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We updated our Data Policy on May 26th, 2020 to add more detail about how we use your information and what happens when we make changes to our Data Policy. By continuing to use our website and/or our services, you acknowledge our updated Data Policy. You can view our previous Data Policy here.
Novi will be a digital payments product owned and operated by Novi Financial (“Novi”). The Novi website (“Website”) helps Novi (together, “us,” “our”) share information with you about the product (“Product”) and updates.
When you interact with us through this Website, we may collect or receive the following types of information:
Information you provide directly to us. We will collect your full name, email address, and countries you selected as of interest to you.
Information we collect automatically. Depending on your actions, we will also collect certain information automatically when you interact with the Website, such as:
Device attributes: information such as the operating system, hardware and software versions, and browser type.
Device operations: information about elements you’ve interacted with on the Website, mouse movements (which can help distinguish humans from bots), and pages visited on the Website.
Pixel information: information captured from the Facebook pixel such as how many unique visitors viewed the Website.
Network and connections: information such as the name of your mobile operator or ISP, language, time zone, and IP address.
We may use the information you provide or we otherwise collect to:
Analyze the use of the Website. We use your information to understand how you use the Website and how to help us improve.
Comply with legal obligations. We use your information to comply with legal obligations.
Provide you with marketing materials. We use your name and email address to send you promotional emails about our Product if you have signed up for updates by submitting your email address on the Website.
There are certain circumstances in which we may share your information with certain third parties without further notice to you, as set forth below:
Authorized third-party vendors and service providers. We share information with third-party vendors and service providers, including Facebook, who support the Website, such as by providing technical infrastructure services, business analytics, conducting the Website, and data processing.
Affiliates. We may share information with our affiliates, such as with other Facebook Company products; however, we will not share your email address with our affiliates for their own purposes.
Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, detect fraud, and to protect and defend the rights, interests, safety, and security of the Website, our affiliates, owner, users, or the public.
Business transfers. We may share information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
With your consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.
If you access third-party services, such as Google or Twitter, through the Website to login to the Website or to share information about your experience on the Website with others, these services are outside our control. These third-party services may be able to collect information about you, including information about your activity on the Website, and they may notify your connections on the third-party services about your use of the Website, in accordance with their own privacy policies.
If you are a California resident, you can learn more about your consumer privacy rights by reviewing the California Privacy Notice.
We may modify this Data Policy from time to time. When we update the Data Policy, we will revise the “Effective Date” above and post the new Data Policy. We recommend that you review the Data Policy each time you visit the Website to stay informed of our privacy practices.
If you have any questions about this Data Policy or our practices, please contact us online or by mail at:
ATTN: Privacy Operations
1601 Willow Road
Menlo Park, CA 94025
EEA Countries Rider
Our Legal Bases For Processing Information
We rely on a variety of legal bases to process data, including:
as necessary to fulfill our Terms;
consistent with your consent, which you can revoke at any time;
as necessary to comply with our legal obligations;
to protect your vital interests, or those of others;
as necessary in the public interest; and
as necessary for our (or others’) legitimate interests, including our interests in providing an innovative personalised, safe and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights or freedoms that require protection of personal data.
You may withdraw consent at any time. Such withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.
Under applicable laws, you have the right to access, rectify, port, and erase your information, as well as the right to restrict and object to certain processing of your information. You also have the right to object to and restrict certain processing of your data. This includes:
the right to object to our processing of your data for direct marketing, which you can exercise by using the “unsubscribe” link in such marketing communications,
the right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party, and
the right to delete information you have provided us.
We generally retain information until it is no longer necessary to serve the purposes for which it was collected. This is a case-by-case determination that depends on things like the nature of the data, why it is collected and processed, and relevant legal or operational retention needs.
We share information globally, both internally within the Facebook Companies and externally with our partners and with those you connect and share with around the world in accordance with this policy. We utilize standard contract clauses approved by the European Commission and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for data transfers from the EEA to the United States and other countries.
The data controller responsible for your information is Facebook Ireland, which you can contact online, or by mail at:
Facebook Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2 Ireland
You also have the right to lodge a complaint with Facebook Ireland’s lead supervisory authority, the Irish Data Protection Commissioner, or your local supervisory authority.
The Website is available only for your personal and informational purposes. We make no representations or warranties of any kind as to the accuracy, currency, or completeness of the information and other materials made available through the Website. Novi is not liable for any decisions you may make in reliance of this content.
We provide these services to you and others. We ask that you make the following commitments:
Provide accurate information about yourself.
Not use the Website if you are under 13 years old (or the minimum legal age in your country) to use the Website.
You are not prohibited from receiving our products, services, or software under applicable laws or other applicable policies and terms.
