Effective Date: February 23, 2021
Information We Collect
Information You Provide:
Certain areas of our website allow you to submit information to us. We may collect information that either directly identifies you or could reasonably be used in combination with other publicly available information to identify you (personal information). We may aggregate that personal information and certain non-personally identifiable information as well.
Personal information includes, but is not limited to, the following data:
- First name and last name
- Username and password
- Email address
- Phone number
- Street address
- Country of residence
- Transaction and payment information
Depending on your site usage (e.g. credit card purchase, report download, etc.), you might not need to provide some of the aforementioned information, but in some cases, you may not be able to access all parts of our website if you choose not to provide your information.
Information We Collect Automatically:
We may also automatically collect other basic information about you that does not directly identify you, but may correspond with you, your browser, or a particular device. This includes the following data:
- Device information (e.g. OS type or browser type)
- Internet Protocol (IP) address
- Browser device (e.g. laptop or mobile)
- Website usage (e.g. pages viewed, amount of time on page, exit URLs, etc.)
- Preferred language
- Cookie ID
We may collect this data using the techniques described below:
Cookies. Our website may use a tracking technology called a “cookie.” A cookie is a small file placed on your device when you visit a website that can be understood by the website that issued the cookie. Cookies enable a website to “remember” the information a user has previously inputted, or in some cases, certain other sites that the user has visited. Cookies may be placed on your computer both by us and by third parties with whom we have a relationship.
The information we collect using cookies and similar technologies may or may not be personally identifiable, but we may link it to personal information that you provide. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. Users do not need to have cookies turned on to visit our website, but may need them to use certain customizable features on the website that we may launch in the future.
Web Beacons and Pixels. We may use other, similar technologies from time to time, like web beacons, pixels (or “clear gifs”), and other tracking technologies. Pixels are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our website. This allows us, for example, to monitor the traffic patterns of visitors from one page within our website to another, to deliver or communicate with cookies, to understand whether you have come to our Site from an online advertisement displayed on a third-party website, to improve site performance, to serve targeted advertisements to you and others like you, and to measure the success of marketing campaigns.
Tracking Technologies. If you would like to opt-out of having interest-based information collected by certain entities during your visits to our Site or other websites, please visit http://www.aboutads.info/choices/. You will be directed to an industry-developed website that contains mechanisms for choosing whether each listed entity may collect and use data for online behavioral advertising purposes. It may be that some of the third parties that collect interest-based information on our Site do not participate in the industry-developed opt-out website, in which case the best way to avoid third-party tracking of your online behaviors may be through your browser settings and deletion of cookies.
Our Response to Do Not Track Signals: Certain web browsers and other programs may be used to signal your preferences regarding how or whether Novae or third parties may collect information about your online activities. Currently, our website does not respond to such signals.
How We Collect Information
The following events are some ways in which we would collect your information:
- When you register for an account;
- When you purchase a product or service;
- When you submit a request for a product, service, or information;
- When you participate in public forums on our website;
- When you respond to a customer survey; and
- When you register for a conference on our website.
How We Use Information
The following events are some ways in which we would use your data to optimize user experience:
- Processing orders and requests
- Sending relevant information (product information, policy updates, event announcements, etc.)
- Responding to your questions and concerns
- Offering personalized promotions
- Providing products and services
- Providing more individualized customer service
- Remembering your user preferences (language, content, etc.)
- Conducting site improvements
- For security, credit or fraud prevention purposes
- Improving the content, functionality, and usability of our website
- For any other purpose identified in an applicable privacy notice, click-through agreement, or other agreement between you and us
Use of Aggregated Information. We may use information gathered through our website to create a compiled, aggregate view of our website audience and their website usage patterns (aggregated information). We use aggregated information to operate our services and to better understand our audience as we develop new products and services. We may also share aggregated information with our third-party business partners and service providers, as well as with potential investors, advertisers, and subscribers so they can better understand and/or market to our audience.
How We Share Information
Novae may share your information as follows:
We may share the information we collect with our affiliates, including our parent company, our subsidiaries, and other affiliated entities.
