This privacy statement is effective as of January 1, 2021. Please note that this privacy statement will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
If you are a California resident, please see our specific privacy statement for California residents below. If you are a California resident, you have specific privacy rights under the California Consumer Privacy Act ("CCPA"). You can opt-out here from any selling of your personal information.
In case you have special accessibility needs to access the content of this statement, we recommend that you or someone on your behalf send us an email to Privacy@Novasind.com for support.
This page and its subpages tell you everything you need to know about how NOVASIND and/or its affiliates, subsidiaries and partners protect the personal data we process and control relating to you ("your personal data"; "your data") and which rights you have in relation to the processing of your personal data.
Any NOVASIND entity located outside the European Union will, for the purposes of compliance with data privacy laws, be represented by NOVASIND LLC.
Below, we first give a general description of how NOVASIND protects your personal data. Further below, we also include specific information on the following:
NOVASIND attaches great importance to your right to privacy and the protection of your personal data. We want you to feel secure when you deal with NOVASIN. Your personal data are in good hands.
NOVASIND protects your personal data in accordance with applicable laws and our data privacy policies. In addition, NOVASIND maintains the appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing and/or against accidental loss, alteration, disclosure, or access, or accidental or unlawful destruction of or damage thereto.
The following sections provide further details as to how NOVASIND processes your personal data:
Which categories of personal data do we collect and how do we process such personal data?
We collect personal data of our employees, potential employees, clients (including employee data shared by our client organization as per their policy), suppliers, business contacts, shareholders, and application/website users. If the data we collect are not listed in this privacy statement, we will give our clients (when required by law) appropriate notice of which other data will be collected and how they will be used.
Below is also a chart describing the categories of personal data we may collect. We may collect this information because of your direct participation and information sharing with us or through the authorized representative of the client organization that you work for. The client organization may also choose to assign a third-party or representative to share your information with us as a part of the consulting process. Any questions related to the employee information sharing policy of your organization must be addressed directly to the concerned department in your organization.
|Category of personal information||Types of personal information captured by category|
|Personal details, contact details, and identifiers||Name, pronoun, all types of identifiers and contact details (such as e-mail, phone numbers, physical address) and occasionally, when necessary for specific purposes, gender, date of birth, age, place of birth.|
|Commercial information||History and records of the products and services you have obtained from NOVASIND.|
|Marketing and research information||
|Sensitive data and biometric information||NOVASIND may also collect certain types of sensitive information when permitted by local law or with your consent, such as health/medical information (including disability status and dietary requirements/allergies in the framework of the events we organize/sponsor) or biometric information, for example as when you elect to use fingerprint authentication on NOVASIND application.|
|Audiovisual materials||Photograph, and images/footage captured/recorded on CCTV or other audio, video and related security/monitoring systems or captured during marketing/public filming events/sessions (including recording of virtual or live workshops or similar events/sessions).|
|Position and professional or employment-related information||Professional or employment-related information, such as description of current position, job title, employer, location, and NOVASIND contact(s).|
|System and application access data and Internet and electronic network activity information||Where you are provided with access to NOVASIND’s systems, NOVASIND may collect information required to access such NOVASIND systems and applications such as System ID, LAN ID, e-mail account, instant messaging account, mainframe ID, system passwords, and internet or other electronic network activity information, including access logs, activity logs, and electronic content produced using NOVASIND systems.|
In addition, NOVASIND may process the personal information set out in the above table as a part of a contractual agreement with an organization that you are a part of.
We also may derive inferences about you based on the information described above and collect other information about you as described in this privacy statement. If you provide us with personal information of another person (for instance, a co-worker or your boss), you are responsible for ensuring that such person is made aware of the information contained in this privacy statement and that the person has given you his/her consent for sharing the information with NOVASIND.
The above-mentioned categories of personal data may have been obtained either directly from you (for example, when you provide information during one of our interactive sessions or register to comment on a forum website) or indirectly from certain third parties (for example, through your organization or its affiliated networks). Please note that if you do not provide certain information, we may not be able to accomplish some or all the purposes outlined in this privacy statement, and you may not be able to use certain tools and systems which require the use of such personal data.
