Privacy Policy
Last Updated: July 2024
1. Introduction.
Welcome to Novaestiq (“Novaestiq,” “Site,” or “it”), a Web-based software toolset operated by Novaestiq (“Provider”). This page explains the terms by which you may use our online and/or mobile services, website, and software and any other content provided on or in connection with the service (collectively the “Service” or “Services”). This Privacy Policy also supplies you with additional information required by the California Consumer Privacy Act in Section 14.
This privacy policy (the “Privacy Policy”) applies to the Services that link to or post this Privacy Policy, and explains how Providers collect, use, and disclose information through the Services. By using the Services, you agree to the terms of this Privacy Policy.
This Privacy Policy does not apply to Provider websites that do not link to this Privacy Policy. In some instances, it may direct you to a site that is operated by a third-party service provider. Even though the page where you provide information may have the look and feel of the Services, a different privacy policy may govern that information collection by Provider’s third-party service provider.
Individuals who are natural person investors in a fund managed, advised or administered by Provider and their employees will receive an Investor Privacy Policy as part of the subscription document they enter into when they become an investor in our fund and, in the event of any conflict with this Privacy Policy, the terms of that Investor Privacy Policy will control.
2. Information Collection.
You generally are not required to provide information about yourself when you visit the Services. However, it may ask you for some or all of the following types of information when you register with the Services, participate in surveys, access various content or features, submit comments or content, use a send-to-a-friend feature, or directly contact Provider with questions or feedback:
- Contact information, such as name, e-mail address, postal address, and telephone number;
- Unique identifiers, such as a username or password;
- Demographic information, such as gender;
- Financial information, such as credit card or other payment information;
- Geolocation information, to the extent such information can be derived with reference to an IP address;
- Electronic network activity information, including operating system type and version, browser information, and information related to your use of Site; This is to help Provider ensure you have the best browsing experience possible.
- Communications preferences;
- Search queries;
- Comments and other information posted in the Site’s interactive online forums;
- Employment application information and other information collected in the context of evaluating applicants, which may include professional or employment information, information regarding protected characteristics, and educational information;
- Commercial information related to your business interactions with the Provider;
- Correspondence and other information that you send to Provider; and
- Additional information as otherwise described to you at the point of collection or pursuant to your consent.
Site may also collect certain information automatically when you visit the Services, including:
- Your Internet Protocol address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
- Other unique identifiers, including mobile device identification numbers;
- Your browser type and operating system;
- Sites you visited before and after visiting the Services;
- Pages you view and links you click on within the Services;
- Information collected through cookies, web beacons, Local Shared Objects, and other technologies;
- Information about your interactions with e-mail messages, such as the links clicked on and whether the messages web received, opened, or forwarded; and
- Standard Server Log Information
3. Use of Information.
Site may use information that it collects through the Services for a variety of purposes, including to:
- Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that it receive from you;
- Contact you via email and otherwise about your account, products, services, and events that it thinks might be of interest to you;
- Send you promotional material or special offers on Provider’s behalf or on behalf of Provider’s marketing partners and/or their respective affiliates and subsidiaries and other third parties;
- Maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of Provider’s business, the Services, and other products and services it offers;
- Publish stories, comments, photos, and other information posted in the Site’s interactive online features;
- Process employment applications and inquiries;
- As otherwise described to you at the point of collection or pursuant to your consent.
4. Sharing of Information.
Site is committed to maintaining your trust, and it wants you to understand when and with whom it may share the information it collects. At times, as described below, it may share your personal information with others for various purposes:
- Service Providers: Site may share your information with service providers that perform certain functions or services on Provider’s behalf (such as to host the Services, fulfill orders, provide products and services, manage databases; perform analyses, process credit card payments, provide customer service, or send communications for Provider). These companies are authorized to use your personal information only as necessary to provide these services to Provider.
- Subsidiaries and Affiliates: Site may share your information with Provider’s subsidiaries and affiliates for business purposes described herein.
- Third-Party Ad Serving and Audience and Traffic Measurement Services: Site may use third-parties to serve advertisements on the Services. These third parties may set their own cookies or similar web technologies to collect information about users’ online activities over time and across different websites. You may manage your preferences by using the following link: http://preferences-mgr.truste.com/.
