Privacy Policy

Updated on : 1 April 2024

Novus Loyalty (Novus) (including Clavax LLC and affiliated entities globally) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and store your personal information.

1. Summary of Key Points

Customers of Merchant Partners - When providing services to merchants (such as operating loyalty programs), we may process your personal information on their behalf. In such cases, please refer to the merchant's privacy policy. When you interact directly with Novus, such as creating a Novus Wallet, we act as a data controller.

Merchants and Associated Users - Most information collected from merchants relates to business operations. Any personal information collected is used to support and improve our services.

Website and Support Users - We collect personal details through direct input, cookies, and similar technologies to enhance your experience and improve our services.

Employees, Contractors, and Job Applicants - Personal information provided during recruitment or employment is used for hiring decisions and employee management. Employees may be subject to an additional privacy policy.

2. Scope of This Policy

  • What's Covered
  • This policy applies to all personal information we collect, use, disclose, or store when you use our services or apply for employment. This includes data related to the Novus Wallet and rewards points aggregated across merchants.

  • What's Not Covered
    • Merchant-Controlled Data: For information handled on behalf of merchants, contact the respective merchant. If you use the Novus Wallet, both Novus and the merchant may hold and manage your rewards data.
    • Non-Personal Data: Business contact details and anonymized data are not considered personal information under this policy.
    • Jurisdictional Exceptions: Our privacy practices may be tailored to comply with the legal requirements of specific jurisdictions where we operate.

3. Policy Updates

We may update this policy periodically. Notification methods include website updates or direct communication. Continued use of Novus services after updates constitutes acceptance of the new terms.

How We Use Personal Information

  • Communicate with you
  • Track transactions and loyalty rewards
  • Operate, improve, and test our services
  • Perform analytics and reporting
  • Market and promote our services
  • Deliver relevant information to merchants and customers
  • Ensure security and fraud prevention
  • Comply with legal obligations

We may request your express consent where legally required, such as when using cookies or signing up for services.

4. Information We Collect

Category Example Data Purpose
Merchant Customers Communications, preferences, contact info, transactions Service delivery, support, marketing
Merchants & Their Users Account details, usage info, communications Account management, service improvement, marketing
Website & Support Users Email, usage data, IP, browser info Enhance website experience, communicate, marketing
Employees & Applicants Job application info, communications Hiring decisions, employment-related purposes

5. Sharing Personal Information

We do not sell your personal information. However, we may share your data with:

Recipient Purpose
Service Providers Marketing, support, hosting, analytics, platform services
Merchants Provide analytics and usage insights
Business Acquirers During mergers, acquisitions, or restructuring
Law Enforcement When legally required or necessary for protection and compliance

Note: Once disclosed, personal information is governed by the recipient's policies.

6. International Data Transfers

Your data may be stored or processed outside your country, including in Canada and the U.S., where data protection laws may differ. Local authorities may access your data as per applicable laws.

7. Tracking Technologies

  • Cookies: We use session and persistent cookies to operate and analyze our site.
  • IP Address: Stored for up to 24 months.
  • Web Beacons: Used in emails to track engagement.
  • Do Not Track: Our website does not currently respond to DNT signals.

8. Your Privacy Rights

You may have the right to:

  • Access or correct your personal information
  • Object to or restrict processing
  • Withdraw consent
  • Request erasure, subject to retention obligations

Requests may require identity verification. In some cases, requests may be denied, or fees may apply. Merchants control most customer data—contact them for related inquiries.

9. Data Retention

We retain personal information as long as necessary for business, legal, or historical purposes. Data may be anonymized instead of deleted.

10. Security Measures

We implement safeguards appropriate to the sensitivity of your information. However, no digital transmission is entirely secure.

11. Additional Questions & Contact Information

  • Marketing Communications
  • You may opt-out of promotional emails via the instructions provided or by emailing info@novusloyalty.com. Merchant-controlled communications must be managed through the merchant.

  • Children's Data
  • We only collect data from children under 13 with parental consent. Contact us if you believe this has occurred without consent.

  • Third-Party Data Sources
  • We may receive your information from third parties. Those parties are responsible for ensuring lawful disclosure.

  • Third-Party Invitations
  • If you provide another person's information (e.g., to invite them), ensure you have their consent. We will use it only to fulfill your request.

  • External Sites & Services
  • Links to third-party services are provided for convenience. Their privacy practices apply - review their policies before use.

  • Merchants' Privacy Obligations
  • Merchants using our platform must comply with applicable privacy laws and obtain required consents.

12. Contact Us

info@novusloyalty.com

For complaints, concerns, or requests regarding your personal data, please contact our Privacy Officer.

If your concern involves a merchant, contact them first. If unresolved, you may reach out to us, though we may be limited in our ability to respond.

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