Privacy Policy

This Privacy Policy was most recently updated on 31.03.2022  (v.2022.1) 

Novable SRL (“we”, “us” or “Novable”) is committed to protecting and respecting your privacy. This Privacy Policy describes our collection, use, disclosure, retention, and protection of your personal information.

 This Privacy Policy applies to our customers, end users, prospects, partners, suppliers, job applicants (“you” or “your”). It was drawn up in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”).

Please read the following Privacy Policy carefully to understand our views and practices regarding your personal information and how we will use it. By visiting www.novable.com (“Website”), or by using our services (“Platform”) you accept and agree to the practices described in this Privacy Policy.

This Privacy Policy is part of our Platform Terms of Use (accessible via our clients’ Platforms) and our Terms and Conditions (https://novable.com/terms-and-conditions/)and applies to you when you access our Platform regardless of the location from which you access it. If you elect to not provide the information we require, we may not be able to provide all of our services to you.

If you do not agree to the terms of this Privacy Policy, please do not use our Website or Platform.

 The controller (as defined in Section 2) under this Privacy Policy is Novable SRL, a private company (“Société à Responsabilité Limitée”) organized under the laws of Belgium, having its registered office at Chaussée de la Hulpe 150, 1170 Brussels (Belgium), registered with the Register of Legal Entities under number BE0702877935. 

If you have any questions or requests concerning this Privacy Policy or how we handle your data more generally, please get in touch with us using the following details:

• By letter to: Privacy Team, Novable SRL, Chaussée de la Hulpe 150, 1170 Brussels (Belgium);
• By contacting our Privacy Team at: [email protected].

The following terms used in this Privacy Policy will have the meaning given to those terms in the GDPR as stated below:

• “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; and defined in Section 1 of this Privacy Policy;
• “Personal data” (“personal information”, “information”) means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
• “Platform” has the meaning given to it in Article 1 of the Terms;
• “Processing” (“process”, “processes” and “processed” will be interpreted accordingly) means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
• “Processor” means a natural or legal person, public authority, agency, or other body that processes personal data on behalf of the controller;

We will collect and process your personal information in a variety of ways, depending upon your use of the Website or our Platform. More details about how your information is collected are listed below.

Personal information when you set up an account  on our Platform

When you create an account on our Platform, we ask you to provide information about yourself including:

• Your contact and identification information (e.g. title, role, name, address, e-mail address, phone number);
• Information in connection with registrations on our Platform (e.g. account log-in information);

 Personal information we automatically collect about you when you visit our Platform

Like many websites, we automatically receive and store certain types of personal information whenever you interact with us or our Platform such as:

• technical information, including the Internet Protocol (IP) address used to connect your computer to the internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• your device ID;
• information about your visit, including the full URL, clickstream to, through and from our Platform (including date and time), pages and/or keywords you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number; 

Personal information about your interaction with our Website

This is the personal information that you give us by filling in forms on our Website or by corresponding with us by phone, email, or otherwise. It also includes personal information you provide to us when you register for a webinar, subscribe to our email newsletter, etc. such as:

• Your contact and identification data (e.g. title, name, address, date of birth, e-mail address);
• Personal information in connection with a job application submitted by you;
• Personal information was given by you in connection with registrations on our Website;
• Your work-related personal information (e.g. role, employment history);
• Your business contact information (e.g. company, email, physical address, phone number); 

Personal information we do not collect

Novable SRL does not seek to collect personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

Personal information we receive from other sources

 This is the information we receive about you if you use any other website/application than ours that advertises or uses our services. We are working closely with third parties (including, amongst others, business partners, sub-contractors in technical services, advertising networks, analytics providers, search information providers) and we will collect and process the information we receive from them.

Our Website and our Platform use cookies. This helps us to provide you with a good experience when you browse our Website and Platform and also allows us to improve them. For detailed information on the cookies we use and the purposes for which we use them, see our Website Cookie Policy (https://novable.com/cookies-policy/)

Personal information may only be collected and processed for specified and lawful purposes and may not be processed in a manner incompatible with those purposes.

