Nikola Management LLC, (“Nikola“) are committed to protecting your privacy.

We have prepared this Privacy Policy to describe to you our practices

regarding the Personal Data (as defined below) we collect from users of our

website, located at www.nikolamanagement.com(opens in a new tab) (the

“Site“) and the data, text, reports, templates, agreements and other materials

that are made available or enabled via the Site (the “Nikola Materials“)

(collectively, the “Nikola Management Site“).

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1. Questions; Contacting Nikola; Reporting Violations. If you have

any questions or concerns or complaints about our Privacy Policy or

our data collection or processing practices, or if you want to report

any security violations to us, please contact us at the following

address or phone number:

​

Nikola Management LLC

Attn: Legal and Compliance

777 S. Flagler Drive

Suite 800 - West Tower

West Palm Beach, FL 33401

​

2. A Note About Children. We do not intentionally gather Personal Data

from visitors in the US who are under the age of 13. If a child under 13

submits Personal Data to Nikola Management and we learn that the

Personal Data is the information of a child under 13, we will attempt to

delete the information as soon as possible. If you believe that we might

have any Personal Data from a child under 13, please contact us

at watson@nikolamanagement.com.

3. A Note to Users Outside of the United States. If you are a user of the

Nikola Management Site who resides in a country other than the United

States this section applies to you:

 

• If you reside in the UK or any country within the European Economic Area (“EEA“): Nikola Management LLC is the Controller (for the purposes of the General Data Protection Regulation 2016/679 (“GDPR”) and any implementing legislation or legislation having equivalent effect in the UK (together, “EU Data Protection Legislation”)) of your Personal Data.

• The legal basis of our processing of your Personal Data as described in this Privacy Policy is our legitimate interests where those interests are not overridden by the impact on you (unless our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, please contact us at the address or phone number above.

• We ask that you not provide us with any Special Category Personal Data (as defined in the GDPR), e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or trade union membership, or any criminal background information. If you do not consent to our processing and use of such sensitive information, you must not submit such sensitive information through the Nikola Management Site.

• We may transfer your Personal Data to a country outside the UK or EEA in accordance with requirements prescribed under EU Data Protection Legislation. When we transfer your Personal Data outside the UK or EEA, we hold it subject to appropriate safeguards and controls and ensure a similar degree of protection is afforded to it by implementing at least one of the following safeguards:

• We may transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en (opens in a new tab).

• If you reside in Singapore:

 

 You agree that your accessing or using the Nikola

Management Site in any way constitutes your

agreement that (a) we may process your Personal

Data for the purposes identified in the Privacy

Policy, and (b) your Personal Data may be

transferred to and processed in the country in

which it was collected and in other countries,

including the United States, where laws regarding

processing of Personal Data may be less stringent

than the laws in your country.

 We may transfer your Personal Data to a country

or territory outside Singapore in accordance with

requirements prescribed under the Singapore

Personal Data Protection Act (“PDPA“) to ensure

that we provide a standard of protection to

Personal Data so transferred that is comparable to

the protection under the PDPA. By providing your

Personal Data, you consent to such transfer.

1. Types of Data We Collect. “Personal Data”

means data that allows someone to identify or

contact you, including, for example, your name,

address, telephone number, e-mail address, as

well as any other non-public information about you

that is associated with or linked to any of the

foregoing data. “Anonymous Data” means data

that is not associated with or linked to your

Personal Data; Anonymous Data does not, by

itself, permit the identification of individual

persons. We collect Personal Data and

Anonymous Data, as described below.

 

4. Information You Provide to Us.

 

1. We may collect Personal Data from you, such as your first

and last name, e-mail, mailing address, and phone number.

 

2. If you provide us feedback, post an event or contact us via

e-mail, we will collect your name and e-mail address, as

well as any other content included in the form, in order to

send you a reply.

3. We may also collect Personal Data at other points in the

Nikola Management Site that states that Personal Data is

being collected.

 

1. Information Collected via Technology.

1. Information Collected by Our Servers. To make our Nikola

Management Site more useful to you, our servers (which

may be hosted by a third party service provider) collect

information from you, including your browser type, operating

system, Internet Protocol (“IP“) address (a number that is

automatically assigned to your computer when you use the

Internet, which may vary from session to session), domain

name, and/or a date/time stamp for your visit.

2. Log Files. As is true of most websites, we gather certain

information automatically and store it in log files. This

information includes IP addresses, browser type, Internet

service provider (“ISP“), referring/exit pages, operating

system, date/time stamp, and clickstream data. We use this

information to analyze trends, administer the Nikola

Management Site, track users’ movements around the

Nikola Management Site, and to gather demographic

information about our user base as a whole. For example,

some of the information may be collected so that when you

visit the Nikola Management Site, it will recognize you and

the information could then be used to provide information

appropriate to your interests. Except as noted in this Privacy

Policy, we do not link this automatically-collected data to

Personal Data.

