Your privacy is important to us, which is why we have created this Privacy Statement to explain how we collect, use and share your personal information. This Privacy Statement applies to the websites operated by Novonto Agency. (“Novonto”), including, but not limited to, the website currently located at novonto.com (collectively, the “Website”). By using the Website, you consent to the collection and use of your personal information as set forth in this Privacy Policy. We respect the EU’s General Data Protection Regulation (GDPR), and this policy explains how we collect and treat information you give us. Please read this Privacy Policy carefully, and if you have any questions, feel free to contact us.

1. Q&A.

If you wish to ask questions or provide comments on this Privacy Policy, you may do so by sending us an e-mail at security@novonto. We will not disclose personal information to third parties for their direct marketing purposes without your consent. ls you wish, after giving your consent, to prevent the disclosure of your personal information to third parties for their direct marketing purposes, please let us know by sending an e-mail to security@novonto. Remember to include your full name, e-mail address and mailing address, and specifically indicate that you do not want your personal information to be shared with third parties for their direct marketing purposes. Be sure to state this clearly!

2. INFORMATION YOU CHOOSE TO SEND.

We may collect and store personal information that you voluntarily provide to us when you contact us. We collect your name, home or business address, email address and other personal information that you choose to provide (collectively, “Personal Information”). The decision to provide this information is optional. We use the information you provide to send you the communications you request. We may also use the information to communicate with you about other topics that we think may be of interest to you. If you communicate with us through the “Contact Us” link on our Web site, we may ask you for information such as your name, e-mail address and telephone number so that we can respond to your questions and comments. We may also use the information you provide so that we can communicate with you about topics we think may be of interest to you.

3. INFORMATION WE COLLECT AUTOMATICALLY.

We automatically collect certain non-personal information to help us understand how our users use the Service (which we will collectively refer to in this Privacy Policy as “Usage Data”). For example, each time you use the Website, we may automatically collect the type of web browser you use, your operating system, your Internet service provider, your IP address, the pages you view, and the time and duration of your visits to the Website. This anonymous usage data may be linked to your username and account, but we do not share the linked information with third parties. We use this information to help us understand how people use the Web site and to improve the services we offer.

Cookies and Web Beacons. We use cookies (a small text file placed on your computer to identify your computer and browser). We may also use web beacons (an electronic file placed on a website to track usage). We do not use cookies or web beacons to collect personal information. Most web browsers are initially set to accept cookies. You can reset your web browser to refuse all cookies or to indicate when a cookie is sent. Some of our service providers may use their own cookies and web beacons in connection with the services they perform on our behalf.

Do Not Track. The Web site does not respond to signals from Web browsers with the “do not track” setting or other mechanisms that allow consumers to choose whether personal information about an individual consumer’s online activities is collected over time. Visit DoNotTrackUs for more information about “do not track.”

We may work with third-party advertising companies that may use information about your use of the Site to inform us about how it is used and to display advertisements about goods and services that may be of interest to you, including our own services, on third-party websites. From the Site, these companies may place or recognize a unique cookie on your computer, or use other technologies such as web beacons or pixel tags. Our Privacy Policy does not cover any use of information that may be collected from you by a third-party advertising company. For more information about advertising cookies and companies that offer users the ability to opt out of having information collected through such cookies, click here: Unsubscribe.

4. GOOGLE ANALYTICS.

We may also use third-party web analytics solutions, such as Google Analytics. Google Analytics is a web analytics service provided by Alphabet, Inc. that uses cookies to help analyze how users use this website. The information generated by the cookie about your use of this site (such as your IP address, the URL visited, the date and time the page was viewed) is transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of monitoring your use of this site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may transfer this information to third parties where required to do so by law, or where such third parties process information on Google’s behalf. For more information on Google’s privacy policy with respect to Google Analytics, please refer to the Google Analytics Privacy Policy. You may choose to opt out of Google Analytics by visiting Google Analytics Opt Out.

