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Privacy Policy

1. Definitions In this Privacy Statement the following terms are defined as follows: 

1.1 Novaya: the legal entity Novaya Belgium NV with registered office at Belgium, 8710 Wielsbeke, Grote Molstenstraat 21, and registered with the Crossroads Bank for Enterprises under the number 0437.860.275;

contact details:

the legal entity Novaya Solutions BV, with registered office at Belgium, 8710 Wielsbeke, Grote Molstenstraat 21, and registered with the Belgian Crossroads Bank for Enterprises under the number 0464.230.023.


contact details:

the legal entity Novaya Iberia S.A.U., with registered office at Spain, 50100 La Almunia de Doña Godina (Zaragoza), Pol. Ind. La Cuesta II, s/n and with company number A50970946.

contact details:

  • adress: Pol. Ind. La Cuesta II, s/n, 50100 La Amunia de Doña Godina
  • e-mail : info@novaya-comfort.com
  • fax : +34 976 811 747
  • telephone : +34 976 811 749

 

the legal entity Novaya Asia Pacific Pte Ltd, with registered office at Singapore, 338729, #02-58 CT Hub 2, 114 Lavender Street, and with company number 200107017E

contact details:

  • adress : #02-58 CT Hub 2, 114 Lavender Street, 338729 Singapore
  • e-mail : info@novaya-comfort.com
  • fax : +65 6234 3140
  • telephone : +65 6385 2580

the legal entity Novaya Indonesia PT, with registered office at Indonesia, Gresik, Desa Segoromadu – Kecamatan Kebomas, Blok D No1-6, JL Mayen Sungkono 5, and with company number 41/35/I/PMA/2001


contact details:

  • adress: JL Mayen Sungkono 5, Blok D No1-6, Desa Segoromadu – Kecamatan Kebomas, Gresik, Indonesia
  • e-mail : info@latexco.com
  • fax : +62 31 398 0879
  • telephone : +62 31 398 0878
     

1.2 Website: the websites of Novaya, www.novaya-comfort.com, and derivative websites developed and administered by Novaya. 

1.3 GDPR: the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data; 

1.4 Privacy Statement: this data protection declaration; 

1.5 Personal Data: Any information relating to an identified or identifiable natural person and to which Novaya refers in the Privacy Statement; 

1.6 Users: customers, contacts or representatives of (business) customers, suppliers or business partners and other users from who Novaya processes Personal Data and who is subject of this Privacy Statement. 

 

2. General – Responsible 

2.1 Novaya gives high priority to the protection of your Personal Data. In this context, Novaya sets out a number of sustainable principles and takes appropriate measures to prevent abuse, loss, unauthorised access, unwanted disclosure and unauthorised changes. Novaya will therefore comply with all applicable legislation, including the Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”), on data protection and regulation and will always cooperate with the competent authorities. The principles and measures that Novaya applies are included in this data protection declaration (“Privacy Statement”). 

2.2 This Privacy Statement provides you with detailed information on the protection of your Personal Data by Novaya . Novaya is an “Controller” within the definition of the GDPR and other data protection provisions. Novaya is responsible for collecting and processing the Personal Data you share with Novaya in connection with Novaya activities. 

2.3 The purpose of this Privacy Statement is to inform you about which Personal Data Novaya may process about you as User, why these Personal Data are used, how they are shared, how long they are kept, what your rights are and how you can assert these rights. 

 

3 Data processing 

3.1 General information 
a. This Privacy Statement applies to Personal Data Users collected by Novaya in Europe in connection with the products and services it offers. This includes Personal Data collected (i) online via the contact page on the Website, e-mails, newsletter registration form, marketing campaigns, surveys and advertising cookies on the Website, and (ii) collected offline via customer service, and sales representatives, events, letters, telephone conversations. 
b. This Privacy Statement also applies to offers and advertisements of Novaya products or services that Novaya or a third party may display on behalf of Novaya on third party websites, platforms and applications based on your user information from these websites. These third-party websites, platforms and applications also have their own data protection declarations and general terms and conditions. It is recommended that you consult these third-party websites prior to visiting them. 
c. Novaya processes the Personal Data in accordance with Article 6.1 (a) GDPR (with the consent of the data subject), 6.1 (b) GDPR (necessary for the execution of the contract), 6.3 (c) GDPR (necessary for the fulfilment of legal obligations), 6.4 (f) GDPR (necessary for the protection of legitimate interests) and all other provisions of the GDPR that apply to them. 

