Privacy Policy

Novoville ltd (hereinafter “Novoville”, “the Company”, “The Organisation”,“We”, “Us”) is committed to protect and respect your privacy and ensuring compliance with the way we collect, process and use information including personal data.

This privacy policy aims to give you information on how Novoville collects and processes your personal data through your use of this website and our services, including any data you may provide through this website when you sign up to our newsletter, or use, purchase or interact with one of our products or services. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting, or processing, personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Who we are

Novoville Limited with company registration number 10313940 and registered address 46 Aldgate High Street, London EC3N 1AL including its wholly owned subsidiary, Novoville Limited Greek Branch (29 Antinoros Str, 11634-Athens, Greece and Kountouriotou 21, 38333-Volos, Greece) is a leading global provider of software solutions that helps public sector organizations accelerate digital transformation and offer better digital services to citizens.

The Company operates both as a data controller and a data processor. For all data and privacy related matters, queries or enquiries please contact us by email at: privacy@novoville.com

Type of personal data collected

Novoville is committed to only collecting no more data than is necessary. We collect personal information that you submit to us voluntarily when you register with us or when you use the Novoville platform (including pireapp) or any of our chatbot applications directly or via third parties such as Facebook.

When you register with and use our mobile and web applications, we may collect your name, nickname, phone number, email address and social media contact details.

Where you use our chatbot applications, we may ask you various pre-programmed questions agreed with our clients (such as your local council). These questions may relate to the services provided to you by our client, your relationship with our client, and other issues that may affect you. We will collect your answers to these questions, along with details about you that you choose to submit such as your age range, gender and disability. If you provide other information that may constitute personal data that we have not asked you for, we will promptly delete such information. Where you interact with such applications via third parties such as Facebook, we will not have any access to your account details, which will not be made available to us by that third party.

We may also collect feedback, comments and questions received from you in service-related communication and activities, such as meetings, phone calls, documents, and emails.

From our website we may collect IP-address and details of actions taken on the site. Novoville does not collect or process any sensitive personal data including any special categories of personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, and data concerning health or sex life or genetic data, and biometric data where processed to uniquely identify an individual. Please note that there may be certain sensitive information you provide if you are using one of our chatbot applications, but this information will always be anonymous and aggregated.

Registration: When you register in Novoville platform to use the software, or one of our mobile or web applications (although please note that registration is not required to use our chatbots), you will be asked to complete online forms providing for: your email address, mobile telephone number, nickname, location information (your mobile or other location-aware device to transmit location data e.g. when submit a problem report), device ID, GAID. This information is required in order to use the Novoville platform and our mobile and web applications. The information will not be re-used for an incompatible purpose to our scope of our services as described in the Terms and Conditions.

User account: You are responsible for maintaining the confidentiality of your password and account, and are fully responsible for all activities that occur under your account.

We also collect device type and unique identifier when you use our mobile application, we use this information for the sole purpose of providing you with the most up to date application and features.

When do we collect personal data

– When users of Novoville mobile apps and web apps, including pireapp (hereinafter “Novoville platform”), use our services/products

• Where individuals interact with our products and services such as our chatbot application directly via third party platforms (such as Facebook).
  – When you interact with us in person, through correspondence, by email, by phone, by social media, via our support system or through our website contact forms.
  – When we collect personal information from other legitimate sources, such as third-party data aggregators, organisation marketing partners, public sources or social networks. We only use this data if you have given your consent to them to share your personal data with others.
  – We may collect personal data if it is considered that we have a legitimate interest, and if this interest is not overridden by your privacy interests. Before data is collected we make sure an assessment is made, ensuring that there is an established mutual interest between you and the organisation.
• We may collect personal data about employees of our suppliers and partners during the course of our working relationship with them.

Why do we collect personal data

We collect and use personal data mainly to provide Novoville platform services to users and clients, generally to perform direct sales, direct marketing and customer service.

