{"id":4015,"date":"2020-10-13T06:07:42","date_gmt":"2020-10-13T05:07:42","guid":{"rendered":"https:\/\/novellusfinance.com\/?page_id=4015"},"modified":"2024-04-17T12:49:31","modified_gmt":"2024-04-17T11:49:31","slug":"privacy-statement","status":"publish","type":"page","link":"https:\/\/novellusfinance.com\/ie\/privacy-statement\/","title":{"rendered":"Privacy Statement"},"content":{"rendered":"\t\t
Novellus Limited (together with its affiliated companies – \u201cNovellus<\/strong>\u201d, \u201cwe<\/strong>\u201d, \u201cour<\/strong>\u201d or \u201cus<\/strong>\u201d) puts great efforts in making sure that your personal data is kept safe and used properly and responsibly. We are an experienced private lender located at Novellus Finance, 100 St. Stephen’s Green, Dublin, D02 EP84. Our dedicated team have vast experience in lending to the UK and Ireland property markets. We provide loans secured against a wide range of assets including (but not limited to) buy to let and commercial properties, land (with or without planning) and properties requiring refurbishment or change of use (our \u201cServices<\/strong>\u201d).<\/p>\n This Privacy Policy describes how we collect, store, use and disclose the following types of personal data:<\/p>\n Specifically, this Privacy Policy describes our practices regarding the following with respect to our Services:<\/p>\n If you are Borrower, Introducer, Site visitor (\u201cyou\u201d), please read this Privacy Policy carefully and make sure that you fully understand and agree to it.<\/strong><\/p>\n You are not legally required to provide us with any personal data, and you are free to do so or not to do so. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please refrain from accessing, using or registering to our Services or sending us your personal data.<\/p>\n (i) Borrower Data.<\/strong> We may collect the following types of personal data relating to our customers (\u201cBorrower Data<\/strong>\u201d):<\/p>\n (ii) Introducer Data<\/strong>: we may engage with Introducers, and receive information relating to potential Borrowers form them.<\/p>\n We may collect and generate the following types of personal data relating to Introducers (\u201cIntroducer Data<\/strong>\u201d):<\/p>\n (iii) Sites Usage, CRM & Prospective Client Data, and Human Resources Data<\/strong>. We may collect and generate the following types of personal data concerning our website visitors, partners Introducers, Borrowers and prospective Borrowers (collectively, \u201cNon-Services Related Data<\/strong>\u201d):<\/p>\n We collect the above Non-Services Related Data either automatically, through the data subject\u2019s interaction with us or with our Sites or Services; or through third party services, social media, analytics tools, events we organize or participate in, and other business initiatives.<\/p>\n To the extent that any of the above-mentioned data pertains only to a non-human entity (e.g., the phone number or bank account of a company or business), we will not regard it as \u201cpersonal data\u201d and this Privacy Policy will not apply to it.<\/p>\n We use personal data as necessary for the facilitation and performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Services; providing customer service and technical support; and protecting and securing our clients, partners, ourselves and our Service.<\/p>\n Further detail about the legal basis on which we rely for each type of processing can be found in the table below.<\/p>\n<\/div>\n \u25aa Performance of a contract.<\/p>\n \u25aa Legitimate Interest<\/p>\n<\/td>\n<\/tr>\n \u25aa Legitimate Interest<\/p>\n \u25aa Consent<\/p>\n<\/td>\n<\/tr>\n \u25aa Legitimate Interest<\/p>\n \u25aa Compliance with legal obligations<\/p>\n<\/td>\n<\/tr>\n \u25aa Legitimate Interest<\/p>\n \u25aa Performance of a Contract<\/p>\n<\/td>\n<\/tr>\n \u25aa Legitimate Interest<\/p>\n \u25aa Performance of a Contract<\/p>\n<\/td>\n<\/tr>\n \u25aa Legitimate Interest<\/p>\n \u25aa Consent<\/p>\n<\/td>\n<\/tr>\n \u25aa Legitimate Interest<\/p>\n \u25aa Consent<\/p>\n<\/td>\n<\/tr>\n \u25aa Legitimate Interest<\/p>\n \u25aa Performance of a Contract<\/p>\n \u25aa Consent<\/p>\n<\/td>\n<\/tr>\n \u25aa Legitimate Interest<\/p>\n \u25aa Performance of a Contract<\/p>\n \u25aa Compliance with legal obligations<\/p>\n<\/td>\n<\/tr>\n If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data (in general, or specifically with respect to the types of personal data you expect or elect to process or have processed by or via the Services, e.g. \u2018special categories\u2019 under the UK GDPR), your acceptance of our Privacy Notice and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed in this Policy. If you wish to revoke your consent, please contact us at dpo@novellusfinance.com<\/u>.<\/p>\n Data Location<\/strong>: Your personal data may be maintained, processed and stored by us and our authorized Service Providers (defined below) in multiple locations, including in the United States, Europe and the United Kingdom, as reasonably necessary for the proper performance and delivery of our Services, or as may be required by law.<\/p>\n While privacy laws may vary between jurisdictions, Novellus and its Service Providers are each committed to protect personal data in accordance with this Privacy Policy, customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such data is transferred. These may include transferring your personal data to a country which is considered to provide an \u2018adequate\u2019 level of protection to your personal data, or putting in place standard contractual clauses and additional security measures to ensure your personal data is protected.<\/p>\n Data Retention<\/strong>: We will retain your personal data for as long as it is reasonably necessary for us to maintain our relationship with you and provide you with our Services and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from, or defend, any potential or actual disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our contractual terms and data retention policy. Generally speaking, we will hold Borrower Data (and any data related to financing we have provided) for a period of 7 years, and 10 years for KYC data, following the end of a contract.