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Privacy Policy

1. NovaPulse Digital activities – Contact DPO  
This privacy policy applies to NovaPulse Digital Corp., a Delaware, USA corporation with headquarters in New York; and its affiliated subsidiaries (collectively, “NovaPulse Digital,” or “we “, “us “, “our “). We operate in various offices around the world and we partner with publishers and advertisers across the globe. 
NovaPulse Digital mission is to serve interesting recommendations to you based on what we believe are your interests. To achieve our mission, we enter into agreements with: 
publishers and online partners who want to recommend relevant content to their readers. 
advertisers who want readers to view their content. 

We regularly review our compliance with this Privacy Policy. Questions, comments, and requests regarding this Privacy Policy are welcomed and should be addressed in the first instance to legal@NovaPulse Digital.com or by mail to NovaPulse Digital Corp, 140 Broadway Lower, 46th floor, 10005 New York, USA, Attn: legal department. 


2. NovaPulse Digital site visitors and users (including opt-out options)
 site visitors and users (including opt-out options) 
This privacy policy concerns visitors of Our Site. We detail what information we collect and its purpose, what cookies and other similar technologies we use, how we share this information and your rights. 
Site Visitors: You are a Site Visitor when you visit and interact with our web site, web pages and their content on NovaPulse Digital.com (“Our Site “). 
Collection and use of information: 
We want to understand what services on our sites are of interest to you and we want to remind you of the services we offer when you are not on our sites. To do this, we collect the following information about your device: (i) IP address; (ii) User agent data: device type, browser type), operating system; (iii) the pages visited on our sites; (iv) the time of the visit (and the corresponding time zone); and (v) referrer URLs and other information normally transmitted in HTTP requests. 
In addition, we may also collect your name and email address if you agree to send your details to us through our site (for example, by signing up to receive our newsletter). 


Cookies and any technologies used: 
Please see this cookie table, which is updated from time to time, in the ‘cookies’ tab for a detailed list of first-party and third-party cookies (and their corresponding retention periods) that may be used when you visit our website. 

Sharing of information: 
We do not sell and / or share personal data about you with third parties for the purposes of third-party marketing or advertising. We may use various third parties (each listed in the cookie table) to help us market or advertise to you. We require that these third parties and companies agree to comply with all applicable data protection laws, to keep all information shared with them confidential, and to use that information only to fulfill their obligations to us. 
On our site, you will notice clickable icons that will take you to the NovaPulse Digital Facebook page or the NovaPulse Digital LinkedIn page. If you choose to click on these links, you should be aware that these sites are not owned or operated by NovaPulse Digital and therefore these third-party websites may send their own cookies to your device and collect personal data independently. It is therefore important that you familiarize yourself with the privacy policies of these third-party websites. 
Your rights: 
You can stop visiting Our Site at any time. If you do, you may also want to remove any cookies that we have placed on any device used to access Our Site, you can do this via your browser. If during your use of Our Site you provided your email address, any email you receive from NovaPulse Digital includes an “unsubscribe” option. 
For visitors to the site in Europe, NovaPulse Digital has set up a consent management system on the site which offers you the possibility of consenting, or not, to cookies and similar tracking technologies. When accessing our sites, you will see a banner with information about the cookies we use. You can click on the banner to decline all cookies (for example, performance cookies or targeting cookies) that are not strictly necessary cookies (as defined in the cookies table). By pressing ‘I accept’ on the banner, you indicate your acceptance of cookies and similar tracking technologies. The legal basis of NovaPulse Digital for the processing of personal data of site visitors from the European territory on our sites is consent. You can withdraw your consent at any time in the Cookie settings. About all other visitors to the site not located in European territories, we rely on our legitimate interest in the processing of personal data, but this does not prevent non-European site visitors from withdrawing their consent at any time. via consent management. 
Users: You are a user when you visit a page of a website or application of one of our partners (“Partner Sites”). If you click on the hyperlink to NovaPulse Digital, you will see a detailed notice which allows you to navigate to NovaPulse Digital’s interest portal and this privacy policy where you can opt out of personalized recommendations. In some cases, a partner may have the NovaPulse Digital service white label for its own offer. In such a case, these partners must disclose their use of NovaPulse Digital in their privacy policies. 
Collection and use of information: 
We use UUIDs, IP Address and other Usage Information so that we can serve interesting recommendations. NovaPulse Digital’s recommendations may be paid for by an advertiser linking you to a new website or they may be organic such that the link is to another page on the same Partner’s Site. 