3. Cookies. Like many online services, we use cookies to

collect information. “Cookies” are text files containing small

amounts of information which are downloaded to your

computer or mobile device when you visit a website or

mobile application. Cookies are then sent back to the

originating site on each subsequent visit, or to another site

that recognizes those cookies. You can find out more

information about cookies

 

at http://www.allaboutcookies.org/(opens in a new tab).

Cookies are widely used in order to make sites work, or to

work more efficiently, as well as to provide information to the

owners of the platform. We use cookies to enhance the

online experience of our visitors and to better understand

how our site is used. Cookies may tell us, for example,

whether you have visited our site before or whether you are

a new visitor. This type of information is collected to make

the Nikola Management Site more useful to you. “Cookies”

are small pieces of information that a website sends to your

computer’s hard drive while you are viewing the website.

We may use both session Cookies (which expire once you

close your web browser) and persistent Cookies (which stay

on your computer until you delete them) to provide you with

a more personal and interactive experience on the Nikola

Management Site. The Nikola Management Site uses the

following types of cookies:

Type of cookie Purpose

Cookies necessary

for essential

purposes

 

These cookies are essential to provide you with services

available through our site and to use some of its features.

 

Analytics Cookies

 

These cookies are used to collect information about how

visitors use our site.

The information gathered does not identify any individual

visitor and is aggregated. It includes the number of visitors to

our site, the sites that referred them to our site and the pages

that they visited on our site.

We use this information to help operate our site more

efficiently, to gather broad demographic information and to

monitor the level of activity on our site.

 

Performance

Cookies

 

These cookies collect information about how visitors use the

site, so that we can analyse traffic and understand how our

site is performing, including Google Analytics, on which see

more below.

 

Functionality

Cookies

 

These cookies allow our site to remember choices you make

and provide enhanced, more personal features. The

information these cookies collect may be anonymized and

they cannot track your browsing activity on other websites.

 

Social Media

Cookies

 

These cookies are used when you share information using a

social media sharing button or “like” button on our sites or

 

you link your account or engage with our content on or

through a social networking site such as Facebook, Twitter or

Google+. The social network will record that you have done

this. This information may be linked to targeting/ advertising

activities.

4. Do Not Track Browser Setting. We do not currently respond

to “do not track” signals from web browsers.

5. Pixel Tags. We may use “Pixel Tags” (also referred to as

clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny

graphic images with a unique identifier, similar in function to

Cookies, that are used to track online movements of Web

users. In contrast to Cookies, which are stored on a user’s

computer hard drive, Pixel Tags are embedded invisibly in

Web pages. Pixel Tags allow us to send e-mail messages in

a format users can read, and they tell us whether e-mails

have been opened to ensure that we are sending only

messages that are of interest to our users. We may use this

information to reduce or eliminate messages sent to a user.

We do not tie the information gathered by Pixel Tags to our

users’ Personal Data.

6. Collection of Data by Advertisers. We do not use third

parties to serve ads on the Site or collect personally

identifiable information about your online activities over time

and across different websites.

7. Google Analytics. We use Google Analytics to help analyze

how users use the Nikola Management Site. Google

Analytics uses Cookies to collect information such as how

often users visit the Nikola Management Site, what pages

they visit, and what other sites they used prior to coming to

the Nikola Management Site. We use the information we get

from Google Analytics only to improve the Nikola

Management Site. Google Analytics collects only the IP

address assigned to you on the date you visit the Nikola

Management Site, rather than your name or other

personally identifying information. We do not combine the

information generated through the use of Google Analytics

with your Personal Data. Although Google Analytics plants

a persistent Cookie on your web browser to identify you as

a unique user the next time you visit the Nikola

Management Site, the Cookie cannot be used by anyone

but Google. Google’s ability to use and share information

 

collected by Google Analytics about your visits to the Nikola

Management Site is restricted by the Google Analytics

Terms of Use and the Google Privacy Policy. You can avoid

the use of Google Analytics relating to your use of our site

by downloading and installing the browser plugin available

via this link: http://tools.google.com/dlpage/gaoptout?hl=en-

GB(opens in a new tab)

5. Use of Your Personal Data

1. General Use. In general, Personal Data you submit to us is used

to respond to requests that you make. We use your Personal Data

in the following ways:

 

 to provide improved administration of the Nikola

Management Site;

 to improve the quality of experience when you

interact with the Nikola Management Site;

 to send you follow-up communications when you

contact us via e-mail, submit feedback, or post an

event; and

 to send you administrative e-mail notifications,

such as updates regarding the Nikola

Management Site, security, or support and

maintenance advisories.

 

 Creation of Anonymous Data. We may create Anonymous

Data records from Personal Data by excluding information

(such as your name) that makes the data personally

identifiable to you. We use this Anonymous Data to analyze

request and usage patterns so that we may enhance the

content of, and improve navigation on, the Nikola

Management Site. We reserve the right to use Anonymous

Data for any purpose and disclose Anonymous Data to third

parties in our sole discretion.

 

2. Disclosure of Your Personal Data. We disclose your Personal

Data as described below and as described elsewhere in this

Privacy Policy.