We may use your information for the following purposes:

– We may use information collected through one of our chatbot applications in the course of providing services to our clients. Such information will be anonymised and aggregated such that it is no longer personal data before we use it or provide it to our clients. We may send you subsequent messages via the chatbot to update you or to let you know that a consultation has been published in connection with the information you and others have provided. The “chathead” through which we have communicated with you will remain open for around one month after we contacted you. Our lawful basis for contacting you and collecting such data is your consent. Once we have collected such data, as it will be anonymised and aggregated, no lawful basis is required for its subsequent use.

– Where we collect information provided by you, we may use it to provide you with an enhanced experience when using the Novoville platform (mobile apps, web app). We use this information to closely monitor which features of the Novoville platform are used most, to allow you to report a problem to your local authority, to submit a service request, to view your requests history, view any promotions we may currently be running, read important announcements or alerts, and to determine which features we need to focus on improving, including usage patterns and geographic locations to determine where we should offer or focus services, features and/or resources, to send sms, email and/or push notification for confirming that your request has been resolved. Our lawful basis for processing your data in this way is our legitimate interest in improving and enhancing our products and services. We use the mobile information collected so that we are able to serve you the correct app version depending on your device type and for troubleshooting. Our lawful basis for processing your data in this way is our legitimate interest in making our products, applications, and services available to you and ensuring that they work correctly.

– We may also use your personal information to create anonymous information records by excluding information that makes the information personally identifiable to you. Our lawful basis for processing your data in this way is our legitimate interest in anonymising your information so that it can be aggregated and incorporated into our records without being able to identify you.
– We may send you marketing communications which you have requested. These may include information about our products and services, events, activities, customer success stories, case studies, and promotions of our associated partners’ products and services. This communication is subscription based and requires your consent.
– We may send you information about the products and services that you have purchased from us. Our lawful basis for this processing is performing our contract with you.
– Perform direct sales activities in cases where legitimate and mutual interest is established.
– Reply to a ‘Request info’ or other web forms you have completed on our website. Our lawful basis for this processing is our legitimate interest in responding to your enquiry.
– Follow up on incoming requests (customer support, emails, chats, or phone calls). Our lawful basis for this processing is our legitimate interest in responding to your enquiry.
– Provide you with access and services related to Novoville platform. Our lawful basis for this processing is performing our contract with you.
– Perform contractual obligations such as order confirmation, license details, invoice, reminders, and similar. The contract may be with the organisation directly or with a Novoville partner. Our lawful basis for this processing is performing our contract with you.
– Notify you about any disruptions to our services (system messages). Our lawful basis for this processing is our legitimate interest in managing our services, products and platforms and keeping our customers updated with issues.
– Contact you to conduct surveys about your opinion on our products and services and in relation to our use of Novoville platform. Our lawful basis for this processing is our legitimate interest in gathering useful feedback on our products and services so that we may improve them.

Your rights to your personal data

You have the following rights with respect to your personal data:

– The right to request a copy of your personal data that the organisation holds about you.
– The right to request that the organisation corrects your personal data if inaccurate or out of date.
– The right to request that your personal data is deleted where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
– The right to withdraw any consent to personal data processing at any time. For example, your consent to receive e-marketing communications:

A. Novoville manages its email opt-ins on the basis that customers, potential customers and any third parties (individuals or other organisations) who request to receive promotional material from us have provided express consent in a freely given, specific, informed, and unambiguous way, which is reinforced by a clear affirmative action. If you want to withdraw your consent to e-marketing, please make use of the link to manage your subscriptions included in our communication, this allows users to manage their email preferences (whether for example, in relation to product information, invitations, promotions, press releases and urgent messages) and includes an ‘unsubscribe link’.
B. Novoville therefore asks all visitors to our website to specifically opt-in to newsletters, promotions or other communications by ticking a sign up box and confirming agreement to any terms that may be applicable as well as the content of this Privacy Policy.
C. Please note that you may still receive system messages and administrative communications from us, such as order confirmations, system messages and notifications about your account activities.

– The right to request that the organisation provides you with your personal data and, if possible, to pass on this information directly (in a portable format) to another data controller when the processing is based on consent or contract.
– The right to request a restriction on further data processing. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

1. If you want us to establish the data’s accuracy.
2. Where our use of the data is unlawful but you do not want us to erase it.
3. Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
4. You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

– The right to object to the processing of personal data, in cases where our data processing has been based on a legitimate interest, and/or where our processing is for direct marketing purposes.

