NOVARA PRIVACY PRINCIPLES
Novara, LLC. takes your privacy seriously. The following principles guide our treatment of your personal information:
- We value the trust you place in Novara when sharing your personal information with us.
- We strive to be transparent with you about what personal information we collect, what we do with it and with whom we share it.
- We endeavor to work with you to address your concerns about how we use your personal information.
- We strive to take steps designed to secure your personal information and reduce the risk it will be misused.
This Privacy Notice (“Notice”) describes how Novara (“Novara,” “we,” “us”, or “our”) collect, use, share and otherwise process personal information in connection with our websites, applications, and other online platforms which link to or display this Policy (the “Platform”). This Notice is not, however, a contract and does not create any legal rights or obligations.
When we use the term “personal information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you. It does not include aggregated, de-identified or anonymized information that is maintained in a form that is not reasonably capable of being associated with or linked to you.
Types of Personal Information We Collect
- Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
- Payment Information. For example, we may collect your credit card number and billing address.
- Shopping History. For example, we may collect personal information about the items you viewed, added to your cart, purchased or returned.
- Information You Post. We may collect personal information you post in a public space on our Platform, such as on our Ratings & Reviews feature.
- Social Media Information. We may collect personal information you post on our social media pages. We may also collect your social media profile information and personal information posted on your page.
- Employment Information. If you apply for a job through our Platform, we collect the personal information you include in your application. For example, this may include the name and address of your employer and your employment history.
- Information You Submit. We may collect personal information when you send us a message through the “Contact Us” page or similar features on our Platform. We may also collect personal information when you enter a promotion. This may include photos, videos and other user-generated content that you submit.
- Demographic Information. We may collect your birthdate, age, gender and zip code. We may also collect personal information relating to your hobbies, interests and shopping behavior.
- Device Information. We may collect the type of device you use to access our Platform. For example, we may also collect your device identifier, IP address or mobile operating system.
- Location Information. We may collect precise location information from your device. This may include information about your exact location when you use our Platform or may include information that allows us to approximate your location. We may also collect this information in the background when our mobile applications are not in use. For more information about your options related to the collection of your location information, see the “Choices Regarding Your Information” section below.
- Log and Analytics Data. If you use our website, we may collect information about the browser you are using. We may look at what site you came from, or what site you visit when you leave us. If you use our app, we may look at how often you use the app and where you downloaded it.
How We Collect Your Personal Information
We collect your personal information in the following ways:
- Directly From You. For example, when you:
- Register for an account.
- Purchase products or services through our Platform.
- Sign up to receive promotional communications.
- Request a sample.
- Join a loyalty, rewards or similar program or club.
- Participate in one of our promotional sweepstakes, contests, surveys, or focus groups.
- Use the Ratings & Reviews or related services and features.
- Submit a request to our Consumer Service team.
- Interact with Novara social media pages.
- Apply for a job through our Platform.
- Automatically. For example, when you:
- Visit and navigate our Platform on any device.
- Enable location-based features on our Platform.
- Click on sponsored links or third-party advertisements.
We may also collect personal information about you over time and across different websites, apps and devices when you use our Platform, using tracking technologies such as cookies, pixels, Flash objects, APIs and mobile software development kits (SDKs) and we may use third party services to collect this personal information when you use our Platform.
- From Third Parties. We may receive personal information about you from other sources. For example, this may include receiving personal information from:
- Our business partners, including online advertising networks, analytics vendors, and companies that co-sponsor our promotions.
- Social media sites, including Facebook, Twitter, YouTube, Pinterest, Snapchat and Instagram. The information we receive from these social media sites is dependent upon the social media site’s policies and your settings on that site.
- Third party sites, including those that allow you to integrate your third-party account with your Novara account.
- Family, friends and others who provide your personal information to us because they think you may be interested in our products and services or they want to share a product or service with you.
- Companies that provide personal information to supplement what we already know about you, including data aggregators. Certain third parties might link your name or email address to other information they have collected. That might include past purchases made offline or online. It might also include online usage information.
- By Combining Personal Information. For example, we may:
- Combine personal information that we collect offline with personal information we collect through our Platform.
- Combine personal information we collect about you from the different devices you use to access our Platform.
- Combine personal information we get from third parties with personal information we already have about you.
How We Use Your Personal Information
We may use your personal information in the following ways:
To Provide Our Products and Services. This could include fulfilling your requests for products or services. It could also include processing purchases or other transactions.
- To Improve Our Products and Services. We may use your personal information to make our Platform, products and services better. We may also use your personal information to customize your experience with us.