UUID. 
When you, as a User, first visit a Partner Site, NovaPulse Digital drops a cookie on your device to generate a UUID. Alternatively, if you first interact with a Partner using that Partner’s application, NovaPulse Digital receives your advertiser ID which is assigned to you by your device. We catalog and analyze the content you consume across Partner Sites. Our recommendations are based on: (i) a UUIDs browsing history; (ii) similar browsing patterns of other Users; (iii) recommendations that are generally popular with NovaPulse Digital’s audience at this time; (iv) some randomness. When you interact with NovaPulse Digital we do not collect traditional personal data from you, like your email address or name, therefore we cannot associate your name with your UUID. 
The UUID is a sequence of numbers and / or letters. This UUID attaches itself to your device and varies depending on your browser combination. In other words, NovaPulse Digital records a different UUID depending on which device and / or which browser you use when accessing the Partner Sites. NovaPulse Digital will combine and consolidate a UUID from a mobile device (handheld or tablet) from a browser that then accesses an application (or vice versa) from that same device. NovaPulse Digital does not conduct cross device tracking and therefore cannot link a user interacting with NovaPulse Digital on their phone as the same user who is interacting with NovaPulse Digital on their desktop. 
IP Address 
In addition to your UUID, we recognise your IP address, which we translate into geolocation and delete the last octet in order to mask the identifying information. We then use this masked information, in conjunction with information we received from other trusted third party partners to determine a broad understanding of where you are located. NovaPulse Digital will still recognise your IP address even if you opt out of personalised tracking as this is necessary to continue serving you context-based recommendations however, in such instances your IP address is not associated with your UUID and would not form part of any user profile. 
Other Usage Information 
In addition to your UUID and IP address, we also collect the following information from you on (a) desktop and mobile web: (i) User Agent data: device type (e.g., iPhone), browser type, operating system ; (ii) the pages visited; (iii) the time of visit; and (iv) referring URLs and other information normally transmitted in HTTP requests. The above statistical information provides us with information about how many Users visited a specific page on our Partner Sites, how long each User stayed on that page, the type of content on that page they clicked on and how they generally engaged with that page.
As NovaPulse Digital does not have a direct relationship with Users interacting with Partner Sites, NovaPulse Digital relies on its partners to determine the lawful basis upon which NovaPulse Digital can process personal data. 

 

 


3. Security Measures, Transfers Outside the EEA, Sharing and Data Retention
Security 
We maintain strict controls over the personal data we collect, keeping it in databases protected by a firewall and secured with strictly limited and controlled access rights, to ensure its security. Please see our security standards for more information. 
Data transfers outside the EU / EEA 
When we transfer personal data from the European Economic Area (EEA), we will ensure that such transfers comply with relevant data protection laws, including, where applicable, EU Standard Contractual Clauses or a positive adequacy decision of the European Commission under Article 25 (6) of Directive 95/46 / EC or Article 45 of the GDPR. In other words, your rights and protections remain with your data and we have used approved contractual clauses and other measures designed to ensure that the recipients of your personal data protect them. 
Sharing 
In addition to the description of how we may disclose your personal data, we may also disclose personal data as follows: 
Within the family of companies controlled by NovaPulse Digital for internal reasons, primarily for business and operational purposes. 
If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal data will likely be among the assets transferred. 
When legally required to do to cooperate with law enforcement investigations or other legal proceedings; and/or to respond to a genuine emergency. 
Data Retention 
The retention period for each of the cookies NovaPulse Digital uses is stated in the Cookie Table. More specifically, cookie which is used for tracking user actions such as clicks, expires three (3) months after a user visited a particular site within our network however, this cookie will reset if a user returns to the same site or different site within our network. In addition, we do not retain any individual data point on a User for more than 13 months. NovaPulse Digital also maintains a Data Retention Policy that details the retention period for personal data based on our analysis of how long the specific data is reasonably required for legal or business purposes. When we no longer need personal data, we securely delete or destroy it. Aggregated data, which cannot identify a device/browser (or individual) and is used for purposes of reporting and analysis, is maintained for as long as commercially necessary.

 
4. Children and Sensitive Data
Children 
None of our services are intentionally directed at children under 16. We do not knowingly collect personal data from anyone under 16 years of age. If we determine upon collection that a Site Visitor is under 16, we will not use or maintain his/her personal data. If we become aware that we have unknowingly collected personal data from a child under the age of 16, we will make reasonable efforts to delete such information from our records. 
Sensitive data 
We do not collect or receive any sensitive categories of personal data. 


5. European Territory Visitors
In compliance with certain privacy laws, the European General Data Protection Regulation (GDPR), NovaPulse Digital provides specific additional rights for individuals who interact with NovaPulse Digital such as the right to access, rectification, right to object, to complaint, erasure, and blockage. More specifically and under certain circumstances: 
the right to request information about whether and which personal data is processed by us, and the right to demand that personal data is rectified or amended. 
the right to request that personal data should be deleted. 
the right to demand that the processing of personal data should be restricted. 
withdraw your consent to the processing and use of your data completely or partially at any time with future application. 
have the right to obtain your personal data in a common, structured, and mechanically readable format. 
contact our data protection officer if there are any questions, comments, complaints, or requests in connection with our statement on data protection and the processing of your personal data. 
the right to complain to the responsible supervisory authority if believed that the processing of your personal data is in violation of the legislation. 
In addition to the above, we reference certain rights for European Territory citizens throughout this Privacy Policy. Pursuant to the GDPR, citizens from ‘European Territories’ mean the European Economic Area (EEA), the European Free Trade Area (EFTA) and Switzerland. To this Privacy Policy, the term ‘European Territories’ shall continue to include the United Kingdom after Brexit. 