We use the personal information we hold about you in the following ways:

 For our customers or end-users of our Platform

•  to ensure that the content from our Platform is presented in the most effective manner for you and for your computer/device;
•  to notify you about changes to our services or Platform;
• to provide you with information about other services we offer that are similar to those that you have already used or enquired about;
• to provide you with information about services we feel may interest you;
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
• to administer our Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our Platform to ensure that content is presented in the most effective manner for you and for your computer/device;
• to allow you to participate in interactive features of our service when you choose to do so;
• as part of our efforts to keep our Platform safe and secure;
• to administer, track and fulfill orders for our services;
• to manage our Service Agreement with you (including, without limitation, invoicing our services) and resolve any disputes relating to our Service Agreement;
• to respond to general queries relating to our services or the Service Agreement;
• to run customer and product communications and events;
• to comply with applicable laws if applicable.

 For our prospects, partners, suppliers, and job applicants

• to ensure that the content from our Website is presented in the most effective manner for you and for your computer/device;
• to provide you with information about other services we offer that are similar to those that you have already used or enquired about;
• to review and assess your job application;
• to invite you to our webinars, conferences, or other events we organize;
• to provide you with information about services we feel may interest you;
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information and services that you request from us;
• to improve our Website to ensure that content is presented in the most effective manner for you and for your computer/device;
• as part of our efforts to keep our Website safe and secure;
• to send you newsletters or other related materials;
• to perform statistical, demographic, and marketing analyses of our customers and end-users and their viewing patterns;
• to measure or understand the effectiveness of advertising we deliver to you and others, and to deliver relevant advertising to you.

 To protect Novable

• for the exercise or defense of legal claims and to exercise and protect the rights of Novable, including determining our liability;
• to enforce the terms of your  Agreement (as defined in article 1 of the Terms and Conditions – (https://novable.com/terms-and-conditions/)
• and keep records of such enforcement, including using your data to analyze whether you have breached your Agreement (such as by misusing the Platform or acting fraudulently), which may result in us disabling or terminating your Agreement if we have the right to do so.

Personal information we receive from other sources

We may combine this information with the information you give to us and the information we collect about you. We may use this information and the combined information to measure or understand the effectiveness of advertising we deliver to you and others, and to deliver relevant advertising to you.

Your personal information is being collected and processed on the following legal bases:

As a customer or end-user of our Platform

1)    As necessary for our legitimate interests in providing the services and the Platform, considering these interests are not overridden by your fundamental rights and freedoms, e.g. we use your personal information to learn about your preferences to be able to better personalize our product offerings, to prevent fraud, to secure our Website, etc.;

2)  As necessary to perform a contract we have with you, e.g. the Service Agreement we signed to provide you with our Platform;

3)    With your consent;

4) As necessary for compliance with a legal obligation to which we are subject. 

As a prospect, partner, supplier, or job applicants

1) As necessary for pursuing our legitimate interests, considering these interests are not overridden by your fundamental rights and freedoms, e.g. we use your personal information to know your preferences so as to be able to better personalize our product offerings, to prevent fraud and to secure our website;

2)  As necessary for the performance of a contract we have with you or in order to take steps at your request prior to entering into a contract;

3)  With your consent, e.g. if you have given your prior express consent thereto we may use your email address for sending you marketing materials;

4) As necessary for compliance with a legal obligation to which we are subject.

We are very careful and transparent about who else your information is shared with. You agree that we have the right to share your personal information with selected third parties including:

• our business partners;
• public authorities (including judicial and police authorities);
• our suppliers of IT related services;
• our suppliers of marketing related services;
• analytics and search engine providers that assist us in the improvement and optimization of our Website.

 Inapplicable circumstances, we will also disclose your personal information:

• if our business enters into a joint venture with, purchases, or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners, or their advisors;
• if Novable SRL or substantially all of its assets are acquired by a third party, in which case information held by it about its customers may be one of the transferred assets;
• if we are under a duty to disclose or share your personal information in order to comply (and/or where we believe we are under a duty to comply with) with any legal obligation or to protect the rights, property, or safety of Novable SRL, our customers, or others. This includes exchanging information with public authorities (including judicial and police authorities) in the event of, for example, a cybersecurity incident;
• in order to enforce our contractual terms with you;
• if that is appropriate to achieve any of the purposes set out in section 5 of this Privacy Policy.

We may transfer your personal information to a destination outside the European Economic Area (the EEA), including to the United States if that is appropriate (i) to achieve any of the purposes set out under section 5 and/or (ii) to disclose your personal information to a third party in accordance with section 7 of this Privacy Policy.