- To Understand Your Interests. For example, we may use your personal information to better understand what products interest you.
- To Respond to Your Requests or Questions. This may include responding to your feedback or notifying you if you win a promotion.
- To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Notice or our Platform terms and conditions.
- To Determine Your Eligibility. We may use your personal information to verify your identity or determine your eligibility for some of our products, services and promotions. For example, this may include verifying your age, date of birth and state of residence. If you apply for a job through our Platform, we may use the personal information you provide to evaluate your application.
- For Marketing Purposes. We may provide you with information about new products and special offers. We might use your personal information to serve you ads about products and offers. We might tell you about new features or updates. These might be third-party offers or products we think you might find interesting. We may also use your personal information to send you electronic communications, including through email or text message.
- For Interest-Based Advertising. We and our third-party partners may engage in interest-based advertising using personal information gathered across multiple websites, devices, or other platforms to serve you relevant advertising on our Platform or on other sites, services and mobile applications or on other devices you may use. For more information about your choices related to these communications, see the “Online Advertising and Third-Party Tracking” section below.
- For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Platform.
- To Send Push Notifications. If you use our mobile apps, we may send you push notifications about new products or special offers.
- As Otherwise Permitted By Law or As We May Notify You.
How We Share Your Personal Information
We may share your personal information in the following ways:
- Internally. We may share your personal information within the Jessamy Group of companies and brands.
- On Our Platform. For example, we may display personal information you post on our Ratings & Reviews feature. We may also display personal information you submit in connection with a promotion.
- With Our Service Providers. We may share your personal information with third parties who perform services on our behalf. For example, this may include merchandise vendors and payment processors. It may also include companies that send emails on our behalf or help us run our Platform.
- With Our Business Partners. For example, this may include a third party that co-sponsors a contest or promotion. We may also share personal information with data aggregators, advertisers, media buying agencies, advertising networks and advertising service providers.
- With Third Parties for Marketing Purposes. This may include our affiliate companies or brands or third parties whose products or services we believe you may be interested. These third parties may also share your personal information with others. These third parties may use your personal information for their own marketing purposes or the marketing purposes of others. This may include the delivery of interest-based advertising.
- For Business Transactions or Reorganizations. We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of all or a portion of our company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy, or receivership.
- To Comply With the Law or To Protect Ourselves or Third Parties. For example, this could include responding to a court order or subpoena. It could also include sharing personal information if a government agency or investigatory body requests. We might share personal information when we are investigating potential fraud. This could include fraud we think has occurred during a sweepstakes or promotion. We may also share information if you are the winner of a sweepstakes or other contest with anyone who requests a winner’s list.
- For Other Reasons We May Describe to You.
Children Under 13
Our Platform is intended for adults. We do not knowingly collect or solicit any information from anyone under the age of 13 though our Platform. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have collected personal information from a child under 13, please contact us at email@example.com.
Choices Regarding Your Personal Information
You can opt out of receiving our marketing communications. Note that you will still receive non-marketing or transactional messages from us, including messages about your account and responses to your inquiries. To opt out of receiving our marketing communications, you can contact us as follows:
- Send us an email at firstname.lastname@example.org
- Call us at 1-800-266-9092 (Monday through Friday, 9:00 AM – 5:00 PM Eastern).
- Send us a letter at:
175 Capital Blvd., Floor 4
Rocky Hill, CT 06067
- For promotional emails or text messages, follow the instructions included with the marketing communication.
MOBILE APPLICATION AND LOCATION BASED SERVICES:
- You may control our collection and use of location-based information through our mobile applications by adjusting the settings on your mobile device. If you withdraw permission for mobile applications to access precise location data, we may continue to approximate your location based on information like your IP address.
- You may completely opt out of all location-based information collection by us if you uninstall all of our mobile apps from your devices.
Online Advertising and Third-Party Tracking
COOKIES & OTHER TRACKING TECHNOLOGIES:
- We use this information collected through tracking technologies to provide custom, personalized content and information, including targeted content and advertising, recognize you across multiple devices, monitor aggregate usage metrics such as total number of visitors, traffic, usage, and demographic patterns of our visitors, and otherwise enhance our Platform and your user experience.
- If you block cookies, certain features on our Platform may not work. Depending on your mobile device and operating system, you may not be able to delete or block all cookies and you may not be able to block non-cookie technologies (such as flash cookies) and these browser settings that block cookies may have no effect on such techniques. In addition, options you select relating to cookies and other tracking technologies are browser and device specific. You must exercise these choices on each browser and device you use.
