Last Updated: December 7, 2017
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.
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.
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.
- 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.
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).
- 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.
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 firstname.lastname@example.org.
Links to Other Websites
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.
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
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 email@example.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.
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 firstname.lastname@example.org. 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.