6. California Privacy Rights
This section applies only to California residents. It describes how we collect, use, and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA. 
Your California privacy rights. 
As a resident of California, you have the rights listed below. However, these rights are not absolute, and in some cases, we may deny your request as permitted by law. 
Information. You can request the following information about how we have collected and used your personal information in the past 12 months: 
The categories of personal information we have collected. 
The categories of sources from which we have collected personal information. 
The commercial or commercial purpose of collecting and / or selling personal information. 
The categories of third parties with whom we share personal information. 
Whether we have disclosed your personal information for commercial purposes and, if applicable, the categories of personal information received by each category of third-party recipient. 
Whether we have sold your personal information and, if applicable, the categories of personal information received by each category of third-party recipient. 
Access. You can request a copy of the personal information we have collected about you in the past 12 months. 
Deletion. You can ask us to delete the personal information we have collected from you. 
Opt-out off sales. If we sell your personal information, you can opt out. In addition, if you direct us not to sell your personal information, we will consider it a request under California ‘Shine the Light’ law to stop sharing your personal information covered by this law with third parties for direct marketing purposes. 
Opt-in. We contractually prohibit our publishing and advertising customers from placing our technology on pages that target people under the age of 16. If we learn that you are under 16, we will ask your permission (or if you are under 13, the permission of your parents or guardians) to sell your personal information before we do so. 
Nondiscrimination. You have the right to exercise the rights described above without discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increase in the price / tariff of services; decrease in the quality of service; or suggesting that we may penalize you as described above for exercising your rights. 
Exercise your rights. 
You may exercise your California privacy rights described above as follows: 
Right to information, access, and deletion. You can request to exercise your information, access, and deletion rights by emailing legal@NovaPulse Digital.com 
Right to opt-out of the “sale” of your Personal Information. We do not sell your Personal Information in the conventional sense. However, like many companies, we use services that help deliver interest-based ads to you. California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users so they can help serve ads more likely to interest you. To opt-out of this” sale,” click on this link which will take you to our Interest Profile where you can opt out of personalized  recommendations. 
We will need to confirm your identity and California residency to process your requests to exercise your information, access, or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. 


7. “Do Not Track” Disclosure
Some browsers transmit Do Not Track (DNT) signals to websites. Because there is no common understanding of how to interpret the DNT signal, NovaPulse Digital does not currently alter, change, or respond to DNT requests or signals from these browsers. We will continue to monitor industry activity in this area and reassess our DNT practices, as necessary. In the meantime, you can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving personalized recommendations.


8. Privacy Policy Change
We may change this Privacy Policy from time to time. We will place a prominent notice that will be visible to you as a Site Visitor, but we do not have a means of advising Users of an update by way of notice. You should check back here periodically to see if the Privacy Policy has been updated as we will always show the date of the latest modification of the Privacy Policy at the top of the page so you can tell when it was last revised.

 

9. Jurisdictional Issues, Governing Law
Our Site is controlled and/or operated from the United States. The Site may not be appropriate or available for use in some jurisdictions outside of the United States. In choosing to access the Site, you do so on your own initiative and at your own risk, and you are responsible for complying with all local laws, rules, and regulations. We may limit the Site’s availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion. Any controversy or claim arising out of or relating to this Agreement or the relationship resulting in or from this Agreement shall be settled through binding arbitration in accordance with the Expedited Commercial Arbitration Rules of The American Arbitration Association, 140 West 51st Street, New York, New York 10020-1203. Any award rendered by the arbitrator(s) shall be entered as a judgment or order and may be confirmed or enforced by either party in any state or federal court having competent jurisdiction thereof.


10. Claims of Copyright Infringement
The Digital Millennium Copyright Act of 1998 (the “DMCA”) provides recourse for copyright owners who believe that material appearing on the Internet infringes their rights under U.S. copyright law. If you believe in good faith that materials available on the Site infringe your copyright, you (or your agent) may send us a notice requesting that we remove the material or block access to it. If you believe in good faith that someone has wrongly filed a notice of copyright infringement against you, the DMCA permits you to send us a counter-notice. Notices and counter-notices must meet the then-current statutory requirements imposed by the DMCA. We suggest that you consult your legal advisor before submitting a notice or counter-notice.