We engage in interest-based advertising to deliver online advertising that may be more relevant to your interests. We permit third party online advertising networks, social media companies, and other third-party services to collect information about your use of our websites and Platform over time so that they may play or display ads on our Platform, on other websites, apps, or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third-party advertising partners to help identify you across devices or serve you ads on social media sites you may use. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research.
- To learn more about interest-based advertising and how you may be able to control the use of your personal information for interest-based advertising purposes, please visit our Ad Choices policy here.
- Please note, however, that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, the options you select relating to interest-based advertising are browser and device specific. If you use a different device, change browsers, or delete the opt-out cookies, you may need to perform the opt-out task again.
- You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt out of interest-based ads” (Android). You may also be able to opt-out of some—but not all—interest-based ads served by mobile ad networks
GOOGLE ANALYTICS AND ADVERTISING:
We use Google Analytics to better understand how our users interact with our Platform. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google’s site “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here.
We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.
OUR DO NOT TRACK POLICY:
- Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals. If you block or reject cookies, not all of the tracking described here will stop.
- Options you select are browser and device specific.
We may choose or be required by law to provide different or additional disclosures relating to the processing of personal information about residents of certain states. Please refer below for disclosures that may be applicable to you:
- California. If you are a California resident, please click here for additional California-specific privacy disclosures.
- Nevada. Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt out of future sales of certain covered information that a website operator has collected or will collect about the resident. To submit such a request, please contact us at email@example.com with the subject line “Nevada opt-out”.
The Internet is not 100% secure. Like all businesses, we cannot guarantee the security of the personal information you provide to us via the Platform. We have, however, taken certain steps designed to reduce the risk that the personal information you provide us will be subject to loss, misuse, unauthorized access, disclosure, alteration or destruction. We encourage you to use caution when using the Internet. A user id and a password are needed to access certain areas of the Platform. It is your responsibility to protect your username and password.
Storage of Information
Personal Information we maintain may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States. This Platform is intended for use in the United States and is subject to the laws of the United States, which may not provide the same level of protections as those in your own country.
Links to Third-Party Services
Our Platform may contain links to other third-party sites, plug-ins, applications or other online services. If you click on a link to a third-party site or other online service, you will be taken to a site or other online service we do not control and that is not governed by this Notice. We are not responsible for the privacy practices used by third-party sites and other online services. We suggest that you read the privacy policies of those sites and other online services carefully.
How to Contact Us
If you have any questions, comments or concerns with respect to our privacy practices or this Policy, or wish to update your information, please feel free to contact us at firstname.lastname@example.org or by telephone at 1-800-266-9092 (Monday through Friday, 9:00 AM—5:00 PM Eastern). You may also write to us at the following address:
175 Capital Blvd., Floor 4
Rocky Hill, CT 06067
Re: Novara Privacy Notice
CHANGES IN POLICY
From time to time, we may change our Notice. We will notify you of any material changes to our Notice as required by law. We will also post an updated copy of this Notice on our Platform. Please check our Platform periodically for updates.
California Privacy Notice
Effective Date: January 1, 2020
Unless otherwise defined in this California Privacy Notice (“Notice”), all terms defined in the Privacy Notice and all other terms defined in the California Consumer Privacy Act of 2018 (“CCPA”) retain the same meaning when used in this Notice.
This Notice supplements the information contained in our Privacy Notice and applies solely to individual residents of the State of California (“consumers” or “you”).
This Notice describes how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the CCPA.
Personal Information Disclosure
When we use the term “personal information” in this Notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.
For the purposes of this Notice, personal information does not include:
- De-identified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.
- Publicly available information from government records.
- Information about job applicants, employees and other of our personnel.
- Information about employees and other representatives of third-party entities we may interact with.
Collection, Disclosure and Sale of Personal Information
In the last 12 months, we have collected, disclosed for a business purpose and sold the following categories of personal information:
|Category of Personal Information||Collected||Disclosed for business purpose||Sold|
|Identifiers, such as name, email address and IP address.||Y||Y|
|California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate, Contact Information, and Payment Information.||Y||Y|
|Protected Classification Characteristics, such as age and gender.|
|Commercial Information, such as Shopping History and other information relating to your hobbies, interests and shopping behavior.||Y||Y|
|Internet/Network Information, such >as Device Information, and Log and Analytics Data.||Y||Y|
|Geolocation Data, such as precise Location Information from your device||Y||Y|
|Profession/Employment Information, such as Employment Information;|
|Non-Public Education Information (20 U.S.C. § 1232g, 34 C.F.R. Part 99)|
|Other Personal Information, such as information you post on our platform or on social media pages, information you submit to us,|
|Inferences, such as predictions about your interests and preferences.||Y||Y|
In addition, we permit third parties to collect certain personal information directly from you when you visit or interact with our Platform. Please see the section entitled “Online Advertising and Third-Party Tracking” in our Privacy Notice and visit our Ad Choices policy to learn how you may exercise your choice over this third-party data collection for advertising purposes.
