NOVOSHIELD PRIVACY POLICY

Last Updated: November 30, 2023

This privacy policy (“Privacy Policy”) governs how we, novoShield Ltd. (“NovoShield”, “we”, “our” or “us”) use, collect and store Personal Information (defined below) we collect or receive from or about you (“User”, “you”). 

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory rights, including your rights to a remedy or other means of enforcement. You are not legally obligated to provide us Personal Information and providing us Personal Information is at your own free will. 

NovoShield’s mission is to detect and warn users against malicious websites. NovoShield provide its services via a mobile app (“App”). NovoShield has an informative website (https://www.novoshield.com/) (“Website”, together with the App, the “Services”). 

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy.  If we implement material changes in the way we use your information, in a manner that is different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means and take any additional steps as required by applicable law.

You are not legally obligated to provide us Personal Information, and you hereby confirm that providing us Personal Information is at your own free will. If you do not agree to this Privacy Policy, please do not access or otherwise use the Services. We reserve the right, at our discretion, to change this Privacy Policy at any time. Such change will be effective ten (10) days following posting of the revised Privacy Policy on the Site, and your continued use of the Services thereafter means that you accept those changes.

“Personal Information” means any information that can be used, alone or together with other information, to uniquely identify any living human being and any information deemed as Personally Identifiable Information by privacy laws.

1.   WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED 

  1. When you browse or visit our Website: 
  1. Personal Information we collect:
  • Information You Provide Directly to Us including, without limitation, in the context of the Website. We collect Personal Information that you voluntarily provide, for example: your full name, email address, telephone number, company name, as well as any other information that you decide to provide us with when you make use of our Website (for example: when you communicate with NovoShield or complete a Website form)
  • Automatic Data Collection. We automatically collect certain information through your use of the Website, such as your, cookie identifiers and other device identifiers that are automatically assigned to your device, browser type and language, hardware type, operating system, internet service provider and other information about actions taken through the use of the Website. 
  1. We process information for the following purposes:
  • To provide you with the NovoShield Website. NovoShield will use your information to provide its Website, including: (i) to respond to your questions, comments, and other requests for customer support, or information, including information about potential or future services; (ii) to provide and manage the Website; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) to generally administer the Website.
  • To Market the Website. NovoShield may use information to market the Website. Such use includes (i) notifying you about offers and services that may be of interest to you, including, without limitation, marketing communications; (ii) conducting market research; (iii) developing and marketing new products and services; (iv) to measure interest in the Website; (v) other purposes disclosed at the time you provide information; and (vi) and as you otherwise consent; 
  • Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. 
  • Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Website, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Website. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Website. If you would like to opt out of the Technologies we employ on the Website, you may do so by blocking, deleting, or disabling them as your browser or device permits.
  1. Legal basis:
    • Legitimate Interest. (e.g., essential cookies required for the operation of the Website; to respond to a query sent by you);
    • Consent. (e.g., non-essential cookies, to the extent required under applicable law; marketing, if required under applicable law); and
    • Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract and/or legitimate interest (e.g., respond to a query sent by you).
  2. Consequences of not providing the Personal Information:
    • Certain Website features may not be available.
    • We cannot receive and answer your questions; provide further information to the extent requested; respond to your questions, comments, and other requests for ongoing customer assistance, technical support and maintenance of the Website and to send you product-related communications; better understand your needs, both on an aggregated and individualized basis, in order to further develop, customize and improve our Website based on users’ preferences, experiences and difficulties; to communicate with you and contact you to obtain feedback from you regarding the Website and demo; establish a business relationship with you. In addition, we won’t be able to send you marketing communications (subject to your consent).
  • When you use our Services: 
  1.  Personal Information we collect:
  • Information You Provide Directly to Us. We collect Personal Information that you voluntarily provide when you register and make use of our Services (for example when you create an account and log-in); 
  • Product data: We collect information on whether the URLs you visit have any form of malware or if it is otherwise suspected to be malicious or deceptive, in such case, the URL might be blocked by NovoShield. When you use the free version of our product with ads, your search queries in the browser may also be collected. For the avoidance of doubt, product data shall not be considered Personal Information.
  • Automatic Data Collection. We automatically collect certain Technologies information through your use of the Services, such as your, cookie identifiers, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such NovoShield ads were displayed, the URL from the referring website, downloads and installations of NovoShield App and other device identifiers that are automatically assigned to your device, browser type and language, hardware type, operating system, internet service provider and other information about actions taken through the use of the Services. 
  1. We process the information for the following purposes:
  • To allow you to download our App, create an account, log in and make use of the Services.  NovoShield will use your information to provide its Services, including: (i) allowing you to create and log-in to your account; (ii) allowing you to make use of the Services; (iii) providing you support and maintenance, (iv) for internal quality control purposes; (v) to generally administer the Services.
  • To Market the Services. NovoShield may use information to market the Services. Such use includes (i) notifying you about offers and services that may be of interest to you, including, without limitation, marketing communications; (ii) conducting market research; (iii) developing and marketing new products and services; (iv) to measure interest in the Services; (v) other purposes disclosed at the time you provide information; and (vi) and as you otherwise consent. 
  • Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent and prosecuting fraud or other illegal activity; to identify and repair errors; to conduct audits; and for security purposes. Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. 
  • De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Information and further use it for internal and external purposes, including, without limitation, to analyze and improve the Services (including through the use of artificial intelligence) and for research purposes. We may use this anonymous or de-identified information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them and/or to develop new product features and improve existing offerings).
  • Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, use Technologies to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your device that allow us to record certain pieces of information whenever you visit or interact with the Services. If you would like to opt out of the Technologies we employ on the Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.
  1. Legal basis:
    • Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract; and
    • Legitimate interest (e.g. to allow you to create an account in our App); or 
    • Consent (for marketing, if required under applicable law).
  2. Consequences of not providing the Personal Information:
    • We cannot allow you to register for and log-in to our App; to provide you with the Services and perform the relevant agreement with our customers; for monitoring and security purposes, including for user authentication, logging and debugging; to provide support (e.g. ticketing and chat functions); improve our Services; allow you to send us feedback, reports and additional features; conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve our Services, develop new features, and conduct audits and troubleshooting activities; customize your experience in our App; or improve the management and administration of our business and maintain compliancy with our internal policies and procedures.
  • When you attend our events or webinars, when we exchange business cards and/or when you contact us though our social media pages 
    1. Personal Information we collect:
  • Information you provide directly to us: Full name, email address, job title, company name, any other data you decide to provide/supply when contacting us through our social media channels, when registering for a webinar or when we exchange business cards.
  1. We process the information for the following purposes:
    • To answer your questions about Novoshield or to fulfil other requests you send us through said channels. 
    • To establish a business relationship with you.
  2. Legal basis:
    • Legitimate Interest. (e.g., to answer your questions);
    • Consent. (depending on the context, the consent you give us to establish a business connection with you or to send you marketing communications); and
    • Performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract and/or legitimate interest (e.g., respond to a query sent by you and to communicate with you for pre-contractual discussions).
  3. Consequences of not providing the Personal Information:
    • We will not be able to answer your questions or queries about Novoshield, to fulfill your requests or to establish a business relationship with you. 

