Novus Partners, Inc.

Privacy Policy

Last Updated: 6/22/2017

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 alpha.novus.com (the “Website”).

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”).

1. 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. 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 Personal Information 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.

2. 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:

a. 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.

b. 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. Examples may include providing technical assistance and customer service. 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 will obtain assurances from our agents that they will safeguard the Personal Information and Other Information consistent with this Privacy Policy and applicable law. 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, 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.

Accessing and Modifying Information; Communication Preferences

Upon request, Novus will grant individuals reasonable access to Personal Information that we and our 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.

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

It is important to note that the Website and our servers are operated in the United States. If you are located outside of the United States, please be aware that any Personal Information you provide to us will be transferred to the United States. By using the Website and by providing us Personal Information in any manner, you consent to this transfer and our use of the information and data provided by you in accordance with this Privacy Policy.

If you have any questions regarding this Privacy Policy, please contact us as described in the “How to Contact Us” section below. We will investigate your question, respond to your inquiry, and attempt to resolve any concerns regarding your privacy question.

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.