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Novoda Privacy policy (OHS) 4123-2783-4132 2 4132-6260-6868 1.docx
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Novoda Privacy Policy

Intro

Novoda Limited[1] ("Novoda", "we", "our", or "us") operates the www.novoda.com website (the "Website") and provides app development and related consultancy services (the "Services"). 

At Novoda we are committed to protecting your privacy. In this privacy policy we have set out how we collect, store, process, transfer, share and use data that identifies or is associated with you (your "personal information") and information regarding our use of cookies and similar technologies.

This privacy policy covers the information we collect about you when you use our Services, access our Website or contact us.

Data Controller

Novoda is the data controller of the personal information we hold about you. If you have any questions about this privacy policy or require any further information you can write to us at privacy@novoda.com or Unit 8 The Ivories, 6-18 Northampton Street, London, N1 2HY.

Information we collect from you

Information that you provide us– we collect personal information about you when you voluntarily submit information to us. This can include information you give us when you engage us to provide Services, fill in forms on our Website or correspond with us by phone, email or otherwise, or when you subscribe to our blog, mailing lists, newsletters or other forms of marketing communication.

We will inform you if the provision of certain personal information is mandatory or voluntary. If you choose not to provide personal information marked as mandatory, we may not be able to provide some of the Services or features of our Website to you, or respond to your queries or comments.

Information we receive from other sources– We may receive personal data about you from public sources and various third parties including for example social media networks.

The table at Annex 1 sets out the categories of personal information we collect about you and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of that information.

Information collected automatically - we may also automatically collect personal information about you indirectly about how you access and use the Website and information about the device you use to access the Website.

The table at Annex 2 sets out the categories of personal information we collect about you automatically and how we use that information. The table also lists the legal basis which we rely on to process the personal information and the recipients of that information.

We may anonymise and aggregate any of the personal information we collect (so that it does not directly identify you). We may use anonymised information for purposes that include testing our IT systems, research, data analysis, improving the Website or our Services and developing new products and features. We may also share such anonymised information with others.

Where we hold your information

We take the security of your personal information very seriously and have policies and procedures in place to protect your personal information against accidental or unlawful destruction, loss, change or damage (a "data breach"). We take care to limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a data breach where we are legally required to do so.

Although we do our very best to protect your personal details, transmission of information via the internet is not completely secure and we cannot and do not guarantee the absolute security and protection of your personal information.

The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we or our third party service providers have operations. If you are located in the European Economic Area ("EEA"), this may mean that your personal information will be stored in a jurisdiction that offers a level of protection that may, in certain instances, be less protective of your personal information than the jurisdiction you are typically resident in. We will take reasonable steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy.

Disclosure of your information

In addition to the parties identified in Annex 1, we may share your personal information with the following:

Service providers. We may transfer your personal information to third party selected service providers that perform services for us or on our behalf, including IT and system management services, legal and financial advisors, billing and payment processing services, fraud detection and prevention services, web analytics, web hosting, email and chat services, marketing services, recruitment services and content providers (collectively, “Third Party Service(s)”).

We require all Third Party Services to respect the security of your personal information and to treat it in accordance with the law.

Law enforcement, regulators and other parties for legal reasons. We may disclose your personal information to third parties if we are under a duty to disclose or share your data in order to comply with any legal obligation, or if we reasonable believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property or personal safety of Novoda, its users, employees or others.

Purchasers and third parties in connection with a business transaction. We may also disclose your personal information to third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this Privacy Policy.

Affiliates. We may transfer your personal information to other affiliates of Novoda, so that they can provide you with news, updates, information and marketing messages about products or services that may interest you.

Social media networks. Content that you share through social media may be shared with your social media account provider and your friends, followers or contacts on the connected social network.

Your rights

You have the following rights in respect of the personal information we hold about you:

  1. Right of access. You have the right to obtain:
  1. confirmation of whether, and where, we are processing your personal information;
  2. information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;
  3. information about the categories of recipients with whom we may share your personal information; and
  4. a copy of the personal information we hold about you.

  1. Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

  1. Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

  1. Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

  1. Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

  1. Right to Object.. You have the right to object to any processing based on our legitimate interest where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information and we will assess and inform you if this is the case. You can object to marketing activities for any reason.

            If you wish to exercise any of these rights, please contact us via email at privacy@novoda.com.

You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Timeline for keeping your information

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.[2]

Cookies and similar technologies

Our Website uses cookies to distinguish you from other users of our Website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our Website.

Cookies are pieces of code that allow for personalisation of our Website experience by saving your information such as user ID and other preferences. A cookie is a small data file that we transfer to your device's hard disk (such as your computer or smartphone) for record-keeping purposes.

We use the following types of cookies:

  1. Strictly necessary cookies. These are cookies that are required for the essential operation of our Website such as to authenticate users and prevent fraudulent use.

  2. Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Website when they are using it. This helps us to improve the way our Website works, for example, by ensuring that users are finding what they are looking for easily. We may use third-party analytics tools such as Google Analytics, to help us measure traffic and usage trends for the Website and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners, and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.   

  3. Functionality cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). 

  4. Tracking cookies. These are used to recognise you when you return to our Website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region). 

