Effective Date: 10/15/2020
Thank you for doing business with Novosi, LLC (“Novosi,” “Company,”
“we,” “our,” or “us”). We welcome you and hope you find
our websites, applications, products, and our other subscription services and tools (collectively, the
”) to help our website visitors, current and potential customers, clients, and the
prospects of our clients (“you” or “your,”) understand what Data we
collect, store, share, and use, how and why we do so, and what your rights are in regards to that Data.
and your use of our Services. “Data” is broken into different categories, which are defined in the “Data We Collect and How We Use It” section of this Privacy
Policy. We may refer to the different categories separately, but when we use the word “Data,” we mean all
To be clear, the term “Data” does not apply to “De-identified Data,” which consists of: (1)
any information that we may acquire from third parties that has been de-identified before we receive it and
(2) de-identified and aggregated data that may be derived from such information and other Data, such as
traffic patterns, geo-location, and other information (which again, cannot be reasonably connected with any
individual). We may use De-identified Data for our own purposes, subject only to our agreements with the
1. DESCRIPTION OF SERVICES
We provide a video conferencing platform that helps our clients easily and seamlessly connect with their
Services, including our website, app, tools, and any other services that we provide directly to you,
including updates thereto, whether now known or developed later, are included in the term
2. LAWFUL BASIS FOR PROCESSING
Many jurisdictions require that we disclose to you the lawful basis for our processing of your Data. We do
is based on your specific consent or your contract with us.
By accessing or using any of the Services or by otherwise interacting with us online, you consent to our use
you may withdraw your consent at any time, and we will cease collecting your Data. However, in some cases,
this may result in your inability to receive partial or full access to the Services, and your withdrawal of
consent does not limit our ability to use the Data that has been aggregated and anonymized for use by us in
connection with our legitimate business efforts in the future. In addition, your withdrawal of consent does
not prevent us from retaining and processing Data if we are required to do so by applicable law or in order
to preserve legal claims. It also doesn’t prevent us from processing Data that has been gathered pursuant to
a different lawful basis. For example, if you give your consent for us to process your Data, but we are also
required by law to keep your Data, that separate “lawful basis” will still apply, even if you withdraw your
When you enter into an agreement with us, either by accessing the Services, by executing an agreement in hard
copy or by clicking “I Accept” or similar language online, we will process your Data for the purposes of
fulfilling the terms of our contract with you. In that case, our processing of your Data is based on the
contract, so your withdrawal of consent will only be effective after the purposes for processing that Data
have been fulfilled and after we no longer have a legal obligation to keep that Data.
In all cases, we will comply with applicable law and we will cease processing your Data after the legal
right, obligation, or other lawful basis expires.
4. DATA WE COLLECT AND HOW WE USE IT
Listed below are the categories of Data we collect when you use our Services. We never sell your Data, and we
always have a lawful basis for gathering the Data, but that lawful basis might be different for different
categories, and we describe those uses below. Regardless, we never use the Data for any purpose other than
the purpose for which we gathered the Data in the first place, unless we get your prior explicit consent.
A. Registration Data
Data Description: Registration Data consists of the name, e-mail address, street address, and
other contact information you provide us using the Services, both when you register your account and
thereafter. Registration Data also includes your username, client type and membership end date, if any.
Lawful Basis for Processing: Our lawful basis for processing Registration Data is our contract
with you and your consent. We can only provide certain of the Services to you if we have the
Registration Data, so we need to store and access that Registration Data during the term of our
contract. Even when the Registration Data is not critically necessary to the provision of the Services,
we may still process that Registration Data to facilitate our contractual interactions with you.
How We Use It and Who We Share It With: Registration Data is accessible only to us and to you. We
use it only to provide the Services to you. At times, we will share the Registration Data with other
third parties at your request or to fulfill requests that you make of us. We may also use your
Registration Data to offer our own goods or services to you, either directly through e-mails or through
third party platforms, but you may opt out of those offers at any time.
B. Engagement Data
Data Description: Engagement Data consists of all the information you input or record using the
Services, except as otherwise stated in this policy. It also includes all information that is
proprietary to you regarding your use of the Services (other than the data that qualifies as “Usage
Data” below) that is collected or processed by the Services. Engagement Data may include records of
online meetings and sessions, including information and recordings gathered in connection with those
meetings and sessions, such as the personal information of prospects, and business information of our
Lawful Basis for Processing: Our lawful basis for processing Engagement Data is (1) our contract
with you, (2) our obligation to provide you with the Services and (3) our legitimate interest in
improving our Services based on the Engagement Data we receive from you.