 If we transfer your personal information outside of the EEA, we will make sure that your personal information is protected by the following safeguards:

• the laws of the country to which your personal information is transferred ensure an adequate level of data protection (Article 45 GDPR); or
• the transfer is subject to data protection clauses approved by the European Commission (Article 46.2 GDPR).

If you wish to receive more information relating to the transfers of your personal information and/or the safeguards that have been implemented (including how to receive a copy thereof), you can contact us through the contact details set out in section 1 above.

Under data protection law, you may have a number of rights regarding the personal information we hold about you:

–       The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we are providing you with the information in this Privacy Policy; 

–    The right of access. You have the right to access the personal information we keep about you – this is because we want you to be aware of the personal information we have about you and to enable you to verify whether we process your personal information in accordance with the applicable data protection laws and regulations;

–       The right to restrict processing. You have the right, under certain circumstances, to “block” or suppress further use of your personal information. When the processing is restricted, we can still store your personal information, but we can no longer use it;

–       The right to rectification. If your personal information is inaccurate or incomplete, you have the right to request the rectification of your personal information;

–       The right to erasure. You have the right, under certain circumstances, to request the deletion or removal of your personal information from our systems;

–       The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your personal information with your national data protection authority (contact details for data protection authorities are available here);

–       The right to withdraw consent. If our processing of your personal information is based specifically on your consent, you have the right to withdraw that consent at any time. This includes the right to withdraw your consent to receive newsletters and promotional emails and other marketing communications from us by: (1) selecting the “unsubscribe” feature where available, or (2) contacting us;

–       The right to data portability. You have the right to obtain from us, under certain circumstances, your personal information in a structured, commonly used and machine-readable format so you can reuse it for your own purposes across different services. For example: if you want to work with a different service provider, this enables you to move your personal information easily and in a secure manner to this new service provider.

–       The right to object to processing. You have the right to raise an objection to certain types of processing, including processing for direct marketing and profiling. You can object by contacting us on the details above.

However, note that we may need to retain certain information, for example for legal or administrative purposes (e.g. keeping of accounting records).

For all requests set out above, please send us an email with “data privacy request” in the subject line and include a copy of your identity card or another proof of your identity (e.g. driver’s license) to help us prevent unauthorized individuals from accessing, changing or deleting your personal information. We will respond to your request as soon as practically possible. If we need more than one month (from receipt of your request) to respond to your request, we will come back to you and let you know.

We have implemented a number of security features throughout our Website and our Platform in order to prevent the unauthorized release of or access to collected and/or received information. We have endeavored to create a secure and reliable Website and Platform for you but note that the confidentiality of any communication or material transmitted to or from us or any other party via our Website and our Platform or email cannot be guaranteed. We accept no responsibility or liability for the security of information transmitted via these methods.

All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website or Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

The information we hold about you will be retained in a manner consistent with the applicable data protection legislation. In any event, your personal information shall not be kept longer than is necessary to achieve the purposes outlined in section 5 above.

When determining the relevant retention periods, we will take into account factors including:

• our contractual obligations and rights in relation to the information involved;
• our legal obligation(s) under applicable law to retain data for a certain period of time; the retention may be necessary for us to comply with any legal or regulatory obligation (e.g. for tax purposes), in which case we will keep your personal information for as long as required by that obligation;
• statute of limitations under applicable law(s);
• the processing of your personal information is necessary in connection with any actual or potential dispute (e.g. we need this information to establish or defend legal claims), in which case we will keep your personal information until the end of such dispute; and
• guidelines issued by relevant data protection authorities.

Our Website and our Platform may, from time to time, contain links to and from websites and/or applications of our partner networks, advertisers, and affiliates. To the extent that hyperlinks or banner advertisements incorporating hyperlinks are utilized to access third-party websites and/or applications, you should be aware that these third-party websites and/or applications are not controlled by us and have their own privacy policies. Therefore, they are not subject to this Privacy Policy and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites and/or applications.

By visiting our Website or using our Platform you acknowledge that you have read the terms of this Privacy Policy and that you agree with the collection and the use of your personal information as set out above.

We may amend this Privacy Policy from time to time. Any changes we make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to the Privacy Policy. Your continued use of this Website and our Platform following the posting of changes to this Privacy Policy will indicate your acceptance of these changes.

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