Last updated: September 1, 2024
This privacy notice for NovoNGen Co. ("Company," "we," "us," or "our") explains how and why we may collect, store, use, and/or disclose ("process") your information when you use our services ("Services"), such as when you:
- Visit our website at http://www.novongen.com, or any other website or mobile application of ours that links to this privacy notice; and/or
- Interact with us in other ways, including through sales, marketing, or events.
Reading this privacy notice will help you understand our privacy practices. If you do not agree with our policies and practices, please refrain from using our Services. If you have any questions or concerns, please contact us at staff@novongen.com.
This summary provides key points from our privacy notice, but for further details on any of these topics, you can use our table of contents below.
What personal information do we collect? When you visit, use, or navigate our Services, we may collect personal information depending on how you interact with NovoNGen Co. and the Services, the choices you make, and the products and features you use.
Do we receive any personal information from third parties? We do not receive personal information from third parties. However, we may receive information about you from other users of the Services.
Why do we collect personal information? We collect, use, and disclose personal information to provide, improve, and manage our Services, communicate with you, ensure security and fraud prevention, and for marketing purposes. We do not sell your personal information. We may also collect, use, or disclose personal information for other purposes with your consent.
In what situations and with which types of parties do we disclose personal information? We may disclose information in specific situations and with specific categories of third parties.
How do users disclose information on NovoNGen? Your public profile, which can be customized, is accessible to other users on the platform. You may also choose to disclose additional information to certain users by responding to event questionnaires and posting content on the platform.
How do we protect personal information? We have implemented organizational and technical processes and procedures designed to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. We cannot promise or guarantee that unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on your geographic location, applicable privacy laws may grant you certain rights regarding your personal information.
How can you exercise your rights? The easiest way to exercise your rights is by contacting us using the details listed in the “How Can You Contact Us About This Notice” section below.
Personal information you disclose to us.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide when you register for the Services, express an interest in obtaining information about us or our products and Services, participate in activities on the Services, or otherwise contact us.
Personal information provided by you. The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. This information may include:
- App and Services usage
- Phone number
- Name(s)
- Contact book information if you give us permission to sync your device’s contact book (such as the name and phone number of your contacts, which we will use to allow you to invite those contacts to an event through the Services)
- Birthdate, which you can choose to provide during account creation (note: while we may share your birthday with other users, we will not share your birth year with them)
- Social media handles
- Other information you may choose to provide to create/update/publish your contents on the platform
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such information.
Personal information provided by others.
In Short: We may receive personal information about you from other users.
We may receive limited personal information about you from other users of the Services in the following scenarios:
- Just as you may provide information about your contacts when you sync your device’s contact book, others may provide this information about you when they do the same.
Information automatically collected.
In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you use our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
We may collect this information through cookies and similar technologies.
The information we collect includes:
- Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings, as well as information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take, such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).
- Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, internet service provider (ISP) and/or mobile carrier, operating system, and system configuration information.
- Location Data: We collect location data, including information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
- Session replay technologies.
In Short: We use session replay technologies on our Services to improve usability.
We use services provided by our third-party service providers that employ cookies and local storage technologies to record and allow us to review replays of user sessions. The replays include users’ clicks, mouse movements, scrolls, text entered, and time spent on the webpage during those sessions. These replays help us diagnose usability problems and identify areas for improvement.
In Short: We use personal information to provide, manage, and improve our Services, communicate with you, ensure security and fraud prevention, conduct research and development, and comply with legal obligations. We may also process your information for other purposes with your consent.
We use personal information:
- To operate and administer our Services. We will use your personal information to operate and administer our Services in accordance with our contractual terms and conditions or to take steps to enter into a contract with you at your request. Depending on how you interact with our Services, we will use your personal information to provide, operate, and maintain our Services and business, including to facilitate account creation, authentication maintenance, and to otherwise manage user accounts.
- To communicate with you about our Services. To perform our contractual obligations or when it is in our legitimate business interests, we will use personal information to respond to your requests, provide customer support, and communicate with you about our Services, including by sending announcements, updates, security alerts, and support and administrative messages.
- To improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe for our users, which includes: understanding your needs and interests, and personalizing your experience with the Services and our communications; troubleshooting, testing, and research to keep the Services secure; and investigating and protecting against fraudulent, harmful, unauthorized, or illegal activity.
- For marketing and advertising. We and our advertising partners may collect and use your personal information for marketing and advertising purposes, as permitted by law. You may opt out of our marketing communications, as described in Section 9 below. We do not sell your personal information.