How We Use It and Who We Share It With: Your Engagement Data is accessible only to us, to you,
and where it relates directly to a party who either provides services to you or receives services from
you, to that party, in which case that party will be obligated to protect the confidentiality of your
Engagement Data under applicable law. We do not share Engagement Data with other third parties, except
at your specific request. We also do not de-identify or aggregate Engagement Data for use for any
purpose other than to provide the Services to you and to improve our knowledge of how our systems are
used. Both during the term of our agreement with you and thereafter, we may also use Engagement Data
that has been anonymized and aggregated in randomized control tests related to the products we offer. We
may share the results of that randomized control testing with third parties such as research or academic
institutions, but the shared information will only include demographic data such as gender and age. It
will never include personally-identifiable information such as names, e-mail addresses, or phone
C. Usage Data
- Data Description: Usage Data consists of the following and similar information:
Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with
you and (2) our legitimate interest in improving our Services based on the Usage Data we receive from
How We Use It and Who We Share It With: Usage Data is accessible to us and to you. We do not
share it with third parties, except when we agree to do so at your specific request, but we may use
Usage Data to make improvements to the Services. Both during the term of our agreement with you and
thereafter, we may also use Usage Data in an anonymized and aggregated format that is not identifiable
to any individual, and that anonymized and aggregated information belongs solely to us to use in our
sole discretion (including to sell anonymized and aggregated information, which is not Data). To the
extent we are required to delete any Usage Data about you, we may still retain aggregated and anonymized
information that may have originated as your Usage Data.
Information about your interactions with the Services, which include the date and time of any
requests you make. This also may include details of your use of Third-Party Applications and any
advertising you receive via the Services.
Adjustments you make to the default state of the Services, such as custom categories or settings.
The timing of the information you post to the Services including messages you send and/or receive
via the Services and your interactions with our customer service team, but not including the content
of those interactions and messages, which would be included as Engagement Data.
Technical data which may include URL information, cookie data, your IP address, the types of devices
you are using to access or connect to the Services, unique device IDs, device attributes, network
connection type (e.g. WiFi, 4G, LTE, Bluetooth) and provider, network and device performance,
browser type, language, information enabling digital rights management, operating system, and
Motion-generated or orientation-generated mobile sensor data (e.g. accelerometer or gyroscope) about
you or your employees, if any, required for the purposes of providing specific features of the
Services to you.
D. Payment Data
Data Description: Payment Data is only collected when your use of the Services is subject to the
payment of a fee or other charge. Payment Data is the information necessary for us to process your
payments. Payment Data will vary depending on the payment method you use (e.g. direct via your mobile
phone carrier or by invoice) but will include information such as:
Lawful Basis for Processing: Our lawful basis for processing Usage Data is (1) our contract with
you and (2) our legitimate interest in improving our Services based on the Payment Data we receive from
How We Use It and Who We Share It With: We only use Payment Data to facilitate payment, and we
only communicate it to those parties who are strictly necessary for that purpose.
- Date of birth;
- Credit or debit card type, expiration date, and certain digits of your card number;
- Address and postal code; and
- Mobile phone number
5. SHARING YOUR INFORMATION
Except where a specific limitation is noted above, we may share your Data as follows:
At Your Instruction. If you request us to make your Data available to a third party,
and such request furthers, in our sole discretion, the purposes of our Services, we will do so, and you
agree to pay any processing fee associated with such efforts.
Sharing with Vendors. In certain cases, we use the services of third-party vendors, to
assist us in providing the Services. We may share your Data with such vendors solely for that purpose.
Service Providers. We may sometimes use a third party to provide specific Services on
our behalf, including sending e-mails to our members, conducting member surveys, processing
transactions, or providing development technology services, or performing statistical analysis of our
Services. In these cases, we may provide certain personal information, such as your name and e-mail
address and other financial information necessary for the service to be provided.
Internet Service Providers. We may provide certain portions of your Data, such as your
email address or name, back to your internet service provider if we have an existing advertising
relationship with them. This is done to allow them to target or discontinue your exposure to our
advertisements, once you have become a participating member of our Services.
Business Transitions. In the event that we go through a business transition, such as a
merger, acquisition, liquidation or sale of all or a portion of our assets, the information we have
about you will, in most instances, be part of the assets transferred. We reserve the right to transfer
that information in connection with such transactions without notice to you. We will not be required to
obtain your consent for such a transfer.
Legal Disclosure. We may disclose your Information if required to do so by law or in
the good faith belief that such action is necessary to conform to applicable law, comply with a judicial
proceeding, court order or legal process served on us, protect and defend our rights or property, or
investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving
potential threats to the physical safety of any person, or violations of our terms of service.
If we ever plan to use any Data in the future for any other purposes not identified above and we do
not have a separate lawful basis for that new purpose for processing, we will only do so after obtaining
your specific consent.
6. TECHNOLOGIES WE USE
The technologies we use for automatic Data collection may include the following:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your
computer. You may refuse to accept browser cookies by activating the appropriate setting on your
browser. However, if you select this setting you may be unable to access certain parts of our Services.
cookies when you direct your browser to our Services.
Flash Cookies. Certain features of our Services may use local stored objects (or Flash
cookies) to collect and store information about your preferences and navigation to, from and on our
Services. Flash cookies are not