Annex 3 contains further information about the cookies we use.

Please be aware that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

The cookies we use are designed to help you get the most from the Website but if you do not wish to receive cookies, most browsers allow you to change your cookie settings. Please note that if you choose to refuse cookies you may not be able to use the full functionality of our Website. These settings will typically be found in the "options" or "preferences" menu of your browser. In order to understand these settings, the following links may be helpful, otherwise you should use the "Help" option in your browser for more details.

  1. Cookie settings in Internet Explorer
  2. Cookie settings in Firefox
  3. Cookie settings in Chrome
  4. Cookie settings in Safari web and iOS.

Marketing and advertising

From time to time we may contact you with information about our products and services. Most of the marketing messages we send will be by email or through push notifications on your device.

We will only send you marketing messages if you have given us your consent to do so. We will ask you if you would like to receive these messages when we first collect your contact details.  

You can change you preferences at a later date by clicking on the unsubscribe link at the bottom of our marketing newsletters. You can also let us know at any time that you do not wish to receive marketing anymore by sending an email to us using the contact details at the end of this privacy policy.

Please note that if you do opt-out of or do not grant consent to receiving marketing related messages from us, we may still send you non-marketing messages, such as communications relating to the provision of our Services.

Links to third party sites

Our Website may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. Please check the individual policies before you submit any information to those websites.

Our policy towards children

Our Website and Services are not directed at persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.

Changes to this policy

We may update this privacy policy from time to time and so you should review this page periodically. When we change this privacy policy in a material way, we will update the "last modified" date at the end of this privacy policy. Changes to this privacy policy are effective when they are posted on this page.

Notice to you

If we need to provide you with information about something, whether for legal, marketing or other business related purposes, we will select what we believe is the best way to get in contact with you. We will usually do this through email or by placing a notice on the Website. The fact that we may send notices to you will not stop you from being able to opt out of certain types of contact as described in this privacy policy.

ANNEX 1 – PERSONAL INFORMATION WE COLLECT WHEN YOU USE OUR SERVICES OR ACCESS OUR WEBSITE[3]

Category of personal information

How we may use it

Legal basis for the processing

Parties we may share your information with

Contact information and basic personal details. Such as your name, phone number, e-mail address.

We may use this information to provide you or another person connected to you (such as your employer) with our Services in accordance with our agreement with you, or in accordance with our agreement with the customer.

Where our agreement to provide Services is with you, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where our agreement to provide Services is with someone else (such as your employer) the processing is necessary for our legitimate interests and those of our customer, namely administering the Services.

We may share this information with Google LLC when we upload documents or information to Google Drive, and with The Rocket Science Group LLC d/b/a MailChimp, our electronic marketing platform.

We may also upload this information to our client relationship management system.

We may use this information to communicate with you, including sending service-related communications.

Where our agreement to provide Services is with you, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where our agreement to provide Services is with someone else (such as your employer) the processing is necessary for our legitimate interests and those of our customer, namely administering the Services.

We may use this information to send you unsolicited marketing communications in accordance with your preferences.

We will only use your personal information in this way to the extent you have given us consent to do so.

We may use this information to deal with enquiries and complaints made by or about you relating to the Service.

The processing is necessary for our legitimate interests, namely administering the Services and our Website, and for communicating with you effectively to respond to your queries or complaints.

Employment information. Such as the name of the company you work for, and information about the business unit you work for, your job title and function.

We may use this information to tailor and provide you or the client with Services.

Where our agreement to provide Services is with you, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where our agreement to provide Services is with someone else (such as your employer) the processing is necessary for our legitimate interests and those of our customer, namely administering the Services.

We may share this information with Google LLC when we upload documents or information to Google Drive, and with The Rocket Science Group LLC d/b/a MailChimp, our electronic marketing platform.

We may also upload this information to our client relationship management system.

Correspondence, instructions and comments. When you contact us directly, e.g. by email, phone, mail, or when you complete an online form, we will record your comments and opinions.

We may use this information to provide the Services in accordance with our customers' instructions and to respond to your questions, issues and concerns.

Where our agreement to provide Services is with you, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where our agreement to provide Services is with someone else (such as your employer) the processing is necessary for our legitimate interests and those of our customer, namely administering the Services.

We may share this information with Google LLC when we upload documents or information to Google Drive. We may also upload this information to our client relationship management system.

We may use this information to tailor the Services to your or our customer's requirements, deal with complaints made by or about you relating to the Services and monitor and improve our Services.

The processing is necessary for our legitimate interests, namely communicating with customers, tailoring our service to customers and to improve our Services generally; the processing is also necessary for your legitimate interests and those of our customers, namely receiving the Services.

We may use this information to determine products, services, news and other information that we believe may be of interest to you.

 

The processing is necessary for our legitimate interests, namely informing our direct marketing.

We may use this information to promote our Services, such as using your feedback in promotional publications or communications.

We will only process your personal data in this way to the extent that you have given us your consent.

Payment and transaction information. Payment information, such as your credit card or bank details, and other information such as the date and time of your transaction.

