PRIVACY POLICY
BACKGROUND:
In this Policy, unless specified otherwise, words and phrases shall have the same meanings as specified in our Terms and Conditions which can be viewed here: https://novoville.com/sharedrepairs_contract for Lead Proprietors and here: https://novoville.com/sharedrepairs_eula for other Proprietors.
NOVOVILLE LIMITED, incorporated in England (Registered No. 10313940) with its registered office at 46 Aldgate High Street, Suite 20, London, England, EC3N 1AL understands that your privacy is important to you and that you care about how your personal data is used and shared online. We respect and value the privacy of Users and will only collect and use personal data in ways that are described here, and in a manner that is consistent with Our obligations and your rights under the law.
Please read this Privacy Policy carefully and ensure that you understand it. You will be required to read and accept this Privacy Policy before using the Services. If you do not accept and agree with this Privacy Policy, you must stop using Our Services immediately.
1. Definitions and Interpretation
In this Policy, the following terms shall have the following meanings:
“Cookie” means a small text file placed on your computer or device by Our Services when you visit certain parts of Our Services and/or when you use certain features of Our Services. Details of the Cookies used by Our Services are set out in section 12, below;
“Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any variation, supplementation replacement, modification, amendment or re-enactment thereof;
“personal data” means any and all data that relates to an identifiable person who can be directly or indirectly identified from that data. In this case, it means personal data that you give to Us via Our Services. This definition shall, where applicable, incorporate the definitions provided in the Data Protection Act 2018, any legislation which succeeds that Act, the retained EU law version of the General Data Protection Regulation ((EU) 2016/679) (the “UK GDPR”), as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018; and
“We/Us/Our” means the said Novoville Limited (as above).
2. Information About Us
2.1 Our VAT number is GB 283614101
2.2 Our Data Protection Officer is Iraklis Bourantas, and can be contacted by email at privacy@novoville.com, by telephone on +44 (0)207 442 5551, or by post at 46 Aldgate High Street, Suite 20, London, England, EC3N 1AL.
2.3 We are a founding member of Association Civic Tech Europe (ACTE).
3. What Does This Policy Cover?
This Privacy Policy applies only to our use of data gathered by Us in your use of the Services.
4. Your Rights
4.1 As a data subject, you have the following rights under the UK GDPR, which this Policy and Our use of personal data have been designed to uphold:
4.1.1 The right to be informed about Our collection and use of personal data;
4.1.2 The right of access to the personal data We hold about you or your employees and customers/clients (see section 11);
4.1.3 The right to rectification if any personal data We hold about you or your employees and customers/clients is inaccurate or incomplete (please contact Us using the details in section 13);
4.1.4 The right to be forgotten – i.e. the right to ask Us to delete any personal data We hold about you or your employees or customers/ clients (We only hold personal data for a limited time, as explained in section 6 but if you would like Us to delete it sooner, please contact Us using the details in section 13). Please note that deletion of certain personal data may prevent the Services from functioning;
4.1.5 The right to restrict (i.e. prevent) the processing of personal data;
4.1.6 The right to data portability (obtaining a copy of personal data to re-use with another service or organisation);
4.1.7 The right to object to Us using personal data for particular purposes; and
4.1.8 Rights with respect to automated decision making and profiling.
4.2 If you have any cause for complaint about Our use of personal data, please contact Us using the details provided in section 13 and We will do Our best to solve the problem for you. If We are unable to help, you also have the right to lodge a complaint with the UK’s supervisory authority, the Information Commissioner’s Office details of which can be found here https://ico.org.uk/
5. What Data Do We Collect?
We may collect some or all of the following personal and non-personal data:
5.1 name;
5.2 date of birth;
5.3 business/company name
5.4 job title;
5.5 contact information such as email addresses and telephone numbers;
5.6 full address;
5.7 IP address;
5.8 web browser type and version;
5.9 operating system;
5.10 you activity on www.novoville.com, including your provenance and destination;
5.11 Information about the repair & maintenance issue you are facing, including description, photos, quotes;
5.12 Information about your building, such as its address, makeup (flats and shops), repair & maintenance issues, Title Deeds rules, etc.;
5.13 Information about your account with our maintenance account provider (“Modulr Finance” as of January 2021) including account holder’s name, account number and sort code;
5.14 The conversations you hold with other members of the Virtual Tenement in the Discussion section.
6. How Do We Use Your Data?
6.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the UK GDPR at all times. For more details on security see section 7, below.
6.2 Our use of personal data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of personal data (e.g. by subscribing to emails or for delivery of the Services), or because it is in Our legitimate interests. Specifically, We may use personal data for the following purposes:
6.1.1 Providing and managing your Account;
6.1.2 Providing and managing your access to the Services;
6.1.3 Supplying Our products and/ or services to you (please note that We require your personal data in order to enter into a contract with you);
6.1.4 Replying to emails from you;
6.1.5 Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by clicking on the link at the bottom of the email;
6.1.6 Market research;
6.1.7 Analysing your use of Our Services and gathering feedback to enable Us to continually improve Our Services and your user experience;
6.2 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on Our products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the UK GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any variation, supplementation replacement, modification, amendment or re-enactment thereof.
6.3 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it; however this may adversely affect the delivery, use and function of the Services.
6.4 We do not keep personal data for any longer than is necessary in light of the reason(s) for which it was first collected.
7. How and Where Do We Store Your Data?
7.1 We only keep personal data for as long as We need to in order to use it as described above in section 6, and/or for as long as We have your permission to keep it.
7.2 Some or all of your data may be stored or transferred outside of the EEA. You are deemed to accept and agree to this by using the App and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements or in the United States of America, Privacy Shield. Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data.
8. Do We Share Your Data?
8.1 We may share your data with other companies in Our group for administrative and internal management.
8.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
8.3 We may compile statistics about the use of products and services including the Services including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you or your employees [or customers]. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
8.4 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
9. What Happens If Our Business Changes Hands?
9.1 We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Any personal data that you have provided will, where it is relevant to any part of Our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by Us.
9.2 In the event that any of your data is to be transferred in such a manner, you may be contacted in advance and informed of the changes. When contacted you may not, however, be given the choice to have your data deleted or withheld from the new owner or controller.
10. How Can You Control Your Data?
10.1 When you submit personal data to us, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
10.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
11. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at privacy@novoville.com or using the contact details below in section 13.
12. Our Use of Cookies
12.1 Our cookie policy can be found here: https://www.novoville.com/cookie-policy
13. Contacting Us
If you have any questions about Our Services or this Privacy Policy, please contact Us by email at srhelpdesk@novoville.com, by telephone on 0131 364 4545 or by post at Unit 102, 12 South Bridge, Edinburgh, Eh1 1DD. Please ensure that your query is clear, particularly if it is a request for information about the data We hold about you (as under section 11, above).
14. Changes to Our Privacy Policy
We may change this Privacy Policy from time to time (for example, if the law changes). Any changes will be immediately posted on Our Services and you will be deemed to have accepted the terms of the Privacy Policy on your first use of Our Services following the alterations. We recommend that you check this page regularly to keep up-to-date.