Privacy Policy
This is a communication issued by Nova Capital Management Limited (“Nova”). This website (the “Site”) refers to Nova Capital Management Limited and to the website www.nova-cap.com only. Terms defined in the Term and Conditions governing use of this Site are adopted in this Statement (defined below). For Data Protection purposes, Nova is the Controller and responsible for your personal data. Personal Data means any information about an individual from which that person can be identified. If you have any questions about this Privacy Policy please contact us using the information set out below.
This Privacy Policy Statement (the “Statement”) only covers this Site and shall be governed by and construed in accordance with the law of England and Wales.
Nova is committed to protecting the security of your personal information in accordance with the General Data Protection Regulation ((EU) 2016/679) (“UK GDPR”) and the Data Protection Act 2018 (“DPA 2018”).
Nova recognises that in using the Contact Form of this Site you may be required to entrust important personal information to us, and we wish to assure you that we take seriously our responsibilities in protecting and safeguarding this information We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
This Statement may be updated at any time.
We will retain, where applicable, your personal information in accordance with the relevant data protection laws for so long as it is needed. We will review not less than annually whether or not personal information held by us is still needed and, if not, we will permanently delete it. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By using this Site you agree and consent to the processing, disclosure and transfer (and international transfer, where applicable, including outside the EEA (as defined below)) of your personal data by Nova for the purposes set out in this Statement.
Please read the Terms and Conditions of Website Use and Cookie Policy (“Terms and Conditions”) together with this Statement carefully before using this Site. These Terms and Conditions set forth the legally binding terms and conditions that govern your access to and use of this Site. If you wish to access or browse the remainder of this Site, then you are reminded that by doing so you will bring into existence a binding legal agreement accepting the Terms and Conditions and this Statement on your own behalf and where applicable, on behalf of any client or investor that you represent, act as agent for and or are associated with.
Information We May Collect
We may collect information about you when you use this Site or when you contact Nova or enter into commercial or other relations with Nova. In particular, we may collect and process information you give us by filling in forms on our Site (if any) or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, address, e-mail address, phone number, personal description and financial information (such as to establish your status as a person or entity at whom this Site is targeted); usage data relating to this Site; marketing and communications data and preferences, etc.). We may also automatically collect technical information, including your IP address, and information about your visit to the Site, such as pages you viewed or searched for, page interaction information and any phone number or email address used to contact us. We may also collect, use and share aggregated data which does not reveal your identity, for instance to analyse use of this Site, how we interact with users and to help improve this Site and its functionality.
We are legally required to have a legal basis for collecting and using your personal data and the following are among the legal bases we rely on: To identify you; We may use your personal data where it is necessary for compliance with a legal obligation that we are subject to (we will identify the relevant legal obligation when we rely on this legal basis); where we have obtained your active agreement to use your personal data for a specified purpose, for example if you subscribe to an email newsletter; and for legitimate interests, which means we may use your personal data where it is necessary to conduct our business and pursue our legitimate interests, for example to prevent fraud and enable us to give you the best and most secure customer experience. We will make sure we consider and balance any potential impact on you and your rights (both positive and negative) before we process your personal data for our legitimate interests. We will not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
In the absence of your prior consent we will not send you direct marketing communications, or share your personal information with any third party for marketing purposes, or if you have withdrawn you consent.
The Nova website may offer the opportunity to “connect” website content via the social network LinkedIn. Social networks such as this almost always use cookies. If you are a member of LinkedIn and do not want the social network cookies to be placed on your system, we suggest that you refrain from using such sharing tools. LinkedIn: https://www.linkedin.com/legal/pop/pop-privacy-policy
Cookies
When visiting the Nova website, Google Analytics collects standard internet log information which details of visitor behaviour patterns. This is done to find out things such as the number of visitors to the various parts of the website and the information is only processed in a way which does not identify anyone. Google cannot attempt to find out the identities of those visiting our website. For more information on Google Cookies and opt out of being tracked, visit http://tools.google.com/dlpage/gaoptout.
Security of Data Transfers
Please note that data that is transported over an open network, such as the Internet or e-mail, may be accessible to anybody. Nova cannot guarantee the confidentiality of any communication or material transmitted via such open networks. When disclosing any personal information via an open network, you should remain mindful of the fact that it is potentially accessible to others, and consequently, can be collected and used by others without your consent. Your data may be lost during transmission or may be accessed by unauthorised parties. Nova does not accept any liability for direct or indirect losses as regards the security of your data during its transfer via Internet. Please use other means of communication if you think this is necessary or prudent for security reasons.
Transferring data outside of the EEA
Your personal information may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“) and may also be processed by staff operating outside the EEA who work for us, or for one of our service providers.
When we, or our permitted third parties, transfer your information outside the European Economic Area, we or they will impose contractual obligations on the recipients of that data to protect your information to the standard required in the European Economic Area. We or they may also require the recipient to subscribe to international frameworks intended to enable secure data sharing. In the case of transfers by us, we may also transfer your information where: (i) the transfer is to a country deemed by the European Commission to provide adequate protection of your information; or (ii) where you have consented to the transfer.
Protection, Processing and Use of Personal Data
We maintain physical, electronic and procedural safeguards, including (where appropriate and applicable) firewalls, individual passwords and encryption and authentication technology for any personal information that we might collect through the Site. We may share your personal information with any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006. This could result in your personal data being transferred to a group office in the USA. We use specific standard contractual terms approved for use in the UK which give the transferred personal data the same protection as it has in the UK, namely the International Data Transfer Agreement. To obtain a copy of these contractual safeguards, please contact us.
We do not use your personal information collected through the Site for purposes other than as set out above, or disclose to any third party any such personal information, except with prior consent or as otherwise permitted or required by law.
We have in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
You have the legal right to access personal information held about you and how we process it. You have the right to request corrections of that data, erasure of that data in certain circumstances or you may (among other rights) be able to object to the processing of your personal data where we are relying on a legitimate interest as the legal basis for doing so. Your legal rights of access can be exercised in accordance with the UK GDPR and DPA 2018. A first access request will be free, further requests may be subject to a fee to meet our costs in providing you with details of the information we hold about you. That fee will depend on the nature, scope and frequency of access requests made by a person.
Contacting Us
Please do not hesitate to contact us regarding any matter relating to this Privacy Policy at info@nova-cap.com.
