Novasec Privacy Policy

NOVASEC PRIVACY POLICY

Last Updated: December 1, 2019

This privacy policy (" Privacy Policy") governs how we, Novasec Ltd. (together, " Novasec" " we", " our" or " us") use, collect and store Personal Data we collect or receive from or about you (" User", " you") such as in the following use cases:

  1. When you browse or visit our website, https://www.novasec.io/(" Website");
  2. When you make use of, or interact with, our Website;
  3. When you sign up for our newsletters / distribution lists / email lists;
  4. When you contact us (through our website, email, phone or social media);
  5. When we use the Personal Data of our investors (e.g. KYC checks);
  6. When you attend a marketing event and provide Personal Data;
  7. When you exchange business cards with us;
  8. When we acquire your Personal Data from third-party sources; and
  9. When we use the Personal Data of our service providers.

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to Personal Data. “Personal Data” means any information that can be used, alone or together with other data, to uniquely identify any living human being. Please note that this is a master privacy policy and some of its provisions only apply to individuals in certain jurisdictions. For example, the legal basis in the table below is only relevant for GDPR-protected individuals.

Please also note that Novasec may in the future provide an option for investors to hold their investments in digital form. We may update this Privacy Policy if and when this feature becomes available and to the extent required.

Table of contents: 1. What information we collect, why we collect it, and how it is used. 2. Period of storage of collected information 3. How we protect and store your personal data 4. How we share your personal data 5. Additional information regarding transfers of personal data 6. Your rights 7. Use by children 8. Links to and interaction with third party product 9. Log files 10. Analytic tools 11. California privacy rights 12. Our California do not track notice 13. Deletion of content from California residents 14. Contact us

This Privacy Policy can be updated from time to time and therefore we ask you to check back periodically for the latest version of the Privacy Policy, as indicated below. If there will be any significant changes made to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

  1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED

Data we collect

Why is the data collected and for what purposes?

Legal basis (GDPR only)

Third parties with whom we share your data

Consequences of not providing the data

(i) When you browse or visit our Website

Cookies, analytic tools and log files.

For more information, please read our cookies policy:https://www.novasec.io/cookies-policy/

To improve the experience, information that we present in our website.

Consent.

Legitimate interest (e.g. essential cookies).

3rd party platforms such as for the following purposes:

  • Google (analyzing traffic sources and usage of the website (United States))
  • Whisp (platform and website developers (Israel))
  • MindAd Media (SEO services (Israel))

Cannot collect and store the information.

Cannot use or access some parts of the Website.

(ii) When you make use of, or interact with, our Website

(ii a)When you sign up for our newsletters / distribution lists/ email lists

Email addresses.

  • To add you to our mailing list.
  • To send newsletters or other communications.

To send you updates of the investments.

Consent.

Legitimate interest

(e.g., to send you more information about Novasec).

3rd party platforms such as for the following purposes:

  • Google (Gmail and Storage (United States))
  • SendGrid (marketing and storage (United States))
  • Whisp (platform and website developers (Israel))

Cannot add you to our mailing list.

Cannot send you newsletters or other communications.

Cannot send you updates.

(iii) When you contact us (through our website, email, phone or social media)

Full name

Email address

  • Phone
  • Message

Any other data you decide to provide/supply

  • To process and answer your questions.

If you so request, we will add you to our investor database in case of interest in Novasec's projects.

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g., to answer your query and/or process your request).

3rd party platforms such as for the following purposes:

Namecheap (domain name registrar and website hosting provider (United States))

  • Netlify (hosting serverless platform (United States))
  • Whisp (platform and website developers (Israel))

Cannot assist you and respond your query.

Cannot process your request.

(iv) When we use the Personal Data of our investors (e.g. KYC checks)

  • Full Name
  • Email address
  • Phone number
  • ID number / copy of passport
  • Company name
  • Job position
  • Proof of address
  • Certificate of incorporation or similar charter documents

Shareholders register, stockholders' ledger, or certificate of incumbency

  • Copy of passport for each ultimate beneficial holder of the entity
  • Proof of address for each ultimate beneficial holder of the entity
  • Any other information that you decide to provide/supply us

To provide you more information about investments opportunities.

To perform the agreement.

To perform AML / KYC and accreditation checks.

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. to send you more information about investments opportunities).

Compliance with AML and KYC requirements, laws and policies.