We may disclose information to third parties who provide us with various business services (service providers). If we work with service providers and disclose your information, these entities are only granted access to your information to the extent in which they can do their jobs. They may perform some of the following functions on our behalf:
- Email contact
- Data management
- Credit card and payment processing
- Customer service
We may also disclose information we collect in special cases, including when we have a reason to believe that such disclosure is necessary to identify, contact, or bring a legal action against someone who may be causing injury to or interfering with our rights and property or those of any other person. We may also disclose information when we believe the law requires it and in any situation that involves threats to any person’s physical safety. We also disclose information where required by law, including when required by laws, court orders, or government regulations.
In General. We respect your right to make choices about the ways we collect, use and disclose your personal information. In most cases, we will ask you to indicate your choices at the time we collect your personal information.
Previously Expressed Preferences. You may change previously expressed preferences regarding how we use your personal information.
Do Not Track Mechanisms. Because of the changing state of technology and indecision within the industry regarding the meaning of DNT signals, we currently do not make any guarantee that we will honor DNT signals.
How to Access, Update or Correct Your Personal Information: You can access, update or correct personal information by emailing us at email@example.com. We will respond to you within a reasonable time and, in any case, within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identify.
The California Consumer Privacy Act of 2018 (CCPA) gives California residents certain rights with respect to their personal information. To learn more, please see our CCPA Notice.
How We Protect Your Information
We maintain reasonable administrative, physical, and technical measures to protect the security of your personal information you submit on or through our website. However, no website, server or database is completely secure or “hacker proof.” Therefore, we cannot guarantee that your personal information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. If you create on our website, it is your responsibility to protect your login credentials from unauthorized access or use.
Children and Privacy
Our website is not intended for or directed towards children. We do not knowingly collect personally identifiable information from children who are 16 years of age or younger. If you have reason to believe that a child under 16 has provided us with personally identifiable information, please contact us at firstname.lastname@example.org.
Supplemental Notice for California Consumers
Effective Date: February 23, 2021
This Supplemental Notice for California Consumers (“Supplemental Notice”) provides information required under the California Consumer Privacy Act and its associated regulations (“CCPA”) and describes California residents’ right to know, right to delete, and right to object to the sale of Personal Information that Novae LLC (“Novae”, “we”, “us”, or “our”) collected about them. Please note that any terms defined in the CCPA have the same meaning when used in this Supplemental Notice. Any terms defined in the CCPA have the same meaning when used in this Supplemental Notice.
Definitions Specific to this Policy
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include publicly available information obtained from government records, deidentified or aggregated consumer information that cannot be reconstructed to identify you, any information covered under the Gramm-Leach-Bliley Act or the California Financial Information Privacy Act, activities covered by the Fair Credit Reporting Act, or protected health information as defined under the Health Insurance Portability and Accountability Act.
“Sale” or “sell” means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by us to another business or a third party for monetary or other valuable consideration.
“Service Provider” means a sole proprietorship, partnership, limited liability company, corporation, association, or other legal entity that is organized or operated for the profit or financial benefit of its shareholders or other owners, that processes information on behalf of us and to which we disclose a consumer’s Personal Information for a business purpose pursuant to a written contract.
“Third Party” means a person or entity that is not a Service Provider that collects Personal Information from consumers or to whom we disclose a consumer’s Personal Information.
Personal Information We Collect
We have collected and disclosed to Service Providers for our business purposes the following categories of Personal Information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, physical characteristics or description, address, telephone number, driver’s license or state identification card number, insurance policy number, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|G. Geolocation data.||Physical location or movements.|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Sources of Personal Information
The categories of sources from whom we collected this Personal Information include the following:
- Directly from a California resident or the individual’s representatives.
- Service Providers, Consumer Data Resellers, and other third parties.
- Public Record Sources (e.g. federal, state or local government sources).
- Information from our Affiliates.
- Website/Mobile App Activity/Social Media.
- Information from Client Directed Third Parties or Institutions representing a Client/Prospect.
- Information from Corporate Clients about individuals associated with the Clients (e.g., an employee or board member).
