Privacy Policy

This is an archived version of Novade Privacy Policy. View the current version or all past versions.

Version: 3rd September 2021

Novade respects the privacy rights of users and recognize the importance of protecting information collected about you.

Please read the following carefully to understand how we will collect, use, share and maintain your Personal Information (as defined below). This Privacy Policy also provides information on the use, access and correction of your Personal Information.

By continuing to use our Website and services, you acknowledge that you have read, understood and agree to the terms set out in this Privacy Policy.

1. Scope of the Privacy Policy

Definition. In this Privacy Policy, Novade Solutions Pte Ltd refers to “Novade”, “we”, “us” or “our”)

“Personal Data” or “Personal Information” means any information identifying an individual or information relating to an individual that we can identify (directly or indirectly) from that data alone or in combination with other identifiers we possess or can reasonably access. Personal Data excludes anonymous data or data that has had the identity of an individual permanently removed.

“Data controller” means the person or organization that determines the purposes and means of the processing of Personal Data. “Data Processor” means the person or organization processing personal data on behalf of the data controller.

Novade acts as both a Data Controller and a Data Processor, depending on the situation. When we process our visitor personal data, we act as a Data Controller. When we provide services to our Customers and process personal data, we act as a Data Processor since we handle personal data of users on behalf of our Customers.

“Data Protection Laws” means all applicable worldwide legislation relating to Personal Data protection which applies to the respective party in the role of processing Personal Data, as amended, consolidated or replaced from time to time.

Data controller. This Privacy Policy covers the processing of Personal Data for which Novade is the Data Controller, i.e. when you:

• act as a visitor of our websites or branded social media pages (the “Websites”),
• interact directly with us (as a “Contact”), particularly when:
  • You visit our offices,
  • You register to attend or take part in our events or webinars,
  • You interact with us through our websites or other media; and/or
• act as a Customer’s representative of Novade Services for administrative purposes;
• act as a supplier’s representative for administrative purposes.

Data processor. For the avoidance of doubt, this Privacy Policy does not apply to any processing of Personal Data that Novade may conduct as a Data Processor as a result of your use of Novade services. If you use the Novade services through an organization that has an agreement with Novade (the “Customer”), that organization shall act as the Data Controller regarding the data you provide when using Novade Services. The Customer is responsible for establishing policies and ensuring compliance with all applicable laws, as well as any privacy policies, agreements or other obligations, relating to the collection of Personal Data in connection with the use of our services by individuals.

2. Data collected

Information you provide to us. We collect Personal Information you provide directly to us when you access our Websites and complete a form, when you participate in a survey, activity or event, or communicate with us via third-party websites. We also collect Personal Information you provide directly to us when you register with us as the Customer’s representative of Novade Services for administrative purposes.

The types of information we may collect directly from you include your name, username, email address, your picture, postal address, phone number, information about your data storage preferences, employer’s name, job title, transactional information as well as any contact or other information you choose to provide.

Information we collect when you access our Websites. When you visit the Novade Websites, we may collect information about your usage of cookies and other similar tools, including:

• Usage Information: We can monitor user activity in connection with the Novade Websites and may collect information about the applications and features you use.
• Log Information: We can log information about you when you access the Novade Websites including your Internet Protocol (“IP”) address, access times, browser type and language.

You can choose to block the cookies that are not strictly necessary for the operation of our Websites as specified in the “Cookies policy” accessible at the following address: www.novade.net/cookie-policy/

3. Purpose of processing and legal basis

We will only use your Personal Data for the purposes for which we collected it as listed below, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

The information may be used for the following purposes:

• improve the Novade Websites;
• answer any request you may have submitted to us;
• communicate with you about services, features, surveys, newsletters, offers, promotions, contests and events, and provide other news or information about Novade;
• communicate with you on behalf of external business partners about a particular offering that may be of interest to you;
• create and publish testimonials;
• allow Novade to handle negotiations of, merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company;
• contact you as a Customer’s representative or supplier’s representative about administrative matters, including billing and account management.

