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Privacy Policy

Last Updated: December 7, 2017

This privacy policy describes the privacy practices of Nova Credit Inc. (“Nova Credit,” “us”, “we” or “our”) with respect to our Services (as defined in our Terms of Service) offered through www.neednova.com and our related websites. Please carefully read our policy to understand how we will treat the information that you provide and other information that is collected while using our Services.

What Information we Collect

When you visit www.neednova.com (or our related websites) or use our Services, we may collect both Personal Information and Non-Personal Information. Personal Information is information that relates to an identified or reasonably identifiable natural person. Non-Personal Information is information that doesn’t or cannot be reasonably identified to you personally.

We may collect the following types of information through our Services:

  • Identifying information you provide when requesting credit-related products. For example, to facilitate access to your foreign credit data, you must provide Personal Information such as name, residence and mailing address, government-issued identification number, date of birth, telephone number, and e-mail address. You may also need to provide additional information to verify your identity, such as your mother’s maiden name or city of birth.
  • Information you authorize us to obtain from third parties, such as foreign credit bureaus. Our Services help you facilitate access to credit data about you held by foreign credit bureaus and other data providers. As such, you may provide or authorize these data sources to provide us with information about you relating to your creditworthiness including, but not limited to, credit accounts and inquiries, utility payment records, public records and other credit report information.
  • Information you provide in connection with customer service communications and general feedback.
Our Website may also use “cookies” (small data files stored on your computer) and other tracking technologies to automatically collect information about your visit to our websites, such as the pages you visit, when you last visited our websites, the website you visited before and after your visit to our websites, and information about your interactions with our website. Some of this information may be Personal Information, such as your IP address combined with other identifiable information. However, some of this automatically collected data, such as performance cookies that collect information about how visitors use the website, which pages are visited most often, etc., are Non-Personal Information.

We use Google Analytics to track and report website traffic. To find out more about Google Analytics’ cookie usage please visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.

Your browser software can be set to reject all cookies or to accept cookies only from our site. Most browsers offer instructions on how to set the browser to reject cookies in the “Help” section of the toolbar. If you reject our cookies, you may not be able to log in or use certain functions and conveniences of our site. We treat the data of everyone who comes to our site in accordance with this privacy policy, whatever their Do Not Track setting.

How We Use Information We Collect

We may use your Personal Information that we collect to:

  • Provide you with product, services, or information that you request, and to fulfill your purchases, as permitted by law.
  • Communicate with you about transactions or services you have requested from us.
  • Send you important information regarding our Services or changes to this Privacy Policy.
  • Understand your needs and preferences and to inform you about products, services, and promotions that we believe may be of interest to you (to the extent you have chosen to receive such communications as discussed further in the section “Your Communication Choices” below).
  • Conduct our internal business operations, such as data analysis and audits.
With respect to the information that is automatically captured about your visit, such as through cookies or other tracking technologies, we may use this information in a variety of ways, including to monitor and maintain information about your visits to our website to better understand your needs and preferences, to help us identify and address problems, to improve our website, to analyze web traffic trends, and to help protect the security and integrity of our website.

Information Disclosure to Third Parties

We may disclose information about you as permitted by law to affiliated and non-affiliated third parties as follows:

  • Affiliates: We may disclose the information that we collect about you to our affiliated companies to provide the products you request, to enhance our products to better suit your needs and, to the extent you have chosen to receive such marketing communications, for marketing purposes.
  • Business Partners: We may partner with other companies to offer you products or services or to complete your requests regarding our products or services. For example, we partner with foreign credit bureaus and others to access, process and deliver your foreign credit data to end users you have chosen. We may disclose Personal Information and/or Non-Personal Information to such third-party business partners as authorized by you or required to provide Services you request. We may also send you from time to time information about products and services offered by these business partners to the extent you have chosen to receive such marketing communications (see “Your Communication Choices” below).
  • Service Providers: We may work with third party service providers who act on our behalf and assist us with functions such as hosting our data, performing analytics, marketing on our behalf, fulfilling orders and customer communication, among others. We may disclose both Personal Information and Non-Personal Information to them for the purpose of enabling such service providers to provide services to us. These third parties are only allowed to use shared information for the intended purpose in accordance with this Privacy Policy.
  • Assignment: We reserve the right to transfer any and all information that we collect through our Services to an affiliate or third party in the event a corporate reorganization, merger, sale, joint venture, assignment, transfer, or other disposition (either whole or partial) of our business, assets, or stock (including, without limitation, a bankruptcy or financial restructuring). We will take all reasonable steps to ensure that any Personal Information transferred under these circumstances will be handled in a manner consistent with the Privacy Policy under which it was originally collected. You will be notified by e-mail if, as a result of such corporate restructuring acquisition or assignment, our new privacy policies or the policies of the acquirer are materially different, and will be given an opportunity to withdraw your consent to the continued use of your information.
  • As Required by Law or Legal Process: Notwithstanding any other provision of this Policy to the contrary, we may disclose Personal Information and/or Non-Personal Information as we believe appropriate to (a) comply with legal process (including possible subpoenas by the United States government); (b) respond to government requests; or (c) as required by applicable laws, including the Fair Credit Reporting Act.
  • To Enforce This Policy and Protect Certain Rights: Notwithstanding any other provision of this Policy to the contrary, we may disclose Personal Information and/or Non-Personal Information as we believe appropriate to: (a) enforce this Policy; (b) protect the rights, privacy, safety or property of Nova Credit, our affiliated companies, you, or others; or (c) to permit us to pursue available remedies or limit the damages that we may sustain.