<\/p>\n Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at dpo@novellusfinance.com<\/u>.<\/p>\n Legal Compliance<\/strong>: In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement) and where such disclosure is necessary to comply with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; or (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our Services.<\/p>\n We engage selected third-party companies and individuals to perform services complementary to our own. Such service providers hosting and server co-location services, communications and content delivery networks (\u201cCDNs\u201d), billing and payment processing services, data and cyber security services, fraud detection and AML prevention services, web analytics, e-mail, monitoring and analytics services, search engine optimization services, document storage (e.g. SharePoint), collaboration and backup (e.g. Dropbox) services, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, \u201cService Providers<\/strong>\u201c).<\/p>\n These Service Providers may have access to your personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use it for such limited purposes as determined in our agreements with them. Should you decide to directly engage with any of our Service Providers, please note that such engagement is beyond the scope of our Terms and Conditions and Privacy Policy, and will therefore be covered by our Service Provider\u2019s terms and policies.<\/p>\n Third Party Websites and Services<\/strong>: Our Services may also include links to third-party websites, and integrations with third party services. These websites and third-party services, and any information you process, submit, transmit or otherwise use with such websites and third-party services, are governed by the third party\u2019s terms and privacy practices and policies, and not by this Privacy Policy. We encourage you to carefully read the terms and privacy policies of such website and third-party services.<\/p>\n Protecting Rights and Safety<\/strong>: We may share your personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Novellus, any of our users, partners or clients, or any members of the general public.<\/p>\n Our Subsidiaries and Affiliated Companies<\/strong>: We may share personal data internally within our group of companies, for the purposes described in this Privacy Policy. In addition, should we or any of our subsidiaries or affiliates undergo, or propose to undergo, any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of our assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail.<\/p>\n For the avoidance of doubt, we may share your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.<\/p>\n Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are \u201cSession Cookies\u201d. Some last for longer periods and called \u201cPersistent Cookies\u201d. We use both types.<\/p>\n We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Services. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Services\u2019 features and tools.<\/p>\n Every browser allows you to manage your cookies preferences. Please bear in mind that disabling cookies may complicate or even prevent you from using certain parts of features of the Services.<\/p>\n\n
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1. Data Collection<\/h2>\n
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2. Data Uses<\/h2>\n
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\n Borrower & Introducer Data<\/strong><\/td>\n<\/tr>\n \n Purpose<\/strong><\/td>\n Legal basis for processing<\/strong><\/td>\n<\/tr>\n \n Provision of our Services<\/td>\n \n \n To comply with applicable laws and regulations<\/td>\n \u25aa Compliance with a legal obligation<\/td>\n<\/tr>\n \n Sending marketing communications<\/td>\n \n \n To support and enhance our data security measures, including for preventing and mitigating the risks of fraud, money laundering, error or any illegal or prohibited activity.<\/td>\n \n \n To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective Services, conduct research, or for any other purpose<\/td>\n \u25aa Legitimate Interest<\/td>\n<\/tr>\n \n To comply with applicable laws and regulations<\/td>\n Compliance with legal obligations<\/td>\n<\/tr>\n \n Non-Services Related Data<\/strong><\/td>\n<\/tr>\n \n Purpose<\/strong><\/td>\n Legal basis for processing<\/strong><\/td>\n<\/tr>\n \n To facilitate, operate, and provide our Service<\/td>\n \n \n To provide our visitors, Users, Borrowers and Introducers with assistance and support.<\/td>\n \n \n To evaluate and develop new features, technologies, and improvements of our Services.<\/td>\n \u25aa Legitimate Interest<\/td>\n<\/tr>\n \n To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications.<\/td>\n \u25aa Legitimate Interest<\/td>\n<\/tr>\n \n To contact our Site visitors, Users and Borrowers (whether existing or prospective) with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them.<\/td>\n \n \n To facilitate, sponsor and offer certain events, contests and promotions.<\/td>\n \n \n To publish your feedback and submissions to our Sites, public forums and blogs.<\/td>\n \n \n To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity.<\/td>\n \u25aa Legitimate Interest<\/td>\n<\/tr>\n \n To create aggregated data, inferred non-personal data or anonymized or pseudonymized data (de-identified data), which we or our business partners may use to provide and improve our respective services, conduct research, or for any other purpose.<\/td>\n \n \n To comply with applicable laws and regulations.<\/td>\n \u25aa Compliance with legal obligations<\/td>\n<\/tr>\n<\/tbody>\n<\/table>\n 3. Data Location & Retention<\/h2>\n
4. Data Sharing<\/h2>\n
5. Cookies and Tracking Technologies<\/h2>\n