SOURCES OF PERSONAL INFORMATION
As described in the “How We Collect Your Personal Information” section of the Privacy Notice, we collect personal information directly from you when you provide it to us, automatically using cookies and other tracking technologies, from the categories of third parties listed in that section and by combining personal information we may otherwise obtain.
PURPOSES FOR COLLECTING PERSONAL INFORMATION
We collect, use, sell or disclose personal information about you for the purposes described in the “How We Use Your Personal Information” section of the Privacy Notice.
Recipients of Personal Information As described in the “How We Share Your Personal Information” section of the Privacy Notice, we share personal information internally and with a variety of third parties.
For a list of the categories of personal information that we have disclosed to third parties for a business purpose or that we have sold to third parties during the previous 12 months, please refer to the chart above.
Your California Privacy Rights
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
|Right to Knowledge|
The right to request the following information relating to the personal information we have collected about you and disclosed in the last 12 months:
|Right to Access||The right to access and obtain a copy of the personal information we have collected about you in the last 12 months.|
|Right to Request Deletion||The right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions.|
|Right to Opt Out of Data Sales||The right to direct us not to sell personal information we have collected about you to third parties.|
|Right to Opt In to Data Sales||If you are under the age of 16: The right to authorize us, or have your parent or guardian authorize us, to sell personal information about you.|
|California’s “Shine the Light” Law||California’s “Shine the Light” law (Civil Code § 1798.83) also permits California residents that have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures.|
How to Exercise Your California Privacy Rights
To Exercise Your Rights to Knowledge, Access, Deletion and/or “Shine the Light”
Please submit a request by:
- Emailing email@example.com with the subject line “California Rights Request”;
- Filling out our California Resident Rights Request Form; or
- Calling 1-877-322-8633 (Monday through Friday, 9:00 AM–5:00 PM Pacific)
We will need to verify your identity before processing most requests, which may require us to obtain additional personal information from you. Please provide your name, email address and mailing address in the original request, as well as an explanation of the rights you wish to exercise. We will only use the personal information provided in connection with a California Consumer Rights Request to review and comply with the request. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.
If you wish to submit a verifiable consumer request on behalf of another individual, such as a minor child, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf.
In certain circumstances, we may decline a request to exercise the rights described above.
To Exercise Your Right to Opt Out of Personal Information Sales
Please submit a request by clicking here.
You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales. However, we may ask you to provide additional personal information (including your name, email address and mailing address) so that we can properly identify you in our dataset to facilitate the opt-out request. If you chose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at firstname.lastname@example.org.
To Exercise Your Right to Opt In to Personal Information Sales
We do not sell personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from the child who is between 13 and 16 years of age, or the parent or guardian of a child less than 13 years of age. The parent or the child who has opted into personal information sales may opt out of future sales at any time. Please contact us at email@example.com to inform us if you, or your minor child, are under the age of 16 and to exercise your rights to opt in or opt out of data sales.
We current offer the following financial incentives:
From time to time, we may offer you certain financial incentives permitted by law (such as coupons, samples, and sweepstakes or contest rewards) in exchange for the collection, retention, or sale of certain personal information about you, including Identifiers (such as your full name and email address), California Customer Records (such as your birthdate and contact information) and Commercial Information (such as information specific to your experiences with Unilever brands). When necessary, we will provide information about the specific terms of the financial incentive, such as the type of personal information required to be disclosed, retained or sold in exchange for the benefit you may receive, and instructions on how to opt in or opt out, on the webpage or form where the financial incentive is made available.
How to Contact Us
If you have any questions, comments or concerns with respect to our privacy practices or this Notice, or wish to update your information, please feel free to contact us at firstname.lastname@example.org or by telephone at 1-800-266-9092 (Monday through Friday, 9:00 AM–5:00 PM Eastern). You may also write to us at the following address:
175 Capital Blvd., Floor 4
Rocky Hill, CT 06067
Re: Novara Privacy Notice
Changes In Notice
From time to time, we may change our Notice. We will notify you of any material changes to our Notice as required by law. We will also post an updated copy of this Notice on our Platform. Please check our Platform periodically for update.`