NOVA’s commitment to our clients

NOVA is a smart home solutions company located in San Antonio, TX and Los Angeles, California (pending) offering home technology options.  Our management and staff are aware of the importance of protecting the privacy of individuals.  We are committed to ensuring the privacy of the personal information we collect in the course of our business.  We believe that respect for your privacy forms part of the ongoing trust we wish to develop with you.

We are bound by the Privacy Act which set out the way in which organizations can collect, use, keep secure and disclose personal and sensitive information.  They also give individuals the right to know what information an organization holds about them and the right to correct that information if it is wrong.

The purpose of this privacy policy is to tell you what kinds of information we may gather or hold about you, how we may use that information, whether we disclose it to anyone, the choices you have regarding our use of that information, and your ability to access or correct that information.

Personal Information

‘Personal information’ is information or an opinion whether true or not, and whether recorded in a material form or not, about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. The personal information we may collect and hold varies and is dependent on the product requested or the service to be provided.  Details can include but are not limited to:

• Name

• Date of birth

• Gender

• Current / previous addresses

• Contact details

• Email address

• Occupation

• Bank account details

• Bank statements and statements for electricity / gas accounts

• Credit references or reports from third party

• Drivers license details

• Passport and visa details

• Property ownership

• Financial information including assets and liabilities, investment and loan accounts, insurance application details, consumer spending, foreign exchange details

• Credit information including consumer and commercial credit reports

• Rental references and prior rental contacts; and

• Consumption habits and preference information

Protected classification characteristics under California or Federal law

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

The above information is collected and recorded about individuals who interact with us such as: our customers, potential customers and their representatives, our suppliers and their representatives, contractors and their representatives providing goods and services to us, our employees past and present, including applicants, and any other person who comes into contact with NOVA.

In most cases, if we do not collect the information we require, then we may be unable to undertake certain activities, such as providing you with the requested information, or services.

The Privacy Act provides an exemption for employee records.  That is information about an individual if that information directly relates to the act or practice of a current or former employment relationship between the employer and the individual.  That exemption may apply to NOVA in relation to the information held by NOVA about its employees.  Please contact the Privacy Officer for more details.

How does NOVA collect personal information?

Generally, when providing goods and services to our clients or obtaining goods and services from our suppliers or contractors, we collect personal information directly from the individuals where reasonable and practical. We may collect personal information directly from you when you:

• Provide information to us in any way (including by completing a form, disclosing information over the phone or providing us a business card)

• Visit our website

• Use our services

• Request information about us, our products or our services

• Provide feedback

• Fill in a form on our website, or when we phone you in response to a form you have submitted via our website;

• Enter a competition; or

• Where we are required or authorized by law to do so.

• Nominated representatives of the individual (e.g. spouse, accountant, power of attorney, brokers and other professional advisors)

• Other credit providers

• Credit reporting bodies and mercantile reporting agencies

• Publicly available sources of information

• Lawyers, medical providers, investigators, insurers including (WorkCover in relation to insurance claims).

We will only collect your personal information from third parties if it is unreasonable or impractical to collect the necessary information directly from you or if we are otherwise permitted to do so.

How does NOVA handle sensitive information?

The Privacy Act describes ‘sensitive information’ as information relating to a person’s racial or ethnic origin, political opinions, religion, trade union or other professional or trade association membership, sexual orientation, criminal record, and health information about an individual.

Occasionally it may be necessary for us to collect sensitive information about you (such as health information, racial origins and criminal records). If you or third parties provide us with sensitive information, we will as a matter of policy only use and disclose the information for the purpose for which it was provided or another directly related purpose, unless you agree otherwise, or where required by law.

Where practical and reasonable, we will only collect sensitive information with your consent.

Why does NOVA collect personal information?

NOVA is committed to providing quality customer service to our internal and external clients and to operate its businesses within statutory requirements and comply with its legal obligations.

