Date Last Updated: June 29, 2020
Novo Platform Inc. (“Novo”) operates the Novo software platform. It is Novo’s policy to maintain the confidentiality, integrity, and security of any personal information about its users.
This Privacy & Security Policy (“Policy”) explains how Novo (“We”, “Us”, or “Our”) collects, uses, shares, and keeps secure your information (“You”, “you”, “Your”, or “User”), including your nonpublic personal information, when You use Novo’s website novo.co (the “Website”), mobile application (the “App”), and any related products and services (collectively referred to as the “Services”).
By using Our Services, you are agreeing to this Policy. If you do not agree to these terms, you may not enroll in or use the Services. Pursuant to this Policy, You direct Our partner financial institution(s) to share your transactional data with Novo, and you direct Novo to share your data with its users, vendors, partners, and affiliates at its discretion, in a way that would otherwise be contrary to this Policy.
1. Website Visitors
Like most website operators, Novo collects non-personally-identifying information that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. Novo’s purpose in collecting non-personally identifying information is to better understand how Novo’s visitors use its website. From time to time, Novo may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website.
Novo also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in Users and for Users leaving comments on blogs. Novo only discloses logged in User and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below, except that blog commenter IP addresses and email addresses are visible and disclosed to the administrators of the blog where the comment was left.
Novo collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor’s interaction with Novo. Novo does not disclose personally-identifying information other than as described below. And visitors can always refuse to supply personally-identifying information, with the caveat that it may prevent them from engaging in certain Services.
2. Customers of Novo
Gathering of Personally-Identifying Information
The amount and type of information that Novo gathers depends on the nature of the interaction. Certain visitors to Novo’s websites choose to interact with Novo in ways that require Novo to gather personally-identifying information, most notably when becoming a “Customer” (which means that you have registered with Novo to use its App or related products or services). Registration involves provision of an email address, a password, and a PIN (collectively the “Registration Information”).
In order to benefit from the full functionality of the Services, you also must provide your third-party account credentials (“Account Credentials”) to allow Novo and our partners to access your account data at those other financial institutions (“Account Information”) for your use.
To help the government fight the funding of terrorism and money laundering activities, the USA PATRIOT Act, a Federal law, requires financial institutions to obtain, verify, and record information that identifies each business that opens an account and the personal information of its owners or representatives. Therefore, when applying to become a Customer, Novo, on behalf of its partner financial institution, We will collect personally-identifying information about You personally and about Your business to establish and maintain Your account. Personal information may include, but is not limited to, your name, personal address (residential address required, no PO box address allowed), date of birth, social security number (SSN), and other similar information. Business information may include, but is not limited to, your business name, tax identification number, business address, business telephone number, business bank account information, business related documentation, telephone number, and email address. Additional information will be requested at account opening and may be requested throughout the life of the account relationship to meet regulatory and legal requirements. If you choose to provide us with personal information, business information, financial information, and financial data, you consent to the transfer and storage of that information on our servers located within the United States.
Use of Personally-Identifying Information
Novo and its affiliated companies use and disclose User’s personal information to provide the Services, including for the purposes of:
- Analyzing site usage and improve the Service;
- Delivering to You any administrative notices, alerts and communications relevant to your use of the Service;
- Marketing Our products and services and those of our business partners that We believe may be of interest to You;
- Fulfilling Your requests for certain products and services;
- Market research, project planning, troubleshooting problems, detecting and protecting against error, fraud or other criminal activity;
- Third-party contractors providing services to Novo which are bound by these same privacy restrictions;
- As otherwise set forth in this Privacy and Security Policy (including disclosures to protect our rights, if required by law, or relating to a transfer of control or sale of assets, as discussed below).
3. Third Parties
The Services may present you information relating to third party products or services (Novo Offers), as well as provide you general tips, recommendations and educational material.
When using our Services, You may have the option to provide Us with information from third parties, such as Facebook, Twitter, Google, and LinkedIn. We may also acquire information about You from third parties in order to verify your identity, process Your transactions, detect and prevent fraud, or other similar purposes.
We are not responsible for the privacy practices of any third parties or the content of sites that are linked from our Services. We strongly encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.
4. Protection of Certain Personally-Identifying Information
Novo discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors and affiliated organizations that (i) need to know that information in order to process it on Novo’s behalf or to provide services available at Novo’s websites, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using Novo’s Services, you consent to the transfer of such information to them. Novo will not rent or sell potentially personally-identifying and personally-identifying information to anyone. Other than to its employees, contractors and affiliated organizations, as described above, Novo discloses potentially personally-identifying and personally-identifying information only in response to a subpoena, court order or other governmental request, or when Novo believes in good faith that disclosure is reasonably necessary to protect the property or rights of Novo, third parties or the public at large.
If you are a registered user of Novo Services (i.e. Customer) and have supplied your email address, Novo may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Novo and our products. We primarily use our various product blogs to communicate this type of information, so we expect to keep this type of email to a minimum. If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. Novo takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally-identifying and personally-identifying information.
The security of your personal information is important to us. We utilize physical, electronic and procedural security measures to protect against loss, misuse, and alteration of information under our control. We offer industry-standard practices and security measures to safeguard and secure the personal information we collect. However, some of the application or networks that you use may not be completely secure, thus we cannot guarantee absolute security.
5. Cookies & Other Technologies
We may also use various technologies to collect and store information related to Your use of our Services. We may collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
6. Business Transfers
If Novo, or substantially all of its assets, are acquired, or in the event that Novo goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Novo may continue to use Your personal information as set forth in this Policy.
9. Opting Out of This Policy
If you no longer wish to use our Services and would like to delete or deactivate your account, please contact us at firstname.lastname@example.org. We are required by law to retain your information, and may also do so for legitimate business purposes, including internal analytics. However, we will not share or use your information for promotional and marketing purposes (except in an anonymized or de-identified form) after you have deleted or deactivated your account. As previously noted, your usage of our Services is contingent on your expressly opting in to this Policy.
10. Social Media
Regarding your creating an account or logging into the Website or App through a social media service or similar tool, such as Log in with Facebook or Sign in with Twitter (whether the use of such tools to sign in is optional or mandatory), any information that these third party social media sites collect as a function of your using those sign-in tools is subject to those respective entities’ own privacy policies. If you sign-in to the Website or App using such third party sign-in tools, certain personally identifiable information from those third party websites or services may be shared with Novo. We will treat this information shared with us in accordance with this Policy.
You are entirely responsible for maintaining the confidentiality of your username(s), password(s), and your account(s), as well as all activities that occur under your account(s). You hereby agree to indemnify, defend, and hold us, our agents, representatives and other authorized users, and each of the foregoing entities’ respective officers, directors, owners, employees, agents, representatives and assigns (collectively the “Indemnified Parties”) harmless from and against any and all losses, damages, liabilities and costs incurred by the Indemnified Parties in connection with any claim arising out of any breach by you of this Policy or claims arising from Our Services. You agree to use your best efforts to cooperate with us in the defense of any claim. We reserve the right, at our own expense, to employ separate counsel and assume the exclusive defense and control of any matter otherwise subject to indemnification by you.
12. Contact Us
Please contact Novo with any questions or concerns regarding our policy.
Novo Platform Inc.
Miami, FL 33130
By e-mail at: email@example.com.