3. Third Party Service Providers. We may share your Personal

Data with third party service providers to: provide you with the

Nikola Management Materials; to conduct quality assurance

testing; to provide technical support; and/or to provide other

 

services to Nikola. These third party service providers are

required not to use your Personal Data other than to provide the

services requested by Nikola.

4. Corporate Restructuring. We may share some or all of your

Personal Data with entities within our group of companies. We

may also share some or all of your Personal Data in connection

with or during negotiation of any merger, financing, acquisition or

dissolution transaction or proceeding involving sale, transfer,

divestiture, or disclosure of all or a portion of our business or

assets. In the event of an insolvency, bankruptcy, or receivership,

Personal Data may also be transferred as a business asset. If

another company acquires our company, business, or assets, that

company will possess the Personal Data collected by us and will

assume the rights and obligations regarding your Personal Data

as described in this Privacy Policy.

5. Other Disclosures. Regardless of any choices you make

regarding your Personal Data (as described in Section 8 below),

Nikola may disclose Personal Data if it believes in good faith that

such disclosure is necessary (a) in connection with any legal

investigation; (b) to comply with relevant laws or to respond to

subpoenas or warrants served on Nikola; (c) to protect or defend

the rights or property of Nikola or users of the Nikola Management

Site; and/or (d) to investigate or assist in preventing any violation

or potential violation of the law, this Privacy Policy, or our Terms of

Use.

6. Third Party Websites. The Nikola Management Site may contain

links to third party websites. When you click on a link to any other

website or location, you will leave our Site and go to another site,

and another entity may collect Personal Data or Anonymous Data

from you. We have no control over, do not review, and cannot be

responsible for, these outside websites or their content. Please be

aware that the terms of this Privacy Policy do not apply to these

outside websites or content, or to any collection of your Personal

Data after you click on links to such outside websites. We

encourage you to read the privacy policies of every website you

visit. The links to third party websites or locations are for your

convenience and do not signify our endorsement of such third

parties or their products, content or websites.

 

6. Your Choices Regarding Information. You have several choices

regarding the use of information on the Nikola Management Site:

 

1. Email Communications. We may periodically send you

free newsletters and promotional e-mails if you have

indicated that you would like us to do so. When you receive

newsletters or promotional communications from us, you

may indicate a preference to stop receiving further

communications from us and you will have the opportunity

to “opt-out” by following the unsubscribe instructions

provided in the e-mail you receive or by contacting us

directly (please see contact information above). Despite

your indicated e-mail preferences, we may send you service

related communications, including notices of any updates to

our Terms of Use or Privacy Policy.

2. Cookies. If you decide at any time that you no longer wish

to accept Cookies from the Nikola Management Site for any

of the purposes described above, then you can instruct your

browser, by changing its settings, to stop accepting Cookies

or to prompt you before accepting a Cookie from the

websites you visit. Consult your browser’s technical

information. If you do not accept Cookies, however, you

may not be able to use all portions, or all functionality, of the

Nikola Management Site. If you have any questions about

how to disable or modify Cookies, please let us know at the

contact information provided above.

3. Changing or Deleting Your Personal Data. Personal Data

submitted for document generation is deleted daily by an

automated process. Personal Data submitted for other

purposes will be retained for such period as may be

required to fulfil the purposes set out in this Privacy Policy,

or such other period as may be required by law. You may

request deletion of your Personal Data by us, and we will

use commercially reasonable efforts to honor your request,

but please note that we may be required by law to keep

such information and not delete it (or to keep this

information for a certain time, in which case we will comply

with your deletion request only after we have fulfilled such

requirements). When we delete any information, it will be

deleted from the active database, but may remain in our

archives. If you reside in the EEA, in the event that such

Personal Data remains in our archives, Nikola will ensure

that this data is put beyond use. If you reside in Singapore,

we will take commercially reasonable efforts to ensure that

 

your Personal Data in our possession or under our control is

destroyed and/or anonymized as soon as it is reasonable to

assume that (i) the purpose for which your Personal Data

was collected is no longer being served by the retention of

such Personal Data; and (ii)

4. Your Rights Regarding Your Personal Data.

a. If you reside in the UK or EEA, you have certain, you

have certain rights regarding your Personal Data and

may, in certain circumstances, ask us to take the

following actions in relation to such data:

1. provide you with information about our

processing of your Personal Data and give you

access to such data.

2. update or correct inaccuracies in your Personal

Data.

3. delete your Personal Data.

4. transfer a machine-readable copy of your

Personal Data to you or a third party of your

choice.

5. restrict the processing of your Personal Data.

6. object to our reliance on our legitimate interests

as the basis of our processing of your Personal

Data that impacts your rights.

7. If you reside in Singapore, you may request to

access and/or correct your Personal Data

currently in our possession by writing to us.

Please note that we may charge you a

reasonable fee for the handling and processing

of your requests to access your Personal Data.

7. Changes to This Privacy Policy. This Privacy Policy may be updated

from time to time for any reason. We will notify you of any changes to

our Privacy Policy by posting the new ( Privacy Policy) and we will

change the “Last Updated” date above. You should consult this Privacy

Policy regularly for any changes.