Novus Partners, Inc.

Privacy Policy

Last Updated: 5/24/18

We at Novus Partners, Inc. (“Novus,” “we,” “us,” or “our”) have created this privacy policy (this “Privacy Policy”) because we know that you care about how information you provide to us is used and shared. This Privacy Policy applies to information received by Novus via the website located at www.novus.com and alpha.novus.com (together, the “Website”) and any Personal Information (as defined below), received by Novus about EU individuals.

By becoming a Registered User via the Website, you acknowledge that you have read, understood, and agree to be legally bound by this Privacy Policy and our Terms of Use, which are hereby incorporated by reference (collectively, this “Agreement”). If you do not indicate your agreement with these Terms of Use and Privacy Policy by clicking where indicated below, you will not be permitted to use the Service.

Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in the Terms of Use.

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”).

Personal Information

For purposes of this Privacy Policy, “Personal Information” means any information or set of information that identifies or could be used by or on behalf of Novus to identify a natural person. The only Personal Information Novus collects relating to a natural person is name, phone number, and email address, provided that Novus may also collect the name of your employer and your employment title with your employer. Personal Information does not include information regarding corporate entities or information that is encoded or anonymized, or publicly available information that has not been combined with non-public Personal Information.

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.

Other Information

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.
  • From Cookies and JavaScript Tags. Information that we or our technology providers collect using “cookie” technology and JavaScript tags. Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. 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 help us collect Other Information and to enhance your experience using the Website. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website may not function properly. We use JavaScript tags to trigger a sequence of events that includes viewing a first-party cookie (or setting that cookie if it does not already exist) and to help us tailor and optimize our Website and provide you relevant Novus advertisements outside of our Website.

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.

  • We may employ other companies and individuals to perform functions on our behalf, including providing technical assistance and support for our networks, customer service, business consulting services, data management and storage. These other companies will have access to the Personal Information and the Other Information only as necessary to perform their functions and to the extent permitted by law. In addition, we maintain agreements with such third parties that they may not use your Personal Information and Other Information other than for purposes of fulfilling their obligations to us. If we learn that an agent is using or disclosing Personal Information or Other Information in a manner contrary to this Privacy Policy, we will take reasonable steps to prevent or stop such unauthorized use or disclosure.
  • 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.
  • In cases of onward transfer to third parties of data of EU and/or Swiss individuals received pursuant to the Privacy Shield Frameworks, Novus is potentially liable.
  • 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 privacy@novus.com. 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 complies with the EU-US Privacy Shield Framework and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries. Novus has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this Privacy Policy, or the website Terms of Use, and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

Novus is subject to the investigatory and enforcement authority of the United States Federal Trade Commission (FTC).

In compliance with the EU and Swiss Privacy Shield Principles, Novus commits to resolve complaints about your privacy and our collection or use of your Personal Information. European Union and/or Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact Novus at: privacy@novus.com.

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.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

Changes to This Privacy Policy.

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Please be aware that, to the extent permitted by applicable law, our use of the Personal Information and Other Information is governed by the Privacy Policy in effect at the time we collect the information. Please refer back to this Privacy Policy on a regular basis.

How to Contact Us.

If you have questions about this Privacy Policy, please contact Novus via e-mail at privacy@novus.com, with “PRIVACY POLICY” in the subject line or at the contact information set forth in the Contact page of the Website.