Nova Legal Policies

Last updated: 22 April 2021

Nova Orbis Inc. (“Nova,” “we,” “our,” or “us”) values the privacy of individuals who use the Nova website and related services (collectively, the “Service”). This Privacy Policy (the “Policy”) describes the information that we gather from visitors, users, and others who access or use the Service (“you” or “your”), how we use and disclose such information, and the steps we take to protect such information. By using the Service, you consent to the privacy practices described in this Policy.This Policy is incorporated into and is subject to the Nova Terms of Service. Capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Service.

1. Information We Collect

Personal Information

While using the Service, we will ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Information”). Personal Information may include, but is not limited to, your name, address, email address, location, payment information, governmental identification information, and other contact and demographic information. We will also ask for information about your company and financial information related to assets and liabilities. You may provide us with Personal Information when you register for an account, use the Service, contact customer support, sign up for marketing material, or otherwise communicate with us. Please note that if you choose not to share certain Personal Information with us, or refuse certain contact permissions, we might not be able to provide certain parts of the Service. Additionally, other customers may give us your Personal Information, such as when a customer initiates a transaction with you and/or wants you to sign an electronic document via the Service. In such case, if you wish to exercise any of your rights with respect to your Personal Information, please contact the applicable third party directly.

Usage Information

We collect information about how you interact with the Service, such as device type, IP address, operating system, browser type, address of a referring website, activity on our website, device ID, access dates and times, location, information related to your transactions on the Service, and other system activity. We may collect certain information by automated means using technologies such as cookies, web beacons, pixels, browser analysis tools, server logs, and mobile identifiers. In many cases the information we collect using cookies and other tools is only used in a non-identifiable manner without reference to Personal Information. For example, we may use information we collect to better understand website traffic patterns and to optimize your experience. In some cases we associate the information we collect using cookies and other technology with Personal Information. We track users’ use of the Service, but we do not track users across third party websites. We do not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who visit or use the Service.

Information Received from Third Parties

If you choose to connect your account to your account with a third-party service, we may receive or be granted access to information from such third-party service, including Personal Information. You can stop sharing your information from a third-party service with us by removing our access to that service.

Third-Party Cookies

When you use and visit the Service, we may also use third-party services, such as Google Analytics, FullStory, and others, which use cookies to collect information about you. Third parties may also use cookies, web beacons, or other devices to collect information when you use the Service. Nova does not control any cookies or other data collection tools that may be placed on the Service by a third party, and this Policy does not cover the use of such cookies and/or other data collection tools by any third party. We encourage you to read the privacy policies of such third parties to find out more about the information that may be collected by them and the choices you have regarding the collection, use, and sharing of such information. You may be able to “opt out” of the collection of information through cookies or other tracking technology by actively managing the settings on your browser or mobile device.

2. How We Use Your Information

Provide, Maintain, and Improve the Service

We may use your information to:

• communicate with you if you contact us directly or sign up for marketing material
• perform our obligations under the contract we have entered into with you
• provide customer service and process any transactions
• send you confirmations, updates, security alerts, and support and administrative messages
• detect and prevent fraud
• operate, protect, and optimize the Service and your experience, such as by performing analytics and conducting research
• troubleshoot and protect against errors
• personalize and improve the Service, including to recognize and contact you across multiple devices
• monitor and analyze usage and trends and otherwise measure the effectiveness of the Service
• develop new features

Sharing Your Information

If you use the Service, you are authorizing us to share information:

• that you direct us to disclose to others
• with our other customers pursuant to certain transactions between you or your company and such third party
• with our third-party business partners, vendors, and consultants who perform services on our behalf or who help us provide the Service, such as accounting, managerial, technical, marketing, or analytic services
• if required to do so by law or in the good-faith belief that such action is necessary to comply with local, state, federal, or international laws, or to respond to a court order, judicial or other governmental subpoena or warrant, or in the event of bankruptcy proceedings
• if we believe in good faith that doing so is reasonably necessary or appropriate to protect the rights, property, or safety of Nova, our users, our employees, copyright owners, third parties, or the public, including without limitation to protect Nova or our users from fraudulent, abusive, inappropriate, or unlawful use of the Service
• to enforce or apply this Policy, our Terms of Service, or our other policies or agreements
• in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition, or in any other situation where information may be disclosed or transferred as one of the business assets of Nova

Nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent. This Policy in no way restricts or limits our collection and use of aggregate or de-identified information.

Links to Third-Party Sites and Services

The Service may contain links to other websites. We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content provided to or contained therein. Please remember that when you use a link to go from the Service to another website, this Policy does not apply to those third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on the Service, are subject to that third party’s own rules and policies. Please read those rules and policies before proceeding.