5. HOW WE HANDLE INFORMATION.

We may use your personal information to further develop our relationship with you and for other purposes, including: (a) send you newsletters and/or industry updates; (b) process, evaluate and respond to your requests and inquiries; (c) verify your identity to ensure security for the other purposes listed here; (d) operate, evaluate and improve our business (including developing new services, managing our communications, understanding our visitors, analyzing our services, website and application, and facilitating the functionality of our website or application); (f) perform data analysis (including anonymizing personal information); (e) enforce our Terms of Use; and (g) comply with applicable legal requirements and industry standards and our policies. In addition, if you have elected to receive other communications from us, we will use your personal information for that purpose. We may use personal information for other additional purposes. We will identify these additional purposes at the time of collection.

6. HOW WE SHARE YOUR INFORMATION.

Except as set forth in this Privacy Policy, and except for collected demographic information that we may share with third parties in a way that does not link such information to any individual, we will not share your Personal Information with third parties unless you have given us permission to do so.

We may sometimes use other companies (“Service Providers”) to perform certain services for us, such as, for example, payment processing, debt collection and legal proceedings, hosting and maintenance, data storage and management services, production and fulfillment, and marketing and promotions. We provide our Service Providers with the information reasonably necessary for them to perform the services on our behalf. Each Service Provider must agree to implement and maintain reasonable security procedures and practices appropriate to the nature of the information involved to protect your information from unauthorized access, destruction, use, alteration or disclosure.

We may disclose aggregate Usage Data to third parties. However, this aggregate data will not reveal any personal information and will not personally identify you or other users of the Site.

7. OTHER AUTHORIZED DISCLOSURES.

Notwithstanding anything in this Privacy Statement, you understand and agree that Novonto may access, retain, and disclose information that we have collected about you or that you have submitted: (a) in response to subpoenas, court orders, or legal process, or to establish, protect or exercise our legal rights, or defend against legal claims; (b) to protect the rights and property of Novonto or the public; (c) if we believe it is necessary to investigate, prevent illegal activity, or take action regarding fraud, violations of the personal or intellectual property rights of others, or situations that pose potential threats to the safety of any person (d) to our business subsidiaries, joint ventures or other companies under common control with Novonto (in which case we will require such entities to comply with this Privacy Policy); and (e) if Novonto is acquired by or merged with another entity or in connection with the sale of our assets.

The Website may contain links to websites operated by third parties over which we have no control. Privacy policies on such linked websites may differ from our Privacy Policy. You access such linked websites at your own risk. We encourage you to review the privacy policy of any such linked website you visit to understand that website’s collection, storage and use of your information.

9. SECURITY.

The security of your personal information is important to us. We maintain standard security procedures and practices appropriate to the nature of the information to protect information from unauthorized access, destruction, use, alteration or disclosure. We also require our service providers to implement and maintain reasonable security procedures and practices appropriate to the nature of the information we share with them. No data transmission over the Internet or a wireless network can be guaranteed to be secure for 100%. As a result, while we make every effort to protect personal information, we cannot guarantee or warrant the security of any information you transmit to or receive from the Site. You do so at your own risk. You can read more in our Security Statement.

10. CHILDREN’S PRIVACY STATEMENT.

We knowingly do not collect personally identifiable information from children under the age of 13. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen (13), we will delete such information from our records. Because we knowingly do not collect personally identifiable information from children under the age of thirteen (13), we also knowingly do not disseminate such information to third parties.

11. DATA PROCESSING.

Please note that your personal information and communications may be transferred and stored on servers or databases in Europe. If you are located outside the EU, please note that we process and store all information in the Netherlands. The laws outside the Netherlands may not be as protective of your privacy as those in your place of residence. By using our Site, you agree that the collection, use, transfer and disclosure of your personal data and communications are subject to applicable laws in the Netherlands.

12. CHANGES.

Novonto may, in its sole discretion, change this Privacy Policy from time to time. Any changes to the Privacy Policy will become effective at the time they are posted. We encourage you to return periodically to review the latest version. If you wish to continue using the Site following changes to the Privacy Policy, you must agree to any such changes. If you object to such changes, your sole remedy is to discontinue using our Site.

Last modified: January 1, 2024.

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