- Business Transfer: If Site sells all or part of its business, or makes a sale or transfer of assets, or is otherwise involved in a merger or business transfer, or in the unlikely event of bankruptcy, a business reorganization, or similar event, Site may transfer your information as part of such transaction.
- Administrative or Legal Process: Site may disclose your information to third parties in order to protect the legal rights, safety, and security of Provider, its corporate affiliates, subsidiaries, business partners, and the users of the Services; enforce its Terms of Use; respond to and resolve claims or complaints; prevent fraud or for risk management purposes; and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.
- Other Parties with Your Express Consent: Site may share information with third parties when you consent to such sharing.
- Aggregate Information: Site may share aggregate information, such as demographics and usage statistics, with advertisers, sponsors or other organizations.
- Geo-Location Data and Services Providers: Site may share your geo-location data with service providers that perform certain functions or services on Provider’s behalf (such as to host the Services, fulfill orders, provide products and services, manage databases, perform analyses, process credit card payments, provide customer service, or send communications for Provider). These companies are authorized to use your geo-location data only as necessary to provide these services to Provider.
- Geo-Location Data and Third Parties: Site may share your geo-location data with third parties for the purpose of them serving you ads relevant to you.
5. Tracking Technologies & Cookies.
Technologies such as: cookies, beacons, tags, and scripts are used by the Provider and its marketing partners, affiliates, and other service providers such as analytics providers and e-commerce providers. These technologies are used in analyzing trends, administering the Site, tracking users’ movements around the Site and gathering demographic information about Provider’s user base as a whole. Site may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. Site uses cookies for various purposes as described above and in addition to remember users’ settings (e.g., language preference) and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Site, but your ability to use some features or areas of the Site may be limited.
As is true of most websites, Site gathers information automatically and store it in log files. This information may include Internet Protocol address, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and or clickstream data. Site may combine this automatically collected log information with other information it collects about you. It does this to improve services it offers to you, and to improve marketing, analytics and Site functionality.
Site uses Local Storage Objects (“LSO”) such as HTML5 to store content information and preferences. Third parties with whom Site partners to provide certain features or to display advertising based upon your web browsing activity use LSOs such as HTML 5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.
By using the Services, you consent to Site’s use of cookies and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies and similar technologies, you may not be able to use certain online products, services or features on the Services.
6. Behavioral/ Re-Targeting.
Site partners with a third party ad network to either display advertising on its website or to manage its advertising on other sites. Provider’s ad network partner uses cookies and web beacons to collect personal information about your activities on this and other websites. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by visiting Digital Advertising Alliance (DAA)’s self-regulatory opt-out page (http://optout.aboutads.info/) and mobile application-based “AppChoices” download page (https://youradchoices.com/appchoices) or Network Advertising Initiative (NAI)’s self-regulatory opt-out page (http://optout.networkadvertising.org/) or if located in the European Union visit European Interactive Digital Advertising Alliance (EDAA)’s consumer opt-out page (http://youronlinechoices.eu). Please note that this does not opt you out of being served advertising. You will continue to receive generic ads.
7. Links to Other Websites.
The Services may contain links to other websites or online services that are operated and maintained by third parties and that are not under Provider’s control or maintained by Provider. Such links do not constitute an endorsement by Provider of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this third-party content. Site encourages you to review the privacy policies of these third-party websites or services.
8. Security.
Site has adopted generally accepted standards to help protect against loss, misuse, and unauthorized access to the information you provide to Provider. When you enter sensitive information (such as a credit card number) and geo-location, it encrypts the transmission of that information using secure socket layer technology.
Please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, while Site strives to protect your information and privacy, it cannot guarantee or warrant the security of any information you disclose or transmit to the Services. Therefore, Site cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.
9. Children’s Privacy
The Services do not knowingly collect, use, or disclose personal information from children under the age of 13. If Provider is made aware Provider has collected personal information from a child under 13 years old in a manner that is inconsistent with the Children’s Online Privacy Protection Act of 1998 (15 U.S.C. 6501 et seq.) (“COPPA”), Provider will delete this information as soon as possible.