NOVASIND uses your personal data only where required for specific purposes. Please view the table below for: (i) a list of the purposes for which NOVASIND uses your personal data and (ii) an overview of the legal basis for each such purpose.
|Managing our contractual relationship with the organization that you work for and you are a party to that contract||Necessary for the performance of a contract to which you are a party.|
|Consulting||Justified based on our legitimate interests for ensuring that we are proving the best consulting experience as per your needs or the needs of the organization that you work for.|
|Facilitating communication with you (including in case of emergencies, and providing you with requested information)||Justified based on our legitimate interests for ensuring proper communication and emergency handling within the organization if it arises.|
|Operating and managing our business operations||Justified based on our legitimate interests for ensuring the proper functioning of our business operations.|
|Complying with legal requirements||Necessary for the compliance with a legal obligation to which we are subject.|
|Monitoring your use of our systems (including monitoring the use of our website and any apps and tools you use)||Justified based on our legitimate interests of avoiding non-compliance and protecting our reputation.|
|Social listening (identifying and assessing what is being said about NOVASIND and our clients on social media (only publicly accessible content) to understand sentiment, intent, mood and market trends and our stakeholders’ needs and thereby improving our services. We do this through key-word searches and our goal is to gain insights in conversation trends over a specified period and not to identify an individual. To achieve this, we analyze and monitor conversation streams and monitor publicly available opinions, statements, or other interactions on social media channels)||Justified based on our legitimate interest of protecting our assets and our brand on social media.|
|Justified based on our legitimate interest of protecting our assets and our brand on social media.||Justified based on our legitimate interest of protecting our assets and our brand on social media.|
|Undertaking data analytics, i.e., applying analytics to business operations and data to describe, predict, and improve business performance within NOVASIND, and/or to provide a better user experience (more details on how we run analytics on our website can be found in our Cookies Policy)||Justified based on our legitimate interests for ensuring the proper functioning of our business operations.|
|Marketing our products and services to you (unless you objected against such processing, as further described in the section “How do we use personal data for marketing purposes?” below)||Justified based on our legitimate interests for ensuring that we can conduct and increase our business.|
|Facilitate communication with you||Justified based on NOVASIND’s legitimate interests of ensuring proper communication within the organization and with you.|
|Perform data analytics, including analysis of our client's employee pool to better understand the client’s organization structure.||Perform data analytics, including analysis of our client's employee pool to better understand the client’s organization structure.|
|Administration of employee forums as mandated by the contractual obligation with the client’s organization||Justified based on NOVASIND’s legitimate interests of ensuring that the employee forums are effectively managed by authorized representatives.|
|Perform any legally required reporting and respond to legal process||Compliance with a legal obligation.|
Legitimate interest means that NOVASIND has reasonable grounds to process your personal information. We will process your personal information for the purposes mentioned above based on your prior consent if you are an independent client or as per the contractual agreement with the organization that you are a part of.
Where the above table states that we rely on our legitimate interests for a given purpose, we are of the opinion that our legitimate interests are not overridden by your interests, rights, or freedoms. If you are part of an organization that we serve and have questions about privacy issues, we recommend you consult with the authorized representative of your organization for more information.
By accessing our services or products such as applications and websites, you are automatically providing your consent to process your personal information. Likewise, if you are a party to the contractual agreement that we have in place with the organization you work for, you are automatically providing your consent as well. Please consult with the authorized representative of your organization for more information or if you have any questions.
We will not use your personal information for purposes that are incompatible with the purposes of which you have been informed, unless it is required or authorized by law, or it is in your own vital interest (e.g., in case of a medical emergency) to do so.