Except where consent is required, we undertake such marketing and advertising on the basis of our legitimate business interests. Where we seek your consent, you may withdraw your consent at any time.
- To measure the effectiveness of advertising campaigns to promote our Services. Except where we rely on your consent, it is in our legitimate interests to use your personal information to track the effectiveness of advertising campaigns.
- For compliance and protection. We may use your personal information to comply with legal obligations and to defend ourselves against legal claims or disputes, including to protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); audit our internal processes for compliance with legal and contractual requirements and internal policies; enforce the terms and conditions that govern the Services; prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft; and comply with applicable laws, lawful requests, and legal processes, such as to respond to subpoenas or requests from government authorities.
- For research and development. We may create and use de-identified information in our legitimate business interests, including to analyze the effectiveness of our Services, to improve and add features to our Services, and to analyze the general behavior and characteristics of users of our Services. We may use this anonymous, aggregated, or de-identified data and disclose it to third parties for our lawful business purposes.
In Short: We may disclose information in specific situations described in this section and/or with the following categories of third parties.
Vendors, Consultants, and Other Third-Party Service Providers: We may disclose personal information to third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot use or disclose your personal information, except to provide services to us or on our behalf, unless we have instructed them to do so. The categories of third parties to which we may disclose personal information include the following:
Professional advisors: We may disclose personal information to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services they render to us.
Authorities and others: We may disclose personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for compliance and protection purposes.
Business Transfers: We may disclose 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.
In Short: Your public profile, which can be customized, is available to other users on the platform. You may also disclose additional information to certain users by responding to event questionnaires and posting content on the platform.
Your public profile is configurable by you. The profile contains a name and any NovoNGen badges you have been awarded, and may also include other optional information such as a profile picture, birthday, a bio, or social handles. This public profile is available for viewing by other users on the platform. Your phone number is only visible to you and is never displayed to other users unless you explicitly choose to disclose it.
Additionally, hosts have the option to add a questionnaire for attendees to fill out when RSVPing to an event; answers provided by you will be disclosed to the host(s).
In some cases, hosts may be event sponsors or marketing partners. If you choose to RSVP to their events, you will disclose your public profile and any questionnaire responses you choose to provide. Hosts may use the information you disclose to them for their own purposes, subject to the limitations in our Terms & Conditions.
The Terms & Conditions prohibit our hosts, event sponsors, and marketing partners from downloading any information from NovoNGen for marketing purposes or contacting users outside our platform.
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
Where required under applicable laws, we retain personal information only for as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with applicable laws and regulatory obligations or until you withdraw your consent (where applicable).
To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure. Therefore, we cannot promise or guarantee that unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of a minor dependent and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at staff@novongen.com.
If you would like to review or change the information in your account or terminate your account, you can contact us using the contact information provided in the “How Can You Contact Us About This Notice” section below.
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.
Personal information requests: We offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information...
- Information about how we have collected and used personal information.
- Access to a copy of the personal information that we have collected about you.
- Correction of personal information that is inaccurate or out of date.
- Deletion of personal information that we no longer need to provide the Services or for other lawful purposes.
- Withdrawal of consent, where applicable.
- Additional rights, such as to object to and request that we restrict our use of personal information.
To make a request, please email us or write to us as provided in the“How Can You Contact Us About This Notice” section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.
Right to complain. Depending on where you reside, such as if you reside in the European Economic Area (“EEA”) or the United Kingdom (“UK”), you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.
Opt out of marketing communications. You may respond "STOP" to any NovoNGen text message to stop receiving all text messages from NovoNGen.
Adjust contact book preferences. You can revoke NovoNGen’s access to your contact book by adjusting your device settings.
Opt out of receiving invitations from past hosts or mutuals. Past hosts and mutuals may send you invitations to other events via NovoNGen, unless you have opted out of receiving future invitations from the host or mutual. If you receive an invitation, you may respond “X” to the text message to stop receiving future invitations from that host or mutual.
Online tracking opt-out. There are several ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:
Opt out. You can opt out of third-party cookies as described in our Cookie Policy.
Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Using privacy plug-ins or browsers. You can block our Services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery, or uBlock Origin, and configuring them to block cookies/trackers.
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
If you have questions or comments about your privacy rights, you may email us at staff@novongen.com.
You will provide personal information directly to our Services in the United States. We may also transfer personal information to our affiliates and service providers in the United States and/or other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.
When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal information, and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal information.
For more information about how we transfer personal information internationally, please contact us as set out in the“How Can You Contact Us About This Notice” section below.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to remain informed about how we protect your information.
If you have questions or comments about this notice, you may email us at staff@novongen.com.