3rd parties such as for the following purposes:

  • Google (Gmail and Storage (United States))
  • EarlyIQ (AML / KYC and accreditation checks (United States))
  • Whisp (platform and website developers (Israel))
  • Docsend (VDR services (United States))
  • Imprima i-Rooms (VDR services (United Kingdom))

In certain cases, we may need to share this information with the project SPV, banks or similar financial institutions, law firms, brokers / dealers.

Cannot provide you with more information about investment opportunities.

Cannot perform the agreement.

Cannot perform AML / KYC and accreditation checks.

(v) When you attend a marketing event and provide Personal Data

Full Name

Email address

Phone number

Company name

Any other information that you decide to provide/supply us

To establish a business connection.

To send newsletters or other marketing communications.

Consent.

Legitimate interest (e.g. to send you more information about Novasec).

3rd party platforms such as for the following purposes:

Google (Gmail and storage (United States))

  • SendGrid (marketing and storage (United States))

Cannot establish a business connection.

Cannot send marketing communications.

(vi) When you exchange business cards with us

  • Full Name
  • Email address
  • Phone number
  • Company name
  • Any other information that you decide to provide/supply us

To establish a business connection.

To send newsletters or other marketing communications.

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.

Legitimate interest (e.g. to send you more information about Novasec).

3rd party platforms such as for the following purposes:

Google (Gmail and storage (United States))

SendGrid (marketing and storage (United States))

Cannot establish a business connection.

Cannot send marketing communications.

(vii) When we obtain your Personal Data from third-party sources (such as banks, brokers dealers and other third parties that provide your data such as partners, affiliates, subsidiaries or other entities with whom you interact or have interacted)

  • Full Name
  • Email address
  • Phone number
  • ID number / copy of passport
  • Company name
  • Job position
  • Proof of address
  • Certificate of incorporation or similar charter documents

Shareholders register, stockholders' ledger, or certificate of incumbency

  • Copy of passport for each ultimate beneficial holder of the entity
  • Proof of address for each ultimate beneficial holder of the entity
  • Any other information that you decide to provide/supply us
  • To provide you more information about investments opportunities
  • To perform the agreement
  • To perform AML / KYC and accreditation checks
  • To establish a business connection
  • To send newsletters or other marketing communications.

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. to send you more information about investments opportunities)

Compliance with AML and KYC requirements, laws and policies

3rd parties such as for the following purposes:

Google (Gmail and Storage (United States))

  • EarlyIQ (AML / KYC and accreditation checks (United States))
  • Whisp (platform and website developers (Israel))
  • Docsend (VDR services (United States))
  • Imprima i-Rooms (VDR services (United Kingdom))

In certain cases, we may need to share this information with the project SPV, banks or similar financial institutions, law firms, brokers / dealers.

Cannot provide you with more information about investment opportunities

Cannot perform the agreement

Cannot perform AML / KYC and accreditation checks

Cannot establish a business connection

Cannot send newsletters or other marketing communications

(viii) When we use the Personal Data of our service providers and suppliers

● Full name

● Email address

● Company name

● Job position

● Phone number

● Any other data you decide to provide/supply

● To contact our service providers

● To perform the agreement

Processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

Legitimate interest (e.g. perform the contract, send contract-related communications)

3rd party platforms such as for the following purposes:

Google (Gmail and Storage (United States))

Cannot communicate with you

Cannot perform the agreement

Finally, please note that some of the abovementioned Personal Data will be used for fraud detection and prevention, and for security purposes. The abovementioned personal data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize your personal data. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).

  1. PERIOD OF STORAGE OF COLLECTED INFORMATION

Personal Data. Your Personal Data (as described above) will be stored until we no longer need the information and proactively delete it or you send a valid deletion request. Please note that we will retain it for a longer or shorter period in accordance with data retention laws. We have an internal data retention policy to ensure that we do not retain your Personal Data perpetually.

Cookies. This depends on the cookie in question. Some cookies (e.g. essential cookies) cannot be disabled. You may also control and delete these cookies through your browser settings. Read more in our cookie policy

  1. HOW WE PROTECT AND STORE YOUR INFORMATION
  • Security. We have implemented appropriate technical, organizational and security measures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to such information appropriate to the nature of the information concerned. However, please note that we cannot guarantee that the information will not be exposed as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  • Retention of your Personal Data. In addition to the retention periods mentioned in Section 1 above, in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
  1. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described in Section 1, we may share your information as follows:

  • To the extent necessary, with regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;

  • If, in the future, we sell or transfer some or all of our business or assets to a third party, we will (to the minimum extent required) disclose information to a potential or actual third party purchaser of our business or assets. In the event that we are acquired by or merged with a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer or assign Personal Data in connection with the foregoing events.