10. Access, Choice and Retention.
Upon request Provider will provide you with information about whether Provider holds any of your personal information. If your information changes, or if you no longer desire to use the Services, you may access or correct your personal information or request your information be excluded from future use by Provider for the purposes set forth herein by signing into your account and making the required changes, by emailing Provider at inquiries@novaestiq.com or by contacting Provider by postal mail at the contact information listed below. Provider will respond to your request within a reasonable timeframe.
Provider will retain your information for as long as your account is active or as needed to provide you services. Provider will retain and use your information as necessary to comply with Provider’s legal obligations, resolve disputes, and enforce Provider’s agreements.
You may choose to receive promotional emails, newsletters, push notifications, and similar communications from Site. You may opt out of receiving commercial emails from Provider by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive or by turning off push notifications at the device level. Please note that opt-out requests may take up to ten (10) days to be effective. Your opt-out request will not apply to messages that you request or that are not commercial in nature. For example, Site may contact you concerning any purchases you have made with Provider, even if you opt out of receiving unsolicited commercial email messages.
11. Your California Privacy Rights; California Consumer Privacy Act.
This California Consumer Privacy Act Notice (“Notice”) provides additional information to California residents whose personal information is processed by Provider pursuant to the California Consumer Privacy Act as modified by the California Privacy Rights Act (referred to together as the “CCPA”). If you are not a California resident, this Notice does not apply to you.
11A. Categories of Personal Information Collected and Disclosed
During the preceding 12 months, Provider has collected the following categories of personal information that are processed pursuant to the CCPA: (1) identifiers, such as your contact information and online account information; (2) professional information; (3) financial information and other information as described above that may be considered personal information under Cal. Civ. Code Section 1798.80; (4) commercial information including records or products or services purchased.
As set forth in the Policy, Provider discloses personal information to third parties for business purposes, including without limitation, for purposes of advertising, marketing, and other services performed on Provider’s behalf, to protect against fraud and malicious activity, and for other business purposes described in the Policy. During the preceding 12 months, Provider has disclosed each of the above-listed categories of personal information for such business purposes. In addition, your information may be accessible to third parties with whom you interact or direct Provider to share your information through Provider services.
We may collect information that is considered “sensitive” under some laws including the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), such as your account log-in information if you log into our portal. When we do so, we use such information only for lawful purposes in compliance with applicable laws, such as to perform the services requested by you and to resist malicious, deceptive, fraudulent or illegal actions. Where required by applicable law, we will obtain your consent prior to processing such information.
We do not “sell” or “share” your personal information, as those terms are defined under the CCPA, and have not done so within the past 12 months.
11B. CCPA Rights
If your personal information is protected by the CCPA, you may have certain rights in respect to your information. These rights include:
The right to know information we collect about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we collect about you;
The right to delete personal information that we collect from you;
The right to correct inaccurate personal information that we may maintain about you;
The right to opt-out of the sale or sharing of personal information; and
The right to limit certain uses of sensitive personal information; and
We will not discriminate against you for exercising any of these rights. If you wish to exercise any of the rights set out above, please submit your request by visiting https://novaestiq.com/ccpa/.
We will review your requests and respond accordingly. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard.
Individuals who submit a rights request will be required to verify their identity by answering certain questions. To do so, we will request that you match specific pieces of information you have provided us previously. If it is necessary to collect additional information from you, we will use the information only for verification purposes and will delete it as soon as practicable after complying with the request. If we are unable to verify your identity, we may need to deny your request.
You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.
Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.
12. Changes to this Privacy Policy.
Site may update this Privacy Policy to reflect changes to its information practices at any time. When it does so, we will notify you by updating the last updated date at the beginning of this Privacy Policy. Your continued use of the Services after any modification to the Privacy Policy will constitute your acceptance of the new terms. Site encourages you to periodically review this page for the latest information on Provider’s privacy practices.
13. International Users.
Please note that the Services are directed towards users who reside in the United States. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States, which may not offer the same level of privacy protection as your own.
14. Contact Us.
If you have any questions about this Privacy Policy or the privacy practices of the Services, please contact Provider by email at inquiries@novaestiq.com.