In respect of each of the purposes for which we use your Personal Data, we will rely on one (or more) of the following legal bases:

• where we have your consent to do so. Generally, we do not rely on consent as a legal basis other than for sending you third party marketing communications via email;
• where it is necessary for our legitimate interests (or those of a third party such as our Customer) and your interests and fundamental rights do not override those interests. These legitimate interests include the processing necessary for Novade to (i) manage the contract with the Customers and fulfil its contractual obligations with the Customers, (ii) secure and improve its services, (iii) communicate with you;
• where we need to comply with a legal or regulatory obligation.

4. International transfers

Because we are a global organisation, we may transfer your personal data across national borders to other countries. Where applicable, we will ensure that any cross-border data transfers comply with the laws, regulations and standards prescribed by the relevant jurisdiction(s).

5. Sharing and disclosure of data

Third-party providers, Consultants and Other Providers. We may share your data with third-party providers, consultants and other providers who are working on our behalf and require access to your information to carry out that work, such as to host our Websites and other applications. These service providers are authorized to use your Personal Data only as necessary to provide services to Novade.

Compliance with Laws. We may disclose your information to a third party (a) if we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request, (b) to enforce our agreements, policies and Terms of Service, (c) to protect the security or integrity of the Novade services, (d) to protect Novade, our customers or the public from harm or illegal activities, (e) to respond to an emergency which we believe in the good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person or (f) to any other third party with your prior consent.

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Community Forums. The Websites may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas”). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your Personal Information from an Interactive Area, contact us at privacy@novade.net.

Promotional and Newsletter Communications. You may opt out of receiving promotional and newsletter emails from Novade by following the opt-out instructions provided in those emails or at the following address: privacy@novade.net.

6. Your rights

You have certain data protection rights in relation to the Personal Data we hold about you. Please note that these rights are subject to certain exemptions which may be applicable to any request you make.

• Your right of access. This right enables you to access to the Personal Data we hold about you and to get information regarding how we deal with your data.
• Your right to rectification. This right enables you to have any incomplete or inaccurate information we hold about you corrected.
• Your right to object. This right enables you to ask us to stop processing your Personal Data, (i) if we are relying on legitimate interests to process your Personal Data, unless we can demonstrate compelling legal grounds for the processing or (ii) if we are processing your Personal Data for direct marketing purposes.
• Your right to erasure. This right enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have exercised your right to object to processing.
• Your right to withdraw consent. This right enables you to withdraw your consent at any time if we are relying on consent to process your Personal Data.
• Your right to restrict processing. This right enables you to ask us to restrict the processing of your Personal Data in certain circumstances, such as where you contest the accuracy of the data or the reason for processing it.
• Your right to decide of the handling of your data after your death. This right enables you to decide of the handling of your Personal Data after your death, by giving instructions that Novade undertakes to respect.

These rights may be limited in some cases by local law. For example, even if you ask us to delete your Personal Data, we may need to retain it to complete transactions information, to comply with our legal obligations, or for other business purposes as required or permitted by law.

If you want to exercise any of the rights set out above, please contact us at privacy@novade.net. Please note that we may need to authenticate your identity before responding to your request.

If you are a user of Novade Services, we typically process personal data on behalf of our customers. In that case we may refer the request to the relevant customer and cooperate with their handling of the request, subject to any special contractual arrangement with that customer. You may also access the “Account” section of our website, and directly access and update a broad range of information about your account, including your Personal Data.

7. Security

While no service is completely secure, Novade takes reasonable measures to protect your Personal Data in our control or possession by making reasonable security arrangements (including, where appropriate, physical, administrative, procedural and information & communications technology measures) to prevent unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or destruction of your Personal Data, or other similar risks. Sensitive information such as password that we request from you on the Novade Services is protected with encryption during transmission over the Internet. In addition, the servers on which Personal Information is stored are kept in a controlled environment with limited access.

While we take reasonable efforts to guard Personal Information we knowingly collect directly from you, no security system is impenetrable. In addition, we cannot guarantee that any passively-collected Personal Information you choose to include in documents you store on our systems are maintained at levels of protection to meet specific needs or obligations you may have relating to that information.