We may transfer personal data to our service providers and professional advisors, public, and governmental authorities, NOVASIND companies/affiliates or third parties in connection with NOVASIND’s operation of its business, including any (potential) corporate or commercial transaction. Before we do so, we shall take the necessary steps to ensure that your personal data will be given adequate protection as required by relevant data privacy laws and NOVASIND’s internal policies. NOVASIND may also transfer your personal data to any of its global affiliates/partners/vendors in furtherance of any visits to our NOVASIND applications/websites or physical locations.
For example, we may disclose personal information to third parties for other business purposes as follows:
We may also share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, initial public offering, or in the unlikely event of a bankruptcy.
Unless you are otherwise notified, any transfers of your personal data from within the European Economic Area (EEA) to third parties outside the EEA will be based on an adequacy decision or are governed by the standard contractual clauses (a copy of which can be obtained through the contact information included below). Any other non-EEA related transfers of your personal data will take place in accordance with the appropriate international data transfer mechanisms and standards.
We do not generally seek to collect sensitive data as defined in the second paragraph below (also known as special categories within the EEA) through applications, websites or otherwise. In the limited cases, where we do seek to collect such data, we will do this in accordance with data privacy law requirements and/or ask for your consent.
The term "sensitive data" refers to the various categories of personal data identified by data privacy laws as requiring special treatment, including in some circumstances the need to obtain explicit consent from you. These categories include racial or ethnic origin, political opinions, religious, philosophical, or other similar beliefs, membership of a trade union, physical or mental health, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including information about suspected criminal activities).
We maintain organizational, physical, and technical security arrangements for all the personal data we hold. We have protocols, controls and relevant policies, procedures, and guidance to maintain these arrangements considering the risks associated with the categories of personal data and the processing we undertake.
We adopt market leading security measures to protect your personal data.
As a global organization with operations throughout the world, personal data we collect may be transferred or be accessible internationally throughout NOVASIND's global business and between its entities and affiliates.
We will retain your personal data only for as long as is necessary. We maintain specific records’ management and retention policies and procedures, so that personal data are deleted after a reasonable time, according to the following retention criteria:
You are entitled (in the circumstances and under the conditions, and subject to the exceptions, set out in applicable law) to:
To the extent that the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time by emailing us at Privacy@Novasind.com.
Please note that this will not affect NOVASIND’s right to process personal data obtained prior to the withdrawal of your consent, or its right to continue parts of the processing based on other legal bases than your consent.
If, despite our commitment and efforts to protect your personal data, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to NOVASIND first to seek resolution of any complaint. You have the right at all times to register a complaint directly with the relevant supervisory authority or to make a claim against NOVASIND with a competent court (either in the country where you live, the country where you work or the country where you deem that data privacy law has been infringed).
Contact us at Privacy@Novasind.com to exercise your rights.
In addition to the information set out above, the following sections describe how we use personal data when you visit NOVASIND’s website:
NOVASIND collects personal data at its websites in two ways: (1) directly (for example, when you provide personal data to sign up for a newsletter or register to comment on a forum website); and (2) indirectly (for example, through our website's technology).
We may collect and process the following personal data:
Our websites may include:
We use personal data for the purposes described in the section above “For which purposes and on which legal basis do we use your personal data?” as well as to provide you with information you request. For example:
We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and make it more effective. Please see the Cookies section below for more information.
We analyze your IP and browser information to determine what is most effective about our website, to help us identify ways to improve it and, eventually, to determine how we can tailor our website to make it a more positive and relevant user experience.
Please see our Cookies Policy for more details including for information about your choices with respect to advertising and social media cookies and for access to our cookie consent manager.
By using our website, you agree that we can place cookies and other similar technologies on your device as explained in our Cookies Policy.
In addition to the information set out above, the following sections describe how we use personal data for marketing purposes:
The bulk of the personal data we collect and use for marketing purposes relates to individual employees of our clients and other companies with which we have an existing business relationship. We may also obtain contact information from public sources, including content made public at social media websites, to make an initial contact with a relevant individual at a client or other company.