3.2. What Personal Data can be processed by Novaya ? 

Novaya may process the following Personal Data. 

(a) General Novaya can collect and process all information and data of any kind, both online and offline (as set out in Art. 3.1.a.), provided by Users, to the extent useful, including (without limitation): 
(i) first and last names, 
(ii) address details, 
(iii) telephone number, 
(iv) e-mail address, 
(v) other personal data that you actively provide in correspondence and by telephone, 
(vi) your interests in marketing and communication that allow Novaya to provide you with targeted information about the services of Novaya and about developments and novelties, 
(vii) location data, 
(viii) IP address, 
(ix) information about your activities, 
(x) data about your surfing behaviour across various websites, 
(xi) payment details, 
(xii) geo-location data. 

Apart from the Personal Data described in the following sections, no other Personal Data will be processed or used for the use of the Website. However, the aforementioned personal data may be processed without your consent if this is required by Novaya in order to comply with the applicable laws and regulations. Novaya does not ask for specific sensitive Personal Data relating to the Users racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic data or data about your sexual orientation, unless this is required by law. The data that Novaya uses about you to check and or supplement its files are either (i) provided by you directly, or (ii) derived from certain (public) sources, including databases of official authorities, credit reference agencies and other databases that are made publicly available by third parties. This at all times in accordance with the GDPR. 

b. Storage of access data, creation of log files Whenever a User accesses a page on the Website of Novaya, and whenever a file is accessed, access data about this procedure is recorded in a log file and saved. The recorded information is standard logging. Each data record consists of the following: Date/time of request; Page from which the file was requested; Pages retrieved via the Website by the user’s system; Transmitted volume of data; Description of operating system and web browser used, user’s IP address; This data is used to deliver the content of the Website, ensure the functionality of our information technology systems, and to optimise the online presence of Novaya. The data may be used in an anonymised form for statistical purposes (see below), as well as for the purposes of data security, especially for error analysis and preventing hacking attempts (Art. 6 (1f) GDPR). Access rate will not be used for the creation of individual user profiles, nor be passed onto third parties, and will be erased after 90 days at the latest. c. Use of IP addresses Each time the homepage of the Website is accessed, Novaya uses the User’s IP address to determine the country from where the access is made. This data is not used further, with the exception of the storage of access data, and creation of log files described under art. 

3.2.a. d. Contact form If there is an option for entering personal or business information on the Website, the information is always entered voluntarily. Information required to perform the desired operation is designated with an asterisk ‘*’. If you provide Novaya with personal or business information via the contact forms, Novaya will only use it for the respective intended purpose. Your consent constitutes the legal basis for this (Art. 6 (1a) GDPR). Data transfers are encrypted using SSL or TLS technology in order to prevent the unauthorised access of your personal data by third parties. e. Newsletter You have the opportunity of subscribing to the newsletter of Novaya. To do so, you are required to enter your email address to which Novaya will send the newsletter. If you enter this into the input screen, Novaya will record your (company) name in order to address the newsletter personally to you. 

By entering your email address you agree that Novaya may use your data for the purpose of sending the newsletters. The legal basis for this processing is Art. 6 (1a) GDPR. Your email address and name will not be used for any other purpose; in particular it will not be sent to any third parties. You can cancel your newsletter subscription and the consent you issued at any time; this will then take effect for the future. If you wish to cancel your newsletter subscription, please use the relevant button in the newsletter sent to you. Your email address will then be promptly erased from the system of Novaya. 

f. Job offers Novaya provides the possibility to apply online via the Website for vacancies or to apply spontaneously. If you wish to apply, you must provide various 

Personal Data via the e-mail mentioned in the vacancy on the Website. This data will be processed with your permission (Art. 6 1(a) GDRP). If you do not wish to transfer Personal Data to Novaya, do not send an e-mail to the e-mail address provided on the Website. When you apply for a vacancy or spontaneously apply for one, Novaya collects, uses and stores your Personal Data for the purpose of the recruitment process. 

No sensitive Personal Data will be processed in this respect, unless this is strictly necessary and required by law or if you choose to share such information with Novaya. In the case of a recruitment, Novaya retains your Personal Data for as long as you work at Novaya and is necessary for the fulfilment of the legal obligations. In the absence of recruitment, Novaya only retains your data for as long as necessary for the purpose for which they were originally collected or if you have given Novaya permission to retain the data (e.g. for future vacancies) or to forward it to other companies within the Novaya group. In the absence of consent, your Personal Data will be deleted within a period of twelve months after the end of the recruitment process. 

