Last Modified: March 3rd, 2021
1. What Information Do We Collect and for What Purpose?
The categories of information we collect can include:
- Information you provide to us directly. We will collect business and financial information as a prerequisite to you being authorized to use the Services to open an account. The collection of business information may include, but is not limited to, your business name, tax identification number, business address, business telephone number, business bank account information, business related documentation, and telephone number, or email address. In addition, the beneficial owners of the Company will be required to provide personal information including, but not limited to: name, personal address, date of birth, social security number (SSN), phone number, a photo of their passport or driver’s license. Additional information will be requested at account opening and may be requested throughout the life of the account relationship to meet regulatory and legal requirements. If you choose to provide us with personal information, business information, financial information, and financial data, you consent to the transfer and storage of that information on our servers located within the United States. We may also collect any communications between you and Novel and any other information you provide to Novel.
- Data collected through the use of the Service. We collect information about how you use the Service, your actions on the Service, and your communications with us through the Services. If you need to update your permissions, you can do so by emailing us at email@example.com. Please remember that Novel may, but has no obligation to, monitor, record, and store information you provide to Novel and information we collect about you in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Service, you consent to the recording, storage and disclosure of such communications you send or receive for these purposes.
- USA Patriot Act. To help the government fight the funding of terrorism and money laundering activities, the USA PATRIOT Act, a Federal law, requires financial institutions to obtain, verify, and record information that identifies each business that opens an account and the personal information of its owners or representatives. Therefore, when applying for an account, we, on behalf of financial institution(s), will ask for details about the personally identifiable information about the business owners, administrators, and/or authorized users such as: name, address, date of birth, SSN, phone number, and other information that will allow financial institution(s) to confirm your identity. We may also ask for details about the business owner’s, administrators’, and/or authorized user’s driver’s license number, passport information, or other identifying information. We may also collect photos, text, videos, or any other information you upload and/or send through our Services.
- Information Collected From Your Device. When you use our Services, we may collect information from your computer or mobile device, such as the unique identification number, the model, operating system and version, your browser type and version, the presence of any device, operating system, or browser add-ons, the times you access our Services, the locations from where you access our Services (attributed based on your IP address, the page you visited before navigating to our Services, and your mobile device’s location services), and your stored contacts.
We use this information to operate, maintain, and provide to you the features and functionality of the Service, as well as to communicate directly with you, such as to send you email messages and push notifications. We may also send you Service-related emails or messages (e.g., account verification, change or updates to features of the Service, technical and security notices). For more information about your communication preferences, see "Control Over Your Information" below.
We, and our third party partners, automatically collect certain types of usage information when you visit our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, file information and similar technology (collectively, "tracking technologies"). "Cookies" are small packets of data that a website stores on your computer’s or mobile device’s hard drive (or other storage medium) so that your computer will "remember" information about your use. We use both first and third party session cookies and persistent cookies. Session cookies make it easier for you to navigate our Services and expire when you close the Services. Persistent cookies remain on your device for an extended period of time or until you delete them. Persistent cookies enable us to track and target the interests of our visitors to personalize the experience on our Services.
Through the tracking technologies we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account, and other such information. We also collect information about the way you use our Services, for example, the site from which you came and the site to which you are going when you leave our website, the pages you visit, the links you click, how frequently you access the Services, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, and other actions you take on the Services. When you access our Services from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers ("IDFA"), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address.
- For Google Analytics, please visit: https://www.google.com/analytics
- For Mixpanel, please visit: https://mixpanel.com/legal/privacy-policy/
- For Segment, please visit: https://segment.com/legal/privacy/
Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.
We use or may use the data collected through tracking technologies to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Service; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our Services; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Services, as some features and services on our Services may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it. Note that deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. You can learn more about Flash objects - including how to manage privacy and storage settings for Flash cookies – on Adobe’s website. If you choose to delete Flash objects from our sites, then you may not be able to access and use all or part of the Services or benefit from the information and services offered.
3. Sharing of Your Information
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the "Control Over Your Information" section below.
We may share your personal information with:
- Third parties at your request.
- Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include providing the following services: identifying and serving targeted advertisements, tax and accounting, web hosting, customer and support services, or analytic services;
- Third parties to investigate fraud inside or outside our Services;
- Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual.
4. Control Over Your Information
Profile and Data Sharing Settings. You may update your profile information, such as your user name and profile photo, and may change some of your data sharing preferences by emailing us at firstname.lastname@example.org
How to control your communications preferences: You can stop receiving promotional email communications from us by clicking on the "unsubscribe link" provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
Modifying or deleting your information: If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our website or publicly displayed content, you can contact us directly at email@example.com. We may not be able to modify or delete your information in all circumstances.
5. Site Data
In an ongoing effort to better understand our users and the Services, we might analyze Site Data to operate, maintain, manage, and improve the Services. This Site Data does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose Site Data and aggregate user statistics to describe the Services to current and prospective business partners and to other third parties for other lawful purposes.
6. Third Party Tracking and Online Advertising
We may share, or we may permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our website over time so that they may play or display ads that may be relevant to your interests on our Services as well as on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, click stream information, browser type, time and date you visited the Services, and other information. This information is used to display targeted ads on or through our Services or on other websites or apps, including on Facebook. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. As noted above, depending on your browser or mobile device, you may be able set your browser to delete or notify you of cookies and other tracking technology by actively managing the settings on your browser or mobile device. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting "limit ad tracking" (iOS) or "opt-out of interest based ads" (Android). To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the Digital Advertising Alliance’s resources at www.aboutads.info/choices, and you may also adjust your ad preferences through your Facebook settings. You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app. If you have any questions about opting out of the collection of cookies and other tracking/recording tools, you can contact us directly at firstname.lastname@example.org.
Facebook Custom Audience Ads. We may work with Facebook to display interest-based ads to you or to your friends on Facebook through a tool offered by Facebook called the Custom Audience Tool. This tool allows us to personalize our ads based on you or your friends’ experience on our Services in order to provide ads tailored for each specific recipient. We do not share personal information about your activities on our Services with Facebook, but we share a hashed email address or phone number which permits Facebook to identify our advertising audience based on the information that Facebook collects from its users. If you do not want to receive interest-based ads on Facebook, you can adjust your ad preferences through your Facebook settings. If you do not want us to use your content to personalize advertising that we direct to your friends on Facebook, you may email us at email@example.com.
7. How We Store and Protect Your Information
Keeping your information safe: We care about the security of your information and use commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through our Services. However, no security system is impenetrable and we cannot guarantee the security of our systems or the systems of the third parties with which we may share your information, nor can we guarantee that the information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.z
8. Children’s Privacy
Novel does not knowingly collect or solicit any information from anyone under the age of 13 through our Services. If you are under 13, please do not give us any personal information. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
9. Links to Other Web Sites and Services
The Services may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.
10. California Privacy Rights
Pursuant to Section 1798.83 of the California Civil Code, residents of California have the right to obtain certain information about the types of personal information that companies with whom they have an established business relationship (and that are not otherwise exempt) have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties. If you wish to submit a request pursuant to Section 1798.83, please contact Novel via email at email@example.com.
11. How to Contact Us