You may access your account information and our service only through the use of an individual user ID and password. To protect the confidentiality of Personal Information, you must keep your password confidential and not disclose it to any other person. Please advise us immediately if you believe your password has been misused. Please note that we will never ask you to disclose your password in an unsolicited phone call or email.

8. Retention of your Personal Data

We will retain and use your information to comply with our legal obligations, resolve disputes and enforce our agreements. If you need more information on personal data retention policy please contact us at privacy@novade.net.

If our use of your data is linked to a Novade Customer agreement, we will retain your Personal Data during the term of the Agreement, unless you or Customer notifies us of a change of representative.

9. Supplemental Terms and Conditions for Certain Regions

European Economic Area (EEA). The following section applies to Personal Data processing which are subject to the EU General Data Protection Regulation 2016/679 (GDPR). Novade Solutions Pte Ltd, located at 111 North Bridge Road, #25-01 Peninsula 179098, Plaza, Singapore is the data controller. The EU representative of Novade Solutions Pte Ltd is Novade Europe, located at 38 Avenue des Ternes, 75017, Paris, France.

We share your Personal data within the Novade group. Since the data controller is located in Singapore, this involves that your data will be processed by an entity outside the European Economic Area (EEA). Furthermore, some of our third-party providers are located outside the EEA, so their processing of your Personal data will entail transfer of data to countries outside the EEA.

Whenever we transfer your Personal Data outside the EEA, we ensure a similar degree of protection is afforded to you by making sure at least one of the following safeguards is implemented:

• we may transfer your data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission;
• otherwise we will have signed with the data importing organization specific contracts (standard contractual clauses) approved by the European Commission.

Please contact us if you want further information on the specific mechanism put in place by us when transferring your data outside the EEA.

If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us at privacy@novade.net. You also have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

Asia Pacific Economic Cooperation (APEC). Novade privacy practices comply with the APEC Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies.

Singapore. Personal information collected, disclosed, stored, used and/or processed by Novade, as described in this Policy, is collected, disclosed, stored, used and/or processed in compliance with the Novade obligations under the Personal Data Protection Act 2012 of Singapore (“PDPA”).

Australia. Personal information collected, stored, used and/or processed by Novade, as described in this Policy, is collected, stored, used and/or processed in compliance with the Australian Privacy Act 1988 (Commonwealth) and the Australia Privacy Principles.

New Zealand. Personal information collected, stored, used and/or processed by Novade, as described in this Policy, is collected, stored, used and/or processed in compliance with New Zealand’s Privacy Act 1993 and its 12 Information Privacy Principles (“NZ IPPs”).

10. Changes to this Policy

We may update this Privacy Policy from time to time. If we make any changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). If there are material changes to this Privacy Policy, we will inform you via email or by way of a notice on the home page prior to the change becoming effective. We encourage you to review our Privacy Policy whenever you access the Novade Services and website to stay informed about our information practices and the ways you can help protect your privacy.

If you disagree with any changes to this Privacy Policy and do not wish your information to be subject to the revised Privacy Policy, please stop using the Novade Services and inform us. Your continued use of any of the Novade Services after any such revision comes into effect shall constitute your consent to such changes.

11. Other conditions

Links to Third Party Websites. We may place links to other websites for your convenience and information. When you click on a link to a third-party website from our website, your activity and use on the linked website is governed by that website’s policies, not by those of Novade. You access these websites at your own risk and we are not responsible for these websites.

Our Policy Toward Children. The Novade Services is not intended for use by individuals under 16. If you become aware that a minor (according to applicable laws) has provided us with Personal Information, please contact us at privacy@novade.net. If we become aware that Customer Data has been collected from a minor (according to applicable laws), we will delete such Personal Data and, where that minor has an account, terminate the minor’s account.

Contacting Us. Any questions about this Privacy Policy should be addressed to privacy@novade.net

English version control. This policy has been originally drawn up in the English language. In case of any discrepancies between the English text version of this Agreement and any translation, the English version shall prevail.