We may use this information to facilitate transactions made in connection with the provision of the Services.

Where our agreement to provide Services is with you, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where our agreement to provide Services is with someone else (such as your employer) the processing is necessary for our legitimate interests and those of our customer, namely administering the Services.

We may use this information to detect and prevent fraud.

The processing is necessary for our legitimate interests, namely the detection and prevention of fraud.

Information about the project. Information regarding the project or services that we have been engaged to provide may contain personal information about you.

We may use this information to provide the Services in accordance with our customer's instructions and to tailor the Services to your or our customer's requirements.

Where our agreement to provide Services is with you, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where our agreement to provide Services is with someone else (such as your employer) the processing is necessary for our legitimate interests and those of our customer, namely administering the Services.

We may share this information with Google LLC when we upload documents or information to Google Drive. We may also upload this information to our client relationship management system.

We may use this information to determine products, services, news and other information that we believe may be of interest to you.

 

The processing is necessary for our legitimate interests, namely informing our direct marketing.

We may use this information to promote our Services, such as providing a description of the project in promotional publications or communications.

We will only process your personal data in this way to the extent that you have given us your consent.

Information provided by third parties. From time to time, we may receive information about you from customers or third parties. We may obtain information from third parties to enhance or supplement our existing information about you. We may also collect information about you that is publicly available.

We may combine this information with the information we collect from you directly. We use this information to:

  • contact you; and

  • provide the Services in accordance with our customer's instructions.

Where our agreement to provide Services is with you, the processing is necessary for the performance of a contract between you and us, and/or to take steps at your request prior to entering into a contract.

Where our agreement to provide Services is with someone else (such as your employer) the processing is necessary for our legitimate interests and those of our customer, namely administering the Services.

We may share this information with Google LLC when we upload documents or information to Google Drive, and with The Rocket Science Group LLC d/b/a MailChimp, our electronic marketing platform.

We may also upload this information to our client relationship management system.

Your preferences that you set for notifications, marketing communications, how our Services are provided and how our Website is displayed.

We may use this information to provide notifications, send news, alerts and marketing communications and provide our Services in accordance with your choices.

The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications.

We may share this information with Google LLC when we upload documents or information to Google Drive, and with The Rocket Science Group LLC d/b/a MailChimp, our electronic marketing platform.

We may also upload this information to our client relationship management system.

We may use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.

The processing is necessary for compliance with a legal obligation to which we are subject.

All personal information set out above.

We may use all the personal information we collect to operate, maintain and provide to you our Services, to communicate with you, to monitor and improve our Services, our Website and business, and to help us develop new products and services.

The processing is necessary for our legitimate interests, namely to administer and improve the Services and/or our business and to develop new services.


ANNEX 2 – PERSONAL INFORMATION WE COLLECT AUTOMATICALLY[4]

Category of personal information

How we may use it

Legal basis for the processing

Parties we may share your information with

Information about how you access and use the Website. For example, the website from which you came and the website to which you are going when you leave our Website, how frequently you access the Website, the time you access our Website and how long you use it for, the approximate location that you access the Website from, whether you access the Website from multiple devices, and other actions you take on the Website.

We may use information about how you use and connect to our Website to present our Website to you on your device.

The processing is necessary for our legitimate interests, namely to tailor our Website to the user.

We may share this information with Google Ireland Limited, our analytics services provider, for the purpose of analysing information related to Website use.

We use this information to monitor and improve our Website, resolve issues and to inform the development of new functionalities and services available through our Website.

The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Website and to improve our Website generally.

Log files and information about your device. We also collect information about the computer, tablet, smartphone or other electronic device you use to connect to our Website. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to our Website through the device, your Internet service provider or mobile network, your IP address, and your device’s telephone number (if it has one).

We may use information about how you use and connect to our Website to present our Website to you on your device.

The processing is necessary for our legitimate interests, namely to tailor our Website to the user.

We may share this information with Google Ireland Limited, our analytics services provider, for the purpose of analysing information related to Website use.

We use this information to monitor and improve our Website, resolve issues and to inform the development of new functionalities and services available through our Website.

The processing is necessary for our legitimate interests, namely to monitor and resolve issues with our Website and to improve our Website generally.

ANNEX 3 – COOKIES[5]

Cookie Name

Name of party setting Cookie

When will the cookie expire?

When is the cookie set?

How the information collected by the cookies is used

google analytics1

“_ga”

Novoda

2 years after initial visit to our website  

When you first visit our website

We use Google Analytics to:

  • monitor and analyse how users use our website and our Service, in order to better understand how users interact with our website and our Service;
  • recognise you and link the devices you use when you visit our website or use our Service;
  • tailor our advertisements and content to you.

For more information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's "How Google uses data when you use our partners' sites or apps" located at www.google.com/policies/privacy/partners.

You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here https://tools.google.com/dlpage/gaoptout/.  

google analytics2

“_gid”

Novoda

2 years after initial visit to our website

When you first visit our website

Service Workers

Novoda

2 years after initial visit to our website

When you first visit our website

__cfduid

When you first visit our website]

We use this cookie to identify individual clients behind a shared IP address and apply security settings on a per-client basis.

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