Your Communication Choices

When using our Services, you may be presented with a choice to receive marketing communications from us about products or services we or our business providers offer that may be of interest. If you no longer wish to receive marketing offers from us, you may unsubscribe via the unsubscribe link in such communications.

You may set your browser not to accept cookies or to notify you when you receive cookies, giving you the opportunity to decide whether to accept cookies. If you do not accept cookies, you may still use our website, but your experience may be impaired. Some web browsers may also transmit “do-not-track” signals to websites with which the browser communicates. We currently do not take action in response to these signals at this time. If we do so in the future, we will describe how we do so in this Privacy Policy. For more information about “do not track,” visit www.allaboutdnt.org.

Security

Personal Information is maintained on our servers or those of our service providers. We use a variety of technologies and processes to help protect the integrity of our Services, including physical, technological, and organizational security measures.

No information transmission or storage system is 100% secure and protecting your Personal Information is also your responsibility. Please safeguard any authentication and identification information you use to access our Services. You should not disclose your authentication information to any third-party and should immediately notify us of any unauthorized use of your password. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account with us has been compromised), please immediately notify us of the problem by contacting us at help@neednova.com.

Links to Other Websites

Our Services may contain links to websites or services owned and operated by third parties. Information you share with a third-party or third-party site is not subject to this Privacy Policy. Please review the privacy policy of any third-party sites or services you access through our Services.

Children’s Privacy

Our Services are not directed to minors (individuals under the age of majority) and we request that such individuals not provide Personal Information to us. We do not knowingly collect information from minors. If you are under the age of majority, you may browse content available on our site but should not provide any Personal Information to us such as name, address, or email address.

Data From the European Union

Nova Credit participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union. Nova Credit is committed to subjecting all personal data received from European Union member countries to the Framework's applicable Principles. These Principles include rights for individuals from the European Union to access their personal data and you can refer to Frequently Asked Questions here. In certain situations, however, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

With respect to personal data received or transferred pursuant to the Privacy Shield Framework, violations of our commitment to Privacy Shield may be investigated by the Federal Trade Commission and/or the United States Department of Commerce. Nova Credit is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Nova Credit is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions.

Nova Credit complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Nova Credit has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

In compliance with the EU-US Privacy Shield, Nova Credit commits to resolve complaints about your privacy and our collection or use of your personal information. Persons from the European Union who have inquiries or complaints regarding this privacy policy should first contact us via: email at: privacy@neednova.com. Privacy Shield organizations must respond within 45 days of receiving a complaint.

If you do not receive a timely acknowledgment from us of your complaint, or if we have not addressed your privacy or data use complaint satisfactorily, please contact your respective EU data protection authority listed here. Nova Credit commits to cooperate with the EU data protection authorities with regard to data transferred from the European Union.

Please note that if your complaint is not resolved through these channels, under limited circumstances, a binding arbitration option may be available before a Privacy Shield Panel.

For Canadian Residents

Nova Credit and its affiliates and service providers may process and store Personal Information outside of Canada for the purposes described in this privacy policy. While outside of Canada, Personal Information will be subject to applicable foreign laws, which may permit foreign government and national security agencies to access Personal Information in certain circumstances.

If you are a resident of Canada, you may request access to or correction of the Personal Information in our custody or control by writing to us at privacy@neednova.com or Nova Credit Inc., Customer Relations, 2 Mint Plaza, San Francisco, CA 94103. We may take reasonable steps to verify your identity before providing access or making corrections.

Changes to Privacy Policy

Nova Credit reserves the right to change this Privacy Policy at any time. If we change this policy, we will revise the “Last Updated” date above. Any changes to our Privacy Policy will become effective upon our posting of the revised Privacy Policy on this page unless otherwise noted. Use of our Services following such changes constitutes your acceptance of the revised Privacy Policy that is in effect. If a change to this Privacy Policy materially modifies your rights or obligations, we may require that you accept the modified Privacy Policy in order to continue to use the Services.

Contact

Nova Credit has assigned responsibility for this policy to our Privacy Officer, who you may contact with any questions regarding this Policy at Nova Credit Inc., Attn: Privacy Officer, 2 Mint Plaza, San Francisco, CA 94103 or by e-mail at privacy@neednova.com. Please note that e-mail communications will not necessarily be secure. As such, you should not include sensitive personal information in your e-mail correspondence with us.