3. How We Protect Your Information

We take measures designed to protect Personal Information in an effort to prevent loss, misuse, unauthorized access, disclosure, alteration, and destruction, such as the use of firewalls, password protection, secure socket layer, encryption, and other security measures. We will only keep your Personal Information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To comply with applicable laws and regulations that govern our provision of the Service, we may retain certain Personal Information for seven (7) years after receipt. We may also retain and use your Personal Information for as long as necessary to resolve disputes and/or enforce our rights. Where we rely on your consent to process your Personal Information, you have the right to decline consent and/or if provided, to withdraw consent at any time. This will not affect the lawfulness of processing prior to the withdrawal of your consent. Additionally, in some circumstances you can ask us to delete your Personal Information.

We limit access to Personal Information to our employees, agents, contractors, and other third parties who have a business need to know. They will only process Personal Information on our instructions and they are subject to a duty of confidentiality. We have implemented procedures to handle any suspected Personal Information breach and will notify you and any applicable regulator of a breach as legally required.

Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable and no method of data transmission can be guaranteed against any interception or other type of misuse. To protect the confidentiality of information maintained in your account, you must keep your password confidential and not disclose it to any other person. You are responsible for all uses of the Service by any person using your password. Please advise us immediately if you believe your password has been misused.

4. International Transfers

European Users

If you choose to use the Service from the EEA, the UK, Switzerland, or other regions of the world with laws governing data collection and use that may differ from U.S. law, please note that you are transferring your Personal Information outside of those regions to the U.S. for storage and processing. By providing any information, including Personal Information, on or to the Service, you consent to such transfer, storage, and processing.

As described in this Policy, we may share Personal Information with third parties and may be required to disclose information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

The legal grounds for our processing your Personal Information for the purposes in this Policy are as follows:

• you provided your consent by agreeing to this Policy, which you may withdraw at any time by emailing us at the email address below
• it is necessary for our contractual relationship
• the processing is necessary for us to comply with our legal or regulatory obligations
• the processing is in our legitimate interest as a provider of the Service (for example, to protect the security and integrity of our systems and to provide you with customer service and the core functionality of the Service)

Privacy Shield

On July 16, 2020, the European Court of Justice issued a judgment declaring invalid the adequacy of the EU-U.S. Privacy Shield Framework (the “Framework”). In accordance with the U.S. Department of Commerce’s guidance and recommendation, we do and will continue to participate in the Framework and will comply with our ongoing obligations with respect to transfers made under the Framework. Additionally, we continue to follow robust privacy principles and to review this Policy to ensure it describe our privacy practices accurately, including with regard to international data transfers.

Other International Transfers

If you are located outside the U.S., the EEA, the UK, and Switzerland, and you choose to provide Personal Information to us, we may transfer your Personal Information to the U.S. and process it there (or any other country where we operate or may have co-locations). When you provide Personal Information, it may be sent to servers located in the U.S. and other countries around the world.

5. California Privacy Rights

California law permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those third parties. See the “Contact” section for where to send such requests. We do not share your Personal Information with third parties for their own direct marketing purposes without your prior consent. Accordingly, you can prevent disclosure of your Personal Information to third parties for their direct marketing purposes by withholding consent.

Effective January 1, 2020, the California Consumer Privacy Act of 2018 (the “CCPA”) allows California residents, upon a verifiable consumer request, to request that a business that collects consumers’ personal information (as defined in the CCPA) to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. See the “Contact” section for where to send such requests. Consistent with California law, if you choose to exercise your rights, we will not charge you different prices or provide different quality of services unless those differences are related to your information. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

We do not sell personal information to third parties. We do allow third parties to collect and share personal information through the Service and share personal information with third parties for the business purposes described in this Policy.

6. Children’s Privacy

The Service is not directed to children under 16 and we do not knowingly collect Personal Information from children under 16. If we learn that we have collected Personal Information of a child under 16, we will take steps to delete such information from our files as soon as possible.

7. Accessing and Modifying Your Information

If you have an account on the Service, you can access and modify your Personal Information associated with your account in your profile settings or by emailing us at the email address below. We will take steps to delete your Personal Information as soon as is practicable, but we may not be able to modify or delete your Personal Information in all circumstances, and some information may remain in archived/backup copies for our records and as otherwise required by law. You may “opt out” of receiving marketing or promotional emails from us by following the instructions in those emails or by emailing us at the email address below. If you opt out, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations (i.e. account verification, transactional communications, changes/updates to features of the Service, and technical and security notices).

8. Changes and Updates to the Policy

We reserve the right to change the provisions of this Policy at any time. Please revisit this page periodically to stay aware of any changes. If we modify this Policy, we will make it available through the Service and indicate the date of the latest revision. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood, and agreed to the current version of this Policy.

9. Contact

Please contact us with any questions regarding this Policy at ops@novahq.com