We send commercial e-mail to individuals at our client or other companies with whom we want to develop or maintain a business relationship in accordance with applicable marketing laws. Our targeted e-mail messages typically include web beacons, cookies, and similar technologies that allow us to know whether you open, read, or delete the message, and links you may click. When you click a link in a marketing e-mail you receive from NOVASIND, we will also use a cookie to log what pages you view and what content you download from our websites, even if you are not registered at or signed into our site.
Targeted e-mails from NOVASIND may include additional data privacy information, as required by applicable laws.
Like most companies, NOVASIND uses customer relationship management (CRM) database technology to manage and track our marketing efforts. Our CRM databases include personal data belonging to individuals at our client and other companies with whom we already have a business relationship or want to develop one. The personal data used for these purposes includes relevant business information, such as: contact data, publicly available information (e.g. board membership, published articles, press releases, your public posts on social media sites if relevant for business purpose), your responses to targeted e-mail (including web activity following links from our e-mails), website activity of registered users of our website, and other business information included by NOVASIND professionals based on their personal interactions with you. If you wish to be excluded from our CRM databases, please send us an email at Privacy@Novasind.com
In addition to the third parties mentioned in the section above “Will we share your personal data with third parties?” we may share your personal data with marketing agencies.
You can exercise your right to prevent marketing communications to you by checking certain boxes on the forms we use to collect your personal data, or by utilizing opt-out mechanisms in e-mails we send to you. You can also exercise the right to discontinue marketing communications to you, or to have your personal data removed from our customer relationship management (CRM) databases at any time by sending an email to Privacy@Novasind.com. In such cases, we will retain minimum personal data to note that you opted out in order to avoid contacting you again. Please allow at least 30 days to opt-out effectively.
We may use or disclose the personal information we collect for one or more of the following business purposes:
NOVASIND will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
NOVASIND may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
ACCESS TO SPECIFIC INFORMATION AND DATA PORTABILITY RIGHTS
You have the right to request that NOVASIND disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request via email at Privacy@Novasind.com, we will disclose to you:
You have the right to request that NOVASIND delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request via email at Privacy@Novasind.com , we will delete your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by contacting us at:
Only you, or a person registered with the California Secretary of State who you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice in a 12-month period.
You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice in a 12-month period.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
NOVASIND's Client Support Team is tasked with verifying a person's identity prior to taking any action on an individual's account with NOVASIND. Our Client Support Team will endeavor to use information that you have previously provided to verify your identity.
NOVASIND may request any of the following information to verify your identity:
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account.
If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
If you are 16 years of age or older, you have the right to direct us not to sell your personal information at any time (the "right to opt out"). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the "right to opt in") from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt into personal information sales may opt out of future sales at any time.
To exercise the right to opt out, you (or your authorized representative) may submit a request to us by sending us as email at Privacy@novasind.com
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, if you have previously opted out of the sale of your personal information under the CCPA and would like to opt back into the sale of your personal information, please send an email to Privacy@Novasind.com. For NOVASIND to process your opt-in request, we will need your first name, last name and the email address associated with your information. Once we receive this information, an email will be sent to the email address associated with the account, to confirm your request.
You do not need to create an account with us to exercise your opt-out rights. We will use only personal information provided in an opt-out request to review and comply with the request.Consumers who opt into personal information sales may opt out of future sales at any time.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Under the CCPA, individuals can appoint an authorized agent to exercise their rights to access or delete their data for them, or to request that NOVASIND stop selling their personal information. To do so, NOVASIND requires that you request a form at Privacy@Novasind.com. We will email you this form when you receive your request
If, despite our commitment and efforts to protect your personal information, you believe that your data privacy rights have been violated, we encourage and welcome individuals to come to NOVASIND first to seek resolution of any complaint. You always have the right to register a complaint directly with the relevant supervisory authority or to make a claim against NOVASIND with a competent court (either in the country/State where you live, the country where you work or the country where you deem that data privacy law has been infringed).
California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write or email to us at:
Please send an email to Privacy@Novasind.com if:
In case you have special accessibility needs to access the content of this statement, we recommend that you or someone on your behalf, email us at Privacy@Novasind.com to request a copy of this document.