(1)(c)) |
| Marketing communications | Consent (Art. 6(1)(a)) |
Where we rely on legitimate interests, we have conducted a Legitimate Interests Assessment (LIA) and you have the right to object to such processing as described in Section 9.
5. Data Protection Impact Assessment
In accordance with Article 35 of the UK GDPR, we have conducted a Data Protection Impact Assessment (DPIA) for NOBL Air™ location data processing. The DPIA identifies the risks associated with this processing and the measures we have implemented to mitigate them, including:
- Encryption of location data in transit and at rest
- Anonymization of contributing devices in the network
- Limited retention periods
- Anti-stalking detection features to protect non-owners
- Strict access controls to location data
- Regular security testing
A summary of the DPIA is available on request from our UK Representative.
6. Retention of NOBL Air™ Data
We retain NOBL Air™ data for the following periods:
| Data Category | Retention Period |
|---|---|
| Registered owner account data | Duration of account, plus 2 years thereafter |
| Active location data (last known location displayed to you) | 24 hours from receipt |
| Historical location data (aggregated) | Up to 7 days for service operation purposes |
| Anti-stalking detection event logs | 90 days |
| App diagnostic and crash data | 90 days |
| Customer support correspondence | 3 years from last contact |
| Records required for legal compliance | As required by applicable law |
7. Anti-Stalking and Unwanted Tracking Detection
We take the misuse of tracking devices seriously. NOBL Air™ includes the following anti-stalking measures:
7.1 Audible Alerts
A NOBL Air™ device that has been separated from its registered owner for an extended period will emit an audible alert at intervals. This alert is designed to draw attention to the device and help individuals discover it if they are unaware it is travelling with them.
7.2 Cross-Platform Detection
NOBL Air™ devices can be detected by:
- iOS devices: Through Apple's built-in unwanted tracker detection features
- Android devices: Through Google's built-in unwanted tracker detection features
- Our own NOBL Travel app: Through manual scanning for unfamiliar NOBL Air™ devices
This means that even if you do not own a NOBL Air™, your smartphone may notify you if an unknown NOBL Air™ has been travelling with you for an extended period.
7.3 If You Believe You Are Being Tracked
If you suspect you are being tracked by an unknown NOBL Air™ device:
- Use your smartphone's unwanted tracker detection. Both iOS and Android can identify nearby NOBL Air™ devices that may be travelling with you.
- Listen for audible alerts. A NOBL Air™ separated from its owner will emit periodic sounds.
- Locate and disable the device. Once identified, the device can be disabled by removing its battery.
- Contact us. We can provide additional information about a NOBL Air™ device if you have located one. Contact details are in Section 12.
- Contact law enforcement. If you believe you are in immediate danger, please contact local police. In the UK, dial 999 for emergencies or 101 for non-emergency reporting.
We cooperate with law enforcement investigations in accordance with applicable law.
8. Recipients of NOBL Air™ Data
We share NOBL Air™ data with the following categories of recipients:
- Service providers: Cloud hosting providers, app analytics providers, customer support platforms, and other vendors who process data on our behalf under contract.
- Network participants: Other NOBL Air™ users contribute location data to the network in encrypted, anonymized form. The identity of contributing devices is not disclosed to NOBL Air™ owners.
- Law enforcement: Where required by law or in response to a valid legal request, we may disclose data to support investigations, including stalking investigations.
- Successors in interest: In the event of a merger, acquisition, or business transfer, data may be transferred as part of the transaction subject to the protections described in this Notice.
9. Your Rights
You have the following rights under the UK GDPR in relation to NOBL Air™ data:
- Access: Request a copy of the Personal Data we hold about you and your NOBL Air™ devices.
- Rectification: Request correction of inaccurate or incomplete data.
- Erasure: Request deletion of your Personal Data, subject to certain exceptions.
- Restriction: Request that we limit our processing of your data.
- Portability: Request a copy of your data in a portable format.
- Object: Object to processing based on legitimate interests, including processing for anti-stalking detection or network contribution.
- Withdraw consent: Where we process your data on the basis of consent (e.g., marketing communications), you can withdraw consent at any time.
You also have the right not to be subject to solely automated decision-making that produces legal or similarly significant effects. We do not make such decisions in connection with NOBL Air™.
To exercise these rights, contact our UK Representative using the details in Section 12.
10. International Transfers
NOBL Air™ data may be transferred outside the UK, including to the United States and Canada, for processing. Where such transfers occur:
- Transfers to Canada are made under the UK adequacy decision for Canada
- Transfers to the United States are made under the UK-US Data Bridge (where the recipient is certified) or under the UK International Data Transfer Agreement or UK Addendum to the EU Standard Contractual Clauses
- Transfers to other countries are made under appropriate UK GDPR Chapter V safeguards
A copy of the relevant safeguards is available on request.
11. Right to Complain
If you have concerns about how we process NOBL Air™ data, please contact our UK Representative first. You also have the right to lodge a complaint with the UK Information Commissioner's Office (ICO).
12. Contact Us
For any matter relating to NOBL Air™ data, please contact:
UK Representative: [Name] [UK Address] [Email] [Phone, if applicable]
NOBL Travel: Nysonian, Inc. (d/b/a NOBL Travel)
Email: help@nobltravel.com
13. Updates to This Notice
We may update this Notice from time to time. Where the changes are material, we will notify you by email (where we hold a current contact email) and by prominent notice on our Services and within the NOBL Travel app. Material changes will take effect no sooner than 30 days after notification unless an immediate change is required by law.