  • Where you have provided your consent to us sharing the Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality); and

  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

If you want to receive the list of recipients of your Personal Data, please make your request by contacting us to info@novasec.io.

  1. ADDITIONAL INFORMATION REGARDING TRANSFERS OF PERSONAL DATA

Storage: Our third party storage providers are located in the following countries:

• Namecheap: domain services data is stored and processed in data centers located in the United States. • Google: Gmail is hosted in the United States. • Netlify (CDN serverless platform): is hosted on Digital Ocean in the Unites States (San Francisco, California). • SendGrid: data is stored and processed in data centers located in the United States (Denver and Colorado). • EarlyIQ: data is stored and processed in the United States (California). • DocSend data is stored and processed in the United States (California). • Imprima i-Rooms: data is stored and processed in England, United Kingdom (London).

Access from Israel: Access from Israel (e.g. by our staff located in Israel and our service providers in Israel) is covered by the European Commission’s Adequacy Decision regarding Israel. You can read more here: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en

Internal transfers: To the extent there are transfers of personal data to project SPVs, a processing agreement may govern such transfers as required by applicable laws.

External transfers:

  • Where we transfer your Personal Data outside of EU/EEA, for example to third parties who help provide our products and services, we will obtain contractual commitments from them to protect your Personal Data.

  • Some of these assurances are well recognized certification schemes like the EU – US Privacy Shield for the protection of Personal Data transferred from within the EU to the United States.

  • Where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any Personal Data is disclosed.

  1. YOUR RIGHTS

The following rights (which may be subject to certain exemptions or derogations) shall apply to certain individuals (some of which only apply to individuals protected by the GDPR and/or other data protection laws):

  • You have a right to access information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  • You have the right to request that we rectify any Personal Data we hold that it is inaccurate or misleading;
  • You have the right to request the erasure of the Personal Data that relates to you. Please note that there may be circumstances in which we are required to retain your data, for example for the establishment, exercise or defense of legal claims;
  • The right to object, to or to request restriction, of the processing.
  • The right to data portability. This means that you may have the right to receive your Personal Data in a structured, commonly used and machine-readable format, and that you have the right to transmit that data to another controller;
  • You have the right to object to profiling / automated decision making;
  • The right to stop direct marketing;
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority;
  • The right to withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your data, in particular if the processing is required to meet our legal and regulatory obligations. Also, please note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
  • You also have a right to request details of the basis on which your Personal Data is transferred outside the European Economic Area, but you acknowledge that data transfer agreements may need to be partially redacted for reasons of commercial confidentiality.
  • You have a right to lodge a complaint with your local data protection supervisory authority (i.e., your place of habitual residence, place or work or place of alleged infringement) at any time or before the relevant institutions in your place of residence. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution.

You can exercise your rights by contacting us at info@novasec.io. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm your identity and for security purposes, before disclosing the Personal Data requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

  1. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any personal data to us without involvement of a parent or a guardian. For the purposes of the GDPR, we do not intend to offer information society services directly to children. In the event that we become aware that you provide personal data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at info@novasec.io.

  1. LINKS TO AND INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with or contain links to your Third Party Account and other third party websites, mobile software applications and services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policy of each Third Party Service that you choose to use or interact with.

  1. LOG FILES

We make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us. We use such information to analyze trends, administer the Website, track users' movement around the Website, and gather demographic information.

  1. ANALYTIC TOOLS
  • Google Analytics. The Website uses a tool called " Google Analytics" to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at http://www.google.com/analytics/terms/us.html/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.
  1. CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Data to third parties for their direct marketing purposes. To make such a request, please send an email to info@novasec.io. Please note that we are only required to respond to one request per customer each year.

  1. OUR CALIFORNIA DO NOT TRACK NOTICE

We do not track consumers over time and across third party websites and therefore do not respond to Do Not Track signals. We do not allow third parties to collect personally identifiable information about an individual consumer's online activities over time and across different web sites when a consumer uses the Site

  1. DELETION OF CONTENT FROM CALIFORNIA RESIDENTS

If you are a California resident under the age of 18 and a registered user, California Business and Professions Code Section 22581 permits you to remove content or Personal Data you have publicly posted. To remove, please send an email to info@novasec.io. Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Data you have posted and that there may be circumstances in which the law does not require us to enable removal of content.

  1. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at info@novasec.io.