Privacy Policy

Last updated / {{TODO: month, year}}

This Privacy Policy describes how {{TODO: legal entity name}} ("NOVI", "we", "us", or "our") handles personal information in connection with the novigtm.com website and any other site we own or control that links to this policy (the "Site"), and our direct business communications.

This policy does not cover data we process for our clients. When we run outbound campaigns on behalf of a client, we act as a processor. That data is governed by our engagement agreement and data processing addendum with that client, not by this policy. If you received an email from a campaign we operate and want to know who is behind it, the sender identifies the client in the message, and you can also contact us at {{TODO: privacy email}} and we will point you to the right party or handle the request on their behalf.

Our services are built for businesses and the people who represent them. We do not offer services to consumers for personal or household use, and we treat the personal information we collect as relating to individuals acting in a business capacity.

A. Information we collect

Information you give us.

Contact details you submit through the slot request form: your work email address, and the answers you select about company size and current outbound activity.
Anything you send us directly, such as questions, replies to our emails, documents shared during a diagnostic, or feedback.
Information exchanged during an engagement with a client company, including names, roles, and contact details of the people we work with on the client side.
Marketing preferences, including whether you have asked to receive or stop receiving communications from us.

Information collected automatically. We and our service providers may collect technical information about your visit: device and browser type, operating system, screen size, IP address, approximate location derived from it, referring URLs, pages viewed, and time spent. We use cookies and similar technologies for this. Most browsers let you block or delete cookies through their settings, though some parts of the Site may not work properly if you do.

Information from other sources. We may receive information about you from public professional sources such as LinkedIn or company websites, and from business data providers, where that information is relevant to a prospective or existing engagement.

B. How we use it

To respond to a slot request, assess fit, and schedule a conversation.
To deliver and improve our services, including diagnostics, campaign strategy, infrastructure, and reporting.
To communicate about an active engagement, including updates, results, and invoicing.
To send business communications about our services where permitted. You can opt out at any time.
To meet legal and regulatory obligations, including tax, accounting, and anti-spam requirements.
To protect our rights, prevent fraud or misuse, and keep our systems secure.
To produce anonymised and aggregated statistics about our own performance. These never identify you or your company.

Legal bases (for individuals in the EEA and UK). We rely on: performance of a contract, where you are our client or acting for one; our legitimate interests in operating and marketing a business-to-business service, assessed against your rights; your consent, where we ask for it; and compliance with legal obligations.

C. How we share it

Service providers. Companies that host our site, send our email, manage our CRM and calendar, process payments, or provide analytics. They may use your information only as instructed by us.
Our deliverability partner, Trust Senders, where infrastructure work forms part of an engagement.
Professional advisers, such as accountants and lawyers, where needed for their work for us.
Authorities, where required by law or to protect our rights or the rights of others.
A successor, in connection with a merger, acquisition, or sale of assets, subject to reasonable efforts to require the recipient to honour this policy.

We do not sell personal information, and we do not share it with third parties for their own marketing.

D. Your choices and rights

Marketing. Every marketing email from us includes an unsubscribe link. You can also write to {{TODO: privacy email}}. You will still receive messages related to an active engagement.

Access, correction, deletion. Write to {{TODO: privacy email}} and we will action the request. Depending on where you are, you may also have the right to restrict or object to processing, to receive your data in a portable format, to withdraw consent, and to complain to your data protection authority. In {{TODO: jurisdiction}} that authority is {{TODO: authority name}}.

Cookies. Manage them in your browser settings.

Do Not Track. We do not currently respond to Do Not Track browser signals.

E. Retention

We keep slot request submissions for as long as needed to assess and respond to them, and for a reasonable period afterwards in case the conversation resumes. Engagement records are kept for the duration of the engagement and for as long as required by tax, accounting, and limitation periods afterwards. We delete or anonymise information when it is no longer needed for these purposes.

F. Security

We use organisational and technical measures appropriate to a business of our size to protect personal information, including access controls, encryption in transit, and vetted service providers. No system is completely secure, and we cannot guarantee absolute security.

G. International transfers

We work with clients and service providers in several countries, and your information may be processed outside your own. Where required, we rely on appropriate safeguards such as the European Commission's standard contractual clauses.

H. Third-party sites

The Site may link to sites we do not control. We are not responsible for their privacy practices, and a link is not an endorsement.

I. Children

The Site is not directed to anyone under 16, and we do not knowingly collect their information. If you believe we have, contact us and we will delete it.

J. Changes

We may update this policy. Material changes will be reflected in the date above and posted here, and where the law requires it, we will tell you directly. Continued use of the Site after an update means you accept the revised policy.