Finally, please note that some of the abovementioned Personal Information will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Information may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims. In certain cases, we may or will anonymize or de-identify your Personal Information and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). 


2.   HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION 

  1. Security. We have implemented and maintain reasonable technical, organizational and security measures designed to protect your information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
  2. Retention of your information. We store your Personal Information for as long as such Personal Information is necessary in accordance with the purpose for which we collected it, and as long as necessary to fulfill your requests or inquiries or provide services or until we proactively delete it or you send a valid deletion request. In certain circumstances we may store your Personal Information for longer periods of time, for example:
  • Where we are required to do so in accordance with legal, regulatory, tax or accounting requirements; or
  • For us to have an accurate record of your dealings with us in the event of any complaints or challenges; or
  • If we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.


3.   HOW WE SHARE YOUR PERSONAL INFORMATION 

(i) In order to perform our contractual and other legal responsibilities or purposes, we share, from time to time, your Personal Information with third parties and affiliated companies. 

a) We may use third party service providers to process your information for the purposes outlined above, including, without limitation: 

  • With cloud service providers for hosting purposes;
  • With websites and web content creation platforms in order to help us manage our Website; 
  • With email providers, marketing, CRM, other similar tool providers; and
  • With our business partners and/or advertisers; and
  • With analytic companies, in order to help us understand and analyze information we collect in accordance with this policy. 


b) To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures and to protect the safety, security, and integrity of NovoShield, our Services, customers, employees, property, and the public.

c) If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your information to such third party (whether actual or potential) in connection with the foregoing events (including, without limitation, our current or potential investors). In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your information in connection with the foregoing events.
d) Where you have otherwise provided your consent to us for sharing or transferring your information.

(ii) If we transfer Personal Information:

Where we transfer your Personal Information outside of Novoshield, we will use commercially reasonable efforts to obtain contractual commitments from them to protect your Personal Information. See below the details of some of our major vendors implemented in the context of the Services: Github, Sentry and Google Cloud Platform.

(iii) If we transfer Personal Information to a country other than your own:
We and third party service providers that store or process Personal Information on our behalf are contractually committed to ensure that Personal Information receives an adequate level of protection. If you are located in the EEA where we transfer your Personal Information outside of the EEA (for example, to third party service providers for the purposes listed above), we will generally rely on either:

  • Adequacy Decisions adopted by the European Commission under Article 45 of the GDPR; or
  • The Standard Contractual Clauses issued by the European Commission (or applicable mechanism adopted by the relevant supervisory and/or competent authority).  