You may not access or use, or attempt to access or use, the Website to take any action that could harm us or any third party, interfere with the operation of the Website, or use the Website in a manner that violates any laws. For example, and without limitation, you may not:
Do or share anything that breaches these Terms or other applicable terms;
Upload viruses or malicious code or do anything that could disable, overburden, or impair the proper working or appearance of our products and services;
Access or collect data from our Products using automated means (without our prior permission) or attempt to access data you do not have permission to access;
Submit content that infringes on the copyright, trademark, patent, or other intellectual property rights of any third party, are false, misleading, libelous, defamatory, obscene, abusive, hateful, or sexually-explicit, violate a third party’s right to privacy or publicity, or degrade others on the basis of gender, race, class, ethnicity, national origin, religion, sexual preference, disability, or other classification; and
Engage in any other conduct that restricts or inhibits any person from using or enjoying the Website or that, in our sole judgment, exposes us or any of our users, affiliates, or any other third party to any liability, damages, or detriment of any type.
Violations of system or network security may result in liability. We may investigate and work with law enforcement authorities to prosecute users who violate the Terms. We may suspend or terminate your access to the Website for any reason at any time without notice.
The Website is provided “as is” without warranties of any kind, either express or implied, including without limitation warranties of merchantability, fitness for a particular purpose, title, non-infringement, or other violation of rights. We do not warrant the adequacy, currency, accuracy, likely results, or completeness of the Website or any third-party sites linked to or from the Website, or that the functions provided will be uninterrupted, virus, or error-free. We expressly disclaim any liability for any errors or omissions in the content included in the Website or any third-party sites linked to or from the Website. Some jurisdictions may not allow the exclusion of implied warranties, so some of the above exclusions may not apply to you.
In no event will we, or our owner, subsidiaries, affiliates, directors, officers, employees, agents, and assigns be liable for any direct or indirect, special, incidental, consequential or punitive damages, lost profits, or other damages whatsoever arising in connection with the use of the Website. Any interruption in availability of the Website, delay in operation or transmission, computer virus, loss of data, or use, misuse, reliance, review, manipulation, or other utilization in any manner whatsoever of the Website or the data collected through the Website, even if one or more of them has been advised of the possibility of such damages or loss.
You agree to indemnify, defend, and hold us and our owner, subsidiaries, affiliates, directors, officers, employees, agents and assigns harmless from and against any and all loss, costs, expenses (including reasonable attorneys’ fees and expenses), claims, damages, and liabilities related to or associated with your use of the Website and any alleged violation by you of these Terms. We reserve the right to assume the exclusive defense of any claim for which we are entitled to indemnification under this section. In such event, you shall provide us with such cooperation as we reasonably request.
You agree that your access to and use of the Website will be governed by and will be construed in accordance with the law of the California without regard to principles of conflicts of laws. For any claim, cause of action, or dispute you have against us that arises out of or relates to these Terms, you agree that it will be resolved exclusively in the U.S. District Court for the Northern District of California or a state court located in San Mateo County.
Our Data Policy explains our principles when it comes to the collection, processing, and storage of your information. This policy specifically explains how we, our partners, and users of our services deploy cookies, as well as the options you have to control them.
A cookie is a small piece of data, stored in text files, that are stored on your browser or other device when websites are loaded in the browser. Cookies are used to “remember” you and your preferences when you visit the Website either for a single visit (through a “session cookie”) or for multiple repeat visits (called a “persistent cookie”).
|Type of Cookie||Purpose of Cookie|
|Strictly Necessary||These cookies are essential in order to enable you to use the Website and its features. The information collected by these cookies relate to the operation of the Website, for example website scripting language and security tokens to maintain secure areas of our Website.|
|Performance||These cookies collect anonymous information about how you use our Website, for example which pages you visit most often, whether you receive any error messages, and how you arrived at our Site. Information collected by these cookies is used only to improve your use of Website and never to identify you. These cookies are sometimes placed by third-party providers of web traffic analysis services, such as Google Analytics.|
|Analytics||These cookies are placed by trusted third party networks, like Google Analytics, to track details like number of unique visitors and pageviews to improve user experience|
|Functionality||These cookies remember choices you make, for example the country you visit our Site from, your language and any changes you have made to text size or other parts of web pages that you can customize, in order to improve your experience of our Website and to make your visits more tailored and enjoyable. The information these cookies collect may be anonymized and cannot be used to track your browsing activity on other websites.|
|Third Party / Embedded Content||These cookies enhance the experience of Website users. These cookies allow you to share what you’ve been doing on our Site with social media organizations such as Facebook and Twitter. We have no control over the information collected by these cookies.|
The Novi Website uses strictly necessary, performance, analytics, functionality, and embedded content cookies for the purposes of: providing relevant content, analyzing our traffic, and providing a variety of features to you.
Most internet browsers are automatically set up to accept cookies. However, if you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your internet browser for instructions on how to block or delete cookies. Please note you may not be able to take advantage of all the features of our Website, including certain personalized features, if you delete or disable cookies.
We, or our third party partners, may employ a software technology called web beacons (also known as web bugs, clear gifs or pixels) which helps us understand what content is effective, for example by counting the number of users who have visited these pages, and to understand usage patterns. Web beacons are tiny graphics with a unique identifier, similar in function to cookies, and are used to let us know when content is viewed. In contrast to cookies, which are stored on a user’s computer hard drive, web beacons are embedded on web pages, ads, and e-mail. We, or our third party partners, may tie the information gathered by web beacons to the other information we collect about you.