As an applicant, you have the right, among other things, to access, correct and/or delete your Personal Data in accordance with Art. 7 of this Privacy Statement. g. Cookies Cookies are textual information that is stored on your hard disk via your web browser. If you revisit the website that has passed on the cookie to your browser, you will be recognised here and individually addressed. The legal basis for this is Art. 6 (1 f) GDPR. Please consult the Cookie Policy of Novaya for more information about our use of cookies. 

h. Integration of third-party services (i) The Website currently uses the Social-Media services Facebook, Instagram, LinkedIn and Youtube. If you visit the Website and click on the logo of one of the aforementioned Social-Media, you will be redirected to the relevant external page of this network service. When you click on one of the buttons, while logged in to one of the services, the information that you have visited the Website of Novaya, can be assigned to your user account there. If you are a member of one of the services and do not want the social networks to collect data about you via the online offer and link this to your data as a member, you must log out of Facebook, Instagram, LinkedIn, and Youtube before clicking on one of the logos. 

Novaya has no knowledge of the content of the transferred data and its use by the social services. These websites, platforms and applications have their own data protection declarations and general terms and conditions. Novaya advises you to consult them before visiting these websites, platforms and applications. (ii) Novaya has integrated Google Maps – a service provided by Google LLC – into the Website. (“Google”), Amphitheatre Parkway, Mountain View, CA 94043, USA, as the third-party provider. 

When you visit the website, the third-party provider receives the information that you have retrieved the relevant sub-pages of the Website of Novaya. Furthermore, the data described in Art. 3.3.b. of his notice will be transferred. This takes place regardless of whether this third-party provider provides a user account which you have logged into, or if no user account exists. If you are logged into the plug-in provider, this data will be directly correlated with your user account. If you do not wish the plug-in provider to make the correlation with your profile, you need to log out before activating the button. Google stores this data for user profiles where relevant, and it uses the data for the purposes of advertising, market research and/or for the appropriate design of its website. This kind of analysis is particularly performed (not only for logged-in users) for the purpose of delivering appropriate advertising, and to inform other users of the social network about your activities on the Website. You have a right to object to the formation of these user profiles. You have to contact Google in order to exercise this right. The legal basis for this processing is Art. 6 (1f) GDPR. 

3.3. Purposes of processing Personal Data Novaya shall Process Personal Data for the following purposes: for the promotion of your interests as a customer; for the representation of the legitimate interests of Novaya; for proper technical functioning and personalization of the Website; management of requests for information; conducting statistical research and analytics; delivery of Novaya services, including without limitation, invoicing, customer relationship management; the handling of job applications; inform you of changes to our services and products; in order to be able to answer to your questions;µ sending our mailings, newsletters and (possible) advertising messages. 

We may process your personal data for promotional or marketing purposes on the grounds of our justified interest. For example, to inform you about a new product that may be of interest to you. Or to be able to respond better to your wishes. Do you no longer want to be contacted for commercial purposes? Then you can indicate this to Novaya, you have the right at all times to have your contact details removed from our database. Novaya also processes Personal Data if Novaya is legally obliged to do so, such as data that we need for tax matters, compliance with money laundering legislation; customer administration, follow-up of orders/deliveries, invoicing, processing and follow-up of payments, follow-up of solvency, etc; the collection and storage of personal data by means of cookies (see Cookie policy) is intended to record and use individual preferences, questions and complaints to communicate with the customer and personalize pages for future visits to the website; 

 

4. Transfer of data to third parties

4.1 Novaya will not sell your Personal Data to third parties and will only share your Personal Data with third parties if (i) this is necessary for the performance of the activities of Novaya, (ii) this is necessary in accordance with applicable laws and regulations, legal obligations, or (iii) this is necessary for the performance of the agreement concluded with you. 

4.2 Novaya could transfer your Personal Data to processors, these being companies Novaya commissions to process data within the legally defined parameters, in accordance with Art. 28 GDPR (service providers, contractors). In this case, Novaya will still remain responsible for the protection of your Personal Data (i.e. as Novaya is the “controller”). Novaya has implemented legal, technical and organisational measures, alongside the performance of regular controls, to ensure that processors comply with the provisions of the data protection laws. We commission contractors in the following areas in particular: IT, sales, legal, marketing, finance, consulting, customer service, HR, logistics, … Novaya will also transfer your Personal Data to its cooperation partners, who deliver services to you under their own responsibility (suppliers, delivery companies). This is the case when you request Novaya to deliver services from these partners, or if you consent to the involvement of the partner, or if we engage the partner in a situation in which we are legally permitted to do so, such as the performance of a contract, in accordance with Art. 6 (1 b) GDPR. 