4.   YOUR PRIVACY RIGHTS

  • Rights: in some jurisdictions, in particular those located within the European Union (the “EU“) or within the European Economic Area (the “EEA“) or the United Kingdom (“UK“), you may be afforded specific rights regarding your Personal Information. Subject to such eligibility, you may have the following rights to:
  1. Access Personal Information held about you. Your right of access may normally be exercised free of charge, however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
  2. Request a rectification of your Personal Information where the information we hold about you is incorrect, incomplete, inaccurate or misleading;
  3. Request the erasure of your Personal Information in certain circumstances, such as where processing is no longer necessary for the purpose it was originally collected for, and there is no compelling reason for us to continue to process or store it. Please note that there may be circumstances in which we are required to retain your Personal Information, for example for the establishment, exercise or defense of legal claims;
  4. Object to, or request restriction, of the processing of your Personal Information;
  5. Object an automated decision-making (including profiling) in certain circumstances.
  6. Withdraw your consent at any time. Please note that there may be circumstances in which we are entitled to continue processing your Personal Information, in particular if the processing is required to meet our legal and regulatory obligations. Also, please  note that the withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal;
  7. Receive your Personal Information, or ask us to transfer it to another organization that you have provided to us (data portability),;
  8. Request certain details of the basis on which your Personal Information is transferred outside the EEA, but data transfer agreements and/or other details may need to be partially redacted for reasons of commercial confidentiality; 
  9. File a complaint to the relevant supervisory authority regarding any claim that may arise due to our data protection and privacy practices. We ask that you please attempt to resolve any issues with us before you contact your local supervisory authority and/or relevant institution; and/or
  10. If you may have certain additional rights under local privacy laws applicable in your jurisdiction. To the extent such privacy laws apply to you, we will respect your rights and comply with such laws.
  • If you would like to access, delete or correct any of your Personal Information, you shall submit a request by sending an email to support@novoshield.com. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we need further information in order to fulfil your request. Please make sure that your request includes adequate details so we can process your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than requested, we will address your request to the maximum extent possible, all in accordance with applicable law.  
  • Marketing emails – opt-out: if you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails, and we will process your request within a reasonable time after receipt. 



5.   USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any information to us without the involvement of a parent or a guardian. In the event that we become aware that you provide information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at support@novoshield.com.


6.   INTERACTION WITH THIRD PARTY PRODUCTS

We enable you to interact with third party websites, mobile software applications and products or services that are not owned, or controlled, by us (each, a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.


7.   ANALYTIC TOOLS 


  • Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website, what pages they visit when they do so, and what other websites they used prior to coming to this Website. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at http://www.google.com/policies/privacy/. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at http://www.google.com/policies/privacy/partners/. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/. 
  • AppsFlyer. We use a tool called “AppsFlyer”, a mobile attribution and marketing analytics platform to understand the use of our Services. AppsFlyer is exposed to the following data: clicks on NovoShield ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or Application from which such ads were displayed, the URL from the referring website, downloads and installations of App. AppsFlyer’s terms of use (available at https://www.appsflyer.com/terms-of-use/) and privacy policy (available at https://www.appsflyer.com/privacy-policy/) also apply to the use of AppsFlyer.
  • Mixpanel. We collect personal information such as your email address and your user activity through the use of Mixpanel. Mixpanel’s ability to use and share information is governed by the Mixpanel Terms of Use, available at https://mixpanel.com/terms/, and the Mixpanel Privacy Policy, available at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s services by clicking on the following link: https://mixpanel.com/optout/we.
  • Advertising Partners. Through our Services, we allow third party advertising partners to set technologies and other tracking tools to collect information regarding your activities and your device (e.g., the URL from the referring website, downloads and installations of NovoShield App, mobile identifiers, page(s) visited, location, time of day). We also combine and share such information and other information with third party advertising partners (such as Microsoft Bing and/or Yahoo). These advertising partners will use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit third party websites within their networks. This practice is commonly referred to as “interest-based advertising” or “online behavioral advertising. We allow access to other data collected by the services to share information that may be useful, relevant, valuable or otherwise of interest to you. If you prefer not to share your Personal Information with third party advertising partners, you may let us know. 
  • We reserve the right to remove or add new analytic tools, cookies, pixels and other tracking technologies.


8.   SPECIFIC PROVISIONS APPLICABLE UNDER CALIFORNIA PRIVACY LAW

  • California Privacy Rights: California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of information to third parties for their direct marketing purposes. To make such a request, please send an email to support@novoshield.com. Please note that we are only required to respond to one request per customer each year.
  • California Do Not Track Notice: Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers.  Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers, but we may allow third parties, such as companies that provide us with analytics tools, to collect personally identifiable information about an individual consumer’s online activities over time and across different web sites when a consumer uses the Services.


9.   CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at support@novoshield.com, or by registered mail sent to our offices at: 
651 N Broad St, Suite 206,
Middletown, Delaware, 19709
 

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