Any request or query about your privacy rights should be sent to: privacy@novoville.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How we share Personal Information with other parties

In addition to the ways we share personal information with authorised Local Government employees (as per our terms of service), we may share your personal information with other third parties in the following manners:

– Service providers under contract with us who help with parts of our business operations (e.g. marketing, technology services), though we require that these service providers only use your information in connection with the services they perform for us and not for their own benefit;
– To a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honour this privacy statement;
– To a company that merges with us, acquires us, or purchases our assets, in which case such company may continue to process your personal information as set forth in this privacy statement;
– Law enforcement, government officials, or other third parties when
A. we are compelled to do so by a court order or similar legal procedure
B. we need to do so to comply with the law
C. we believe in good faith that we need this information to protect or defend our rights or property or users of our products, platform, software or other services.
– Other third parties with your consent or where we are directed to do so

Except as set forth above, we do not sell, share, rent or trade your personal information or geo-location information other than as disclosed within this privacy statement. We sometimes use data from Novoville platform, or share it with trusted third parties, for research. This data is completely anonymised and contains no identifying details such as names, email addresses or the content.

Local Governments / Local Authorities

When you submit a report or a service request through Novoville platform, authorised personnel from the local authority responsible for handling the report/request may have access to your details, and details of the issue/request.

Furthermore, you may receive a call or SMS/email/in-app message regarding the status of your request.

Third Party Applications

Facebook and Google: You may decide to register or sign in to the Novoville platform through Facebook or Google login. In this case you authorise the relevant Facebook/Google authentication service to provide us with the following personal details: name, email, age range, Facebook/Google ID, timezone.

Google maps: Novoville platform uses Google maps API that allows you to get location data when requested (e.g. to submit a report or view POIs on city maps). We provide only location data to Google according to GDPR clause 6.1.

The use of cookies and beacons

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see: https://www.novoville.com/cookie-policy/

Third-party Service Providers working on our behalf

We may pass your information on to our partners, distributors, agents, subcontractors and other associated organisations with the purpose of them providing services to you on our behalf.

If required by law: we will disclose your personal information if required by law or if we, as an organisation, reasonably believe that disclosure is necessary to protect our organisation’s rights and/or to comply with a judicial proceeding, court order or legal process. However, we will do what we can to ensure that your privacy rights continue to be protected.

Use of subcontractors (processors and sub-processors)

We may use subcontractors to process personal data on your behalf, (e.g. for platform management and hosting services we provide) we are responsible for making sure they commit themselves to adhere to applicable data protection legislation by entering into data processing agreements with them.

If a new subcontractor is engaged or there is a change of subcontractor in relation to our products or services, we will notify you in line with the requirements of our data processing obligations.

International Transfers

We do not currently transfer your personal data outside the European Economic Area (EEA) or the United Kingdom.

If in the future we were to transfer your personal data out of the EEA or the UK, we would ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission or any body governing data protection within the UK.
2. Where we use certain service providers, we may use specific contracts approved by the European Commission or any body governing data protection within the UK which give personal data the same protection it has in Europe.
3. Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield (or any alternative scheme permitting transfers of personal data from the UK to the US) which requires them to provide similar protection to personal data shared between Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA or the UK.

Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers for six years after they cease being customers for tax purposes. If you are employed by one of our customers, we may keep your personal data for the duration of our time providing services to your employer organisation, or longer, if necessary.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

Where we collect your data through one of our products, platforms or via a third-party platform (such as Facebook), we will anonymise any data collected that we hold about you. Any data we receive from third parties such as Facebook is deleted around 2 months after the initial engagement (although note that we will retain anonymised, aggregated data derived from the engagement).

Changes to this Privacy Notice

Novoville reserves the right to amend this Privacy Policy at any time. The applicable version will always be found on our website. We encourage you to check this Privacy Policy occasionally to ensure that you are happy with any changes.

If we make changes that significantly alter our privacy practices, we will notify you by email or post a notice on our websites prior to the change taking effect.

Your right to complain

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance, by emailing: privacy@novoville.com