4.3 Personal Data is transferred within the Novaya for internal administrative purposes connected with centralised customer care and order processing. The legal basis for this is Art. 6 (1 f) GDPR. Novaya has instituted internal guidelines that obliged its companies to implement the technical/organisational measures for ensuring the security of data processing operations. 

4.4 In certain cases Novaya has a legal obligation to provide certain data to public agencies if requested. 

4.5 Novaya keeps its technical and organizational measures to ensure the security of data processing up to date, in particular to protect your Personal Data from risks during the data transfer. These measures are adapted in accordance with (i) the current state of the art, (ii) the need to protect the relevant Personal Data, and (iii) the risks to your rights and freedoms. In general, your data will be processed in the European Union. If, in exceptional cases, your data is also processed in countries outside the European Union (i.e. in “third countries”), this will take place to the extent that you have explicitly agreed or if this is necessary to enable Novaya to provide its service to you, or if this is laid down by law (Art. 49 GDPR). Furthermore, your data will be processed in third countries only insofar as certain measures are in place to ensure that a reasonable level of data protection exists there (e.g. adequacy decision taken by the EU Commission or “appropriate safeguards”, Art. 44 et seqq. GDPR).

5. Length of the storage Unless otherwise described in this Privacy Statement, Personal Data will be erased once it has fulfilled its applicable, specified purpose, and there are no retention obligations preventing its erasure. Personal Data is routinely erased following the expiry of the retention period, provided it is not needed for the initiation or fulfilment of a contract, and there is no other existing legal basis for the data processing. 

 

6. Security of data processing 

6.1 Novaya maintains up-to-date technical and organisational measures for ensuring the security of the data processing operation, especially in order to protect your Personal Data from risks during data transfer and from becoming known to unauthorised third parties. These measures are modified in accordance with the current state-of-the-art, the need for protecting the Personal Data in question, and the risks to your rights and freedoms. In addition to securing the systems, Novaya also want to ensure that not everyone within Novaya has access to your Personal Data. The systems in which Users data is stored are therefore only accessible to a select group of employees for whom it is necessary for them to carry out their work that they have access to. 

6.2 Novaya does not use automated individual decision-making. If Novaya uses these procedures in individual cases, she will inform you of this separately, provided this is prescribed by law. 

 

7. Rights of the data subject 

You have the right 
a) to demand information concerning the categories of data processed, the purposes of the processing, any recipients of the data, the envisaged storage period (Art. 15 GDPR); 
b) to demand the rectification or augmentation of incorrect or incomplete data (Art. 16 GDPR); 
c) to withdraw consent at any time, effective for the future (Art. 7 (3) GDPR); 
d) to object to the processing of your Personal Data on grounds relating to your particular situation (Art 21 (1) GDPR); 
e) in certain cases, to demand the erasure of data – especially insofar the Personal Data is no longer necessary for the envisaged purpose or if it is processed unlawfully, or if you withdraw your consent in accordance with (c) above, or if you have stated your objection in accordance with (d) above (Art. 17 GDPR); f) under certain conditions, to demand the restriction to the processing of data, insofar as it is not possible to erase it, or the obligation to erase disputed (Art. 18 GDPR); g) to data portability, i.e. you are entitled to receive the personal data concerning you, which you provided to us, in a commonly used machine-readable format, such as CSV, and, where relevant, to transmit it to others (Art. 20 GDPR); 

7.2 Novaya is committed to responding to your request as quickly as possible, within thirty days at the latest. However, you should keep in mind that Novaya may not be obliged to comply with every request for access, correction, deletion or transfer. This is because of our legal obligations, reasons of general interest (preservation, statistical analysis, scientific or historical research), for the institution, exercise or substantiation of a legal claim or the justified exercise of the right to freedom of expression and/or information. 

7.3 In the event of a conflict with regard to the processing of your Personal Data, you can contact Novaya by sending an e-mail to: info@novaya-comfort.com. You also have the option of submitting a complaint to the national supervisory authority. 

7.4 Questions and suggestions on the subject of data protection are always welcome. If you have any questions about data protection, please contact Novaya at the address given in Art. 1 of this Privacy Statement. 

8. amendment of the privacy statement 

Novaya reserves the right to amend this Privacy Statement in accordance with relevant changes to the law or the services Novaya offers. 

Older versions shall remain accessible. Date 10/12/2023