The categories of Third Parties to whom we disclosed Personal Information for our business purposes described in this Supplemental Notice are:
- Affiliates and subsidiaries of Novae
- Vendors and Service Providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure, customer service, email delivery, auditing, marketing and marketing research activities
- Partners and Third Parties who provide services such as payment, communication infrastructure, and legal expertise
- Other Third Parties who enable customers to conduct transactions online and via mobile devices, support fulfillment services, and loan processes
- Government Agencies as required by laws and regulations
Use of Personal Information
With respect to each of the categories of Personal Information relating to California residents, we may use or disclose such Personal Information for the following business purposes:
- To fulfill or meet the reason for which the information is provided. For example, if you provide us with Personal Information in order to open a banking or mortgage account;
- To provide you with information, products or services that you request from us
- To provide you with email alerts, event registrations and other statements concerning our products or services;
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;
- To detect and protect against security incidents, and malicious, deceptive, fraudulent or illegal activity, and prosecute the same;
- To identify and repair errors in our systems;
- As otherwise necessary or appropriate to protect the rights, property or safety of us, our customers, consumers, or others;
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
- For such purposes as may be necessary or appropriate in connection with audits and reporting relating to particular transactions and interactions, including online interactions, you may have with us or others on our behalf;
- To improve our website and apps and present their content to you;
- For testing, research, analysis and product development;
- For short-term, transient use including contextual customization of ads;
- As otherwise described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
Your Rights under the CCPA
The CCPA grants California residents (“consumers”) or another person authorized to act on behalf of the consumer, the following rights:
- Right to Notice. Before or at the time we collect Personal Information from you, you have the right to receive notice of the Personal Information to be collected and the purposes for which we use it.
- Right to Know. You also have the right to request that we disclose to you the categories of Personal Information we have collected about you in the preceding 12 months, along with the categories of sources from which the personal information was collected, the purpose for collecting or selling the personal information, the categories of Third Parties with whom we shared the personal information, and the categories of Third Parties with whom we sold the personal information. You may make such a request up to twice in a 12-month span.
- Right of Access. You have the right to request that we disclose or provide you with access to the specific pieces of Personal Information we have collected about you in the preceding 12 months.
- Right to Deletion. You have the right to request that we delete the Personal Information we collect from you. However, in certain situations we are not required to delete your Personal Information, such as when the information is necessary in order to complete the transaction for which the Personal Information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information.
- Right to Opt-Out of the Sale of Personal Information. If we sell your Personal Information to Third Parties, you have the right, at any time, to direct us not to sell your personal information. Please note that Novae does not sell any Personal Information we collect about you.
- Right to Not be Subject to Discrimination. We will not discriminate against you if you exercise any of your rights under the CCPA as described in this Supplemental Notice. Please note that a legitimate denial of a request for information, deletion, or to opt-out is not discriminatory, nor is charging a fee for excessive or repetitive consumer requests as permitted by the CCPA.
How to Exercise Your Rights
If you are a California resident, you may submit a request by:
- Writing to us at: One Novae Parkway, Markle, IN 46770
- Emailing us at: email@example.com
- Calling us at: 800-372-1755
We endeavor to respond to all verified requests within 45 days pursuant to the CCPA. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay. Please note that there are circumstances in which we may not be able to comply with your request pursuant to the CCPA, including when we cannot verify your request and/or when there is a conflict with our own obligations to comply with other legal or regulatory requirements. We will notify you following submission of your request if this is the case.
Verifying Your Request
We value the security and confidentiality of your Personal Information. Therefore, if you exercise your right to know, right to access, or right to deletion, we must first verify your identify to make sure that you are the person about whom we have collected Personal Information. We verify every request carefully.
When you submit your request, we ask that you:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
You may also authorize someone else to submit these requests on your behalf. To do so, you may designate directly with us another person who may act on your behalf by providing us with a notarized copy of power of attorney or ask the authorized agent to provide us with a copy of your written permission and a scanned copy of their own government-issued ID.
We will advise you in our response if we are not able to honor your request. We will not provide social security numbers, driver’s license numbers or government issued identification numbers, financial account numbers, health care or medical identification numbers, account passwords or security questions and answers, or any specific pieces of information if the disclosure presents the possibility of unauthorized access that could result in identity theft or fraud or unreasonable risk to data or systems and network security.
If you would like additional information regarding our Supplemental Notice, please contact us at 800-372-1755. California residents who are unable to review or access this Supplemental Notice due to a disability may call us at 800-372-1755 or email us at firstname.lastname@example.org to access this Supplemental Notice in an alternative format.
Changes to This California Consumer Privacy Act Notice
We reserve the right to amend this Supplemental Notice at our discretion and at any time. When we make material changes to this Supplemental Notice, we will notify you by posting an updated Supplemental Notice on our website with the effective date.