Effective Date: February 25, 2019
The Information We Collect
Novus collects the following types of information, both directly from you and indirectly through our third-party service providers (our “Providers”).
Novus collects the Personal Information identified above for specific and limited purposes. When we or our Providers collect Personal Information, we or our Providers will inform the individuals of these purposes and the choices and means, if any, offered to such individuals for limiting the use and disclosure of that Personal Information. We or our Providers will endeavor to provide such notice in clear and conspicuous language when individuals are first asked to provide Personal Information or as soon as practicable thereafter.
Examples of different purposes for which we may collect Personal Information include, but are not limited to (i) the user registration process; and (ii) responding to a request from you for information regarding our products and services.
In addition to the Personal Information, we may collect additional information on the Website (collectively, the “Other Information”). Such Other Information may include:
- From Your Activity. Information that we or our technology providers may automatically collect when you visit, access, and/or use the Website, such as your IP addresses, Internet service provider, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, what sections of the Website you visit, number of links you click while on the Website, search terms, and operating system.
How We Use and Share the Information
We use the Personal Information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Novus will take reasonable steps to ensure that the Personal Information is relevant to its intended use, accurate, complete, and current.
We may also use and/or share the Personal Information and the Other Information as described below.
- In an ongoing effort to better understand visitors to our Website and our products and services, we may analyze the Other Information in aggregate form in order to operate, maintain, manage, and improve the Website and/or our products and services. This aggregate information does not identify individuals personally. We may share this aggregate data with our affiliates, Providers, agents, and business partners. We may also disclose aggregated user statistics in order to describe our products and services to current and prospective business partners and to other third parties for other lawful purposes.
- We may share some or all of the Personal Information and Other Information with any of our parent companies, subsidiaries, or other companies under common control with us.
- As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Personal Information and Other Information may be part of the transferred assets.
- To the extent permitted by law, we may also disclose the Personal Information and the Other Information: (i) to government and regulatory agencies in connection with our seeking regulatory approval for our products; (ii) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (iii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of Novus or others. Note that we may be required to release EU and/or Swiss Personal Information in response to lawful requests by public authorities including to meet national security and/or law enforcement requirements.
- Pursuant to the Privacy Shield, Novus remains liable for the transfer of personal data to third parties acting as our agents unless we can prove we were not a party to the events giving rise to the damages.
- It is our current policy to not share Personal Information with non-agent third parties. If we ever were to engage in any onward transfers of your data with third parties for a purpose other than which it was originally collected or subsequently authorized, we would update this policy and provide you with an opt-out choice to limit the use and disclosure of your personal data.
Accessing and Modifying Information; Communication Preferences
Upon request, Novus will grant individuals reasonable access to Personal Information that we and our Providers or agents hold about them. For example, visitors to the Website who have provided Personal Information to us may review and/or make changes to the same by contacting Novus. In addition, individuals may manage their receipt of marketing communications by clicking on the “unsubscribe” link located on the bottom of any Novus marketing e-mail or by following the instructions found on the Website. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. Novus acknowledges that EU individuals and Swiss individuals have the right to access, correct or delete the Personal Information that we maintain about them. An EU or Swiss individual who seeks access, or who seeks to correct, amend, or delete data, should direct his query to firstname.lastname@example.org. We will respond to such request within a reasonable timeframe.
How We Protect the Information
We take commercially reasonable steps to protect the Personal Information and Other Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Website may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.
Important Notices to Non-U.S. Residents/Privacy Shield Certification
EU-US and Swiss-US Privacy Shield Frameworks
Novus is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).
Novus has further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles to an independent dispute resolution mechanism, BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. This resource is provided at no cost to you.
Recourse for EU & Swiss Human Resources Data Transferred into the US
If your complaint involves human resources data transferred to the United States from the EU and/or Switzerland in the context of the employment relationship, and Novus Partners does not address it satisfactorily, Novus Partners commits to cooperate with the panel established by the EU data protection authorities (DPA Panel) and/or the Swiss Federal Data Protection and Information Commissioner, as applicable and to comply with the advice given by the DPA panel and/or Commissioner, as applicable with regard to such human resources data. To pursue an unresolved human resources complaint, you should contact the state or national data protection or labor authority in the appropriate jurisdiction. Complaints related to human resources data should not be addressed to the BBB EU PRIVACY SHIELD.
Contact details for the EU data protection authorities can be found at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm
Contact details for the Swiss Federal Data Protection and Information Commissioner can be found at https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/links/data-protection—switzerland.html
If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introductionChanges
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