OUR COMMITMENT TO YOU
At Agency Novelus, your privacy is a top priority. We appreciate that you put your trust in us when you provide us with your information and we do not take this lightly.
We do not compromise with your privacy. We design all of our products and services with your privacy in mind. We involve experts from various fields, including legal, security, engineering, product design and others to make sure that no decision is taken without respect for your privacy.
We work hard to keep your information secure. We have teams dedicated to keeping your data safe and secure. We constantly update our security practices and invest in our security efforts to enhance the safety of your information.
We appreciate that you trust us with your information and we intend to always keep that trust. This starts with making sure you understand the information we collect, why we collect it, how it is used and your choices regarding your information. This Policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum.
- Who we are
Agency Novelus d.o.o.
- Information we collect
It goes without saying, we can’t send you e-mails or make meaningful connections with you without some information about you, such as basic details. We also collect information generated as you use our services, for example access logs, as well as information from third parties, like when you access our services through a social media account. If you want additional info, we go into more detail below.
Information you give us
You choose to give us certain information when using our services. This includes:
- When you subscribe to our e-news and blog, you provide us with information, such as your e-mail address and other information.
- When you participate in surveys or focus groups, you give us your insights into our products and services, responses to our questions and testimonials.
- When you choose to participate in our promotions, events or contests, we collect the information that you use to register or enter.
- If you contact us to say hello, ask for services and offers, we collect the information you give us during the interaction.
- Of course, we also process your chats with other users as well as the content you publish, as part of the operation of the services.
Information collected when you use our services
When you use our services, we collect information about which features you’ve used, how you’ve used them and the devices you use to access our services. See below for more details:
- Usage information
We collect information about your activity on our services, for instance how you use them (e.g. date and time you logged in, features you’ve been using, searches, clicks and pages which have been shown to you, referring webpage address, advertising that you click on)…
- Device information
We collect information from and about the device(s) you use to access our services, including:
- hardware and software information such as IP address, device ID and type, device-specific and apps settings and characteristics, app crashes, advertising IDs (such as Google’s AAID and Apple’s IDFA, both of which are randomly generated numbers that you can reset by going into your device settings), browser type, version and language, operating system, time zones, identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g. IMEI/UDID and MAC address);
- Other information with your consent
If you give us permission, we can collect your precise geolocation (latitude and longitude) through various means, depending on the service and device you’re using, including GPS, Bluetooth or Wi-Fi connections. The collection of your geolocation may occur in the background even when you aren’t using the services if the permission you gave us expressly permits such collection. If you decline permission for us to collect your geolocation, we will not collect it.
- Cookies and other similar data collection technologies
Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) have a ‘Do Not Track’ (‘DNT’) feature that tells a website that a user does not want to have his or her online activity tracked. If a website that responds to a DNT signal receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many businesses, including Novelus, do not currently respond to DNT signals.
- How we use information
The main reason we use your information is to deliver and improve our services. Additionally, we use your info to help keep you safe. Read on for a more detailed explanation of the various reasons we use your information, together with practical examples.
To provide our services to you
- Provide you with customer support and respond to your requests
- We send you e-news and blog updates
- Communicate with you about our services, including order management and billing
To serve you relevant offers and ads
- Administer sweepstakes, contests, discounts or other offers
- Develop, display and track content and advertising tailored to your interests on our services and other sites
- Communicate with you by e-mail, phone, social media or mobile device about products or services that we think may interest you
To improve our services and develop new ones
- Administer focus groups and surveys
- Conduct research and analysis of users’ behavior to improve our services and content (for instance, we may decide to change the look and feel or even substantially modify a given feature based on users’ behavior)
- Develop new features and services (for example, we may decide to build a new interests-based feature further to requests received from users).
To prevent, detect and fight fraud or other illegal or unauthorized activities
- Address ongoing or alleged misbehavior on and off-platform
- Perform data analysis to better understand and design countermeasures against these activities
- Retain data related to fraudulent activities to prevent against recurrences
To ensure legal compliance
- Comply with legal requirements
- Assist law enforcement
- Enforce or exercise our rights, for example, the ones laid out in our Terms
To process your information as described above, we rely on the following legal bases:
- Provide our service to you: Most of the time, the reason we process your information is to perform the contract that you have with us. For instance, as you go about using our service to build meaningful connections, we use your information to maintain your account and your profile, to make it viewable to other users and recommend other users to you.
- Legitimate interests: We may use your information where we have legitimate interests to do so. For instance, we analyze users’ behavior on our services to continuously improve our offerings, we suggest offers we think might interest you, and we process information for administrative, fraud detection and other legal purposes.
- How we share information
Since our goal is to offer you perfect services we also share some users’ information with service providers and partners who assist us in operating the services and in some cases, legal authorities. Read on for more details about how your information is shared with others.
- With our service providers and partners
We use third parties to help us operate and improve our services. These third parties assist us with various tasks, including data hosting and maintenance, analytics, customer care, marketing, advertising, payment processing and security operations.
We may also share information with partners who distribute and assist us in advertising our services. For instance, we may share limited information on you in hashed, non-human readable form to advertising partners.
We follow a strict vetting process prior to engaging any service provider or working with any partner. All of our service providers and partners must agree to strict confidentiality obligations.
- For corporate transactions
We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control.
- When required by law
We may disclose your information if reasonably necessary: (i) to comply with a legal process, such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements; (ii) to assist in the prevention or detection of crime (subject in each case to applicable law); or (iii) to protect the safety of any person.
- To enforce legal rights
We may also share information: (i) if disclosure would mitigate our liability in an actual or threatened lawsuit; (ii) as necessary to protect our legal rights and legal rights of our users, business partners or other interested parties; (iii) to enforce our agreements with you; and (iv) to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing.
- With your consent or at your request
We may ask for your consent to share your information with third parties. In any such case, we will make it clear why we want to share the information.
- Cross-border data transfers
Sharing of information laid out in Section 6 sometimes involves cross-border data transfers, for instance to the United States of America and other jurisdictions. As an example, where the service allows for users to be located in the European Economic Area (‘EEA’), their personal information is transferred to countries outside of the EEA. We use standard contract clauses approved by the European Commission or other suitable safeguards to permit data transfers from the EEA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of your data.
- Your rights
We want you to be in control of your information, so we have provided you with the following tools:
- Access / Update tools in the service.
Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our DPO at firstname.lastname@example.org
- Device permissions.
Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.
We want you to be aware of your privacy rights. Here are a few key points to remember:
- Reviewing your information.
Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by putting in such a request to email@example.com
- Updating your information.
If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us: firstname.lastname@example.org
For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.
Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore.
You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device.
In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.
- How we protect your information
We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.
We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage, and processing practices to update our physical, technical and organizational security measures.
We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security
- How long we retain your information
We keep your personal information only as long as we need it for legitimate business purposes (as laid out in Section 5) and as permitted by applicable law:
- we must keep it to comply with applicable law (for instance, some ‘traffic data’ is kept for one year to comply with statutory data retention obligations);
- there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security.
Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific time frame due to technical constraints.
- Children’s privacy
Our services are restricted to users who are 16 years of age or older. We do not knowingly collect personal information from anyone under the age of 16. If you suspect that a user is under the age of 16, please report it to email@example.com
Because we’re always looking for new and innovative ways to help you build meaningful connections, this policy may change over time. We will notify you before any material changes take effect so that you have time to review the changes.
- How to contact us
Write to us at firstname.lastname@example.org