We collect and hold personal information in order to operate our businesses efficiently as well as to provide and market our products and/or services for the benefit of our customers. We collect, hold and use your personal Information:

• to identify and communicate with you

• to enable us to provide requested goods and services

• to assess any request you make for the supply of goods and services on credit by establishing your financial position and credit status

• assess your ability to repay a loan

• to collect payments

• to place insurance policies

• to process any job application submitted by you

• to manage and maintain credit accounts for the provision of goods and services on credit

• to help us to manage and enhance goods and services we provide to you

• to help us to manage and enhance goods and services we purchase from our suppliers

• to develop and tell you about goods and services that we consider may be of interest, unless you advise us not to do so

• to protect you and us from fraud

• for business support purposes including maintenance, backup and audit

• to comply with our statutory and legal obligations

• to allow us to provide advertising material to you regarding us, our clients and other business partners,

• to respond to any queries or complaints you may have

• monitor activity on our website.

Marketing

You consent to us using your personal information for sending you information, including promotional material, about us or our products and services, as well as the products and services of our related entities and third parties, now and in the future.  You also consent to us sending you such information by means of phone, mail, email, SMS and MMS messages.  You can contact us using the contact details if you do not want to receive marketing information from us. In some instances, we may use third-party advertising technology to serve ads when you visit our website and sites upon which we advertise. This technology uses non-personal information about your visits to this website and the sites upon which we advertise to serve ads to you.

While the Company does not monetize your personal information, in the preceding 12 months the Company has “sold” consumer personal information to third parties, as we understand the term “sold” to be defined by the CCPA. In particular, we share personal information as follows:

Should you ever view any embedded Vimeo or Youtube video material on our Site, please be aware that they apply their own cookies which help you stay logged in, suggest recommended videos, volume preference and help Vimeo and Youtube to deliver advertisements. For further information regarding their policies, please refer to these webpages:
‍https://vimeo.com/cookie_policy
‍https://policies.google.com/privacy (YouTube)

How does NOVA manage data security?

We take reasonable steps to protect the security of your personal information by ensuring it is protected from misuse, loss, interference and from unauthorized access, modification or disclosure.

Our personnel are required to respect the confidentiality of your personal information and the privacy of individuals.  We maintain strict standards and security procedures to prevent unauthorized access to the personal information whether it is in an electronic or paper format, and to ensure the correct use of this information.  Personal information is stored in a central database that is password protected with access available only to authorized persons (such as NOVA employees or our external database administrator) or otherwise your personal information is securely held within the offices and only available to authorized persons.

Where we no longer require your personal information we will take reasonable steps to delete, de-identify or destroy all record of the information held.

You can access and update your personal information.

Subject to certain restrictions, the CCPA gives California residents certain rights to request access to personal information that the Company has about you, to request deletion of personal information that we collect and maintain, and to opt-out of the sale of personal information about you. This section describes how you can exercise those rights and our process for handling your requests.

You are entitled to access the personal information that we hold about you.  Upon written request, we will provide access to your personal information, except in circumstances where there are legal or administrative reasons to deny access.  If we refuse your request to access your personal information, we will provide you with reasons for our refusal.  For example, if the information requested relates to an insurance claim, we may refuse access if the information has been provided by third parties during an investigation.

We will require you to verify your identity and to specify what information you require.  We may charge a reasonable fee depending on the complexity of the request to cover costs in retrieving, coping and supplying the information to you.

If you establish that the personal information we hold about you is not accurate, complete and up to date, we will take reasonable steps to correct the information so that it is accurate, complete and up to date. If we cannot take reasonable steps to correct the information due to such correction is not technically possible or would be impracticable for us to perform, we may be unable to continue to provide services to you.  In these cases, we will provide reasons for denial of correction.

To request access or to correct your information, please contact our Privacy Officer.

How does NOVA deal with complaints?

If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Policy, please contact our Privacy Officer and advise us as soon as possible.  We will investigate your queries and complaints within a reasonable time frame depending on the complexity of the complaint.All complaints should be made in writing detailing relevant information pertaining to the complaint and those parties involved in the alleged breach.

Updates to this Privacy Policy

We may from time to time, update this Privacy Policy including to take into account new laws, regulations and technology.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

If you have any concerns or queries about our Privacy Policy, or if you would like more information about privacy-related issues please contact our Privacy Officer at:

‍Email address: privacy@novasmart.co