Last Updated: 28 October 2018

 

Data privacy is of high importance for Novel Creatives ("NC") and we want to be open and transparent with our processing of your personal data. This website is not intended for children under the age of 16 and requires written parental consent for members under the age of 18. The information displayed on this site is suitable for children of 16 years and upwards.

 

We, therefore, have a policy setting out how your personal data will be processed and protected.

 

What data do you collect about me?

 

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioner's Office.

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name/last name/ username / title / age (range) 

• Contact Data includes billing address / email address / telephone numbers / social media handles. 

• Transaction Data includes details about payments to and from you/other details about services you provided or bought through the platform.

• Technical Data includes IP address/login data/browser type and version/location/operating system and platform/other technology on the device you use to access our website.

• Profile Data includes your username and password/your interests/preferences/feedback/working practices. 

• Usage Data includes information about how you use our website and services.

• Marketing and Communications Data includes your preferences in receiving marketing from us/your communication preferences.

 

We also collect and use Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

 

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offenses.

 

 

Who is the controller of your personal data?

 

UK based, Khandiz Joni Towill is the owner of Novel Creatives (“NC”) and is the controller of the personal data you submit to us and responsible for your personal data under applicable data protection law.

Our contact details are: 14c St Mary’s Road, London. NW10 4AP. United Kingdom.

 

For all data matters, contact our data representative on hello@novelcreatives.com

 

 

Where do we store your data?

The data that we collect from you is stored within the European Economic Area (“EEA”) but may also be transferred to and processed in a country outside of the EEA with our third-party Data Processors, Wix Ltd. (https://www.wix.com/about/privacy), 123 Form Builder, Sharetribe Ltd and Google.com (https://policies.google.com/privacy?hl=en-GB&gl=uk).

 

Any such transfer of your personal data will be carried out in compliance with applicable laws.

For transfers outside the EEA, Wix Ltd and Google Ltd will use Standard Contractual Clauses and Shields as safeguards for countries without adequacy decisions from the European Commission.

 

We will only retain your personal data 14 months or for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. By law, we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

 

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

 

In some circumstances, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

 

 

Who can access your data?

 

Our third-party data processors, Wix Ltd. (https://www.wix.com/about/privacy), 123 Form Builder, Sharetribe.com have access to your data in order for you to exercise your rights. 

 

We never pass on, sell or swap your data for marketing purposes to third parties.

 

Any payment transactions will be encrypted using SSL technology through our secure payment partners. Payments made on our site are made through our payment solutions providers, (i) Stripe Inc. (“Stripe”) at www.stripe.com and PayPal Holdings Inc (“PayPal”) at www.paypal.com. 

 

Data that is forwarded to third parties, is only used to provide you with our services. You will find categories of third parties under every specific process below.

 

 

What is the legal ground for processing?

For every specific process of personal data, we collect from you, we will inform you whether the provision of personal data is statutory or required to enter a contract and whether it is an obligation to provide the personal data. Where we need to collect your personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.

 

To give you more transparent and clear information on how we process your personal data, we have divided the Privacy Notice into different chapters, which can be found at the bottom of this notice. Depending on if you are a Community Subscriber, Client or Supplier, different parts of the notice will apply to you. In each chapter, we describe in even more detail what personal data we have about you and how we use it. We have also added more information about your rights, for example how to get access to your data and how to request that we stop using your data.

 

i. Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

ii. Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by writing to us at hello@novelbeings.com.

 

 

What security measures do you have in place to protect my data?

 

We use malware and anti-virus software, secure cloud storage and encrypted files to ensure we are keeping your personal data secure. We do not produce or keep hard-copies of your documentation.

 

Any third-party services we use to manage our business offer "state-of-the-art" security measures to keep yours and our data safe.

 

 

What are your rights?

 

• Right to access:

You have the right to request information about the personal data we hold on you at any time. You can contact us and we will provide you with your personal data via email.

 

• Right to portability: 

Whenever Novel Creatives processes your personal data, by automated means, based on an agreement, you have the right to get a copy of your data transferred to you or to another party. This only includes the personal data you have submitted to us.

 

• Right to rectification:

You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed.

 

• Right to erasure:

You have the right to erase any personal data processed by Novel Creatives at any time except for the following situations:

*you have an ongoing matter with us
*you have an open order which in which the product or services has not been delivered or completed
*you have an unsettled debt withNovel Creatives, regardless of the payment method
*if you are suspected or have misused our services within the last four years
*your debt has been sold to a third party within the last three years or one year for deceased customers
*if you have made any purchase of product or service, we will keep your personal data in connection with your transaction for bookkeeping purposes

 

• Your right to object to processing based on legitimate interest:  

You have the right to object to the processing of your personal data that is based on Novel Creativeslegitimate interest. Novel Creatives will not continue to process the personal data unless we can demonstrate legitimate grounds for the process which overrides your interest and rights or due to legal claims.

 

• Your right to object to direct marketing:

You have the right to object to direct marketing, including profiling analysis made for direct marketing purposes.

You can opt-out from direct marketing by the following means:

* following the instruction in each marketing emails

*by logging into your account and managing the settings yourself
* by email hello@novelcreatives.com with the subject line "Opt Out"

 

• Right to restriction:

You have the right to request that Novel Creatives restricts the process of your personal data under the following circumstances:

* if you object to a processing based on Novel Creatives legitimate interest, Novel Creatives shall restrict all processing of such data pending the verification of the legitimate interest.
* if you have a claim that your personal data is incorrect, Novel Creatives must restrict all processing of such data pending the verification of the accuracy of the personal data.
* if the processing is unlawful you can oppose the erasure of personal data and instead request the restriction of the use of your personal data instead
* if Novel Creatives no longer needs the personal data but it is required by you to defend legal claims.

 

Access to your personal data (or to exercise any of the other rights) is free of charge. However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

 

How can you exercise your rights?

 

Send us an email to hello@novelcreatives.com. We take your privacy very seriously and are happy to help resolve any issue to the best of our ability. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

 

 

Right to complain to a supervisory authority: 

 

If you consider NC to process your personal data in an incorrect way you can contact us. You also have the right to raise a complaint to the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

 

 

Your duty to keep us informed:

 

Please keep us informed if your personal data changes during your relationship with us. It is important that the personal data we hold about you is accurate and current.

 

 

Updates to our Privacy Notice:

We may need to update our Privacy Notice. The latest version of the Privacy Notice is always available on our website. We will communicate any material changes to the Privacy Notice, for example, the purpose of why we use your personal data, the identity of the Controller or your rights. You will always be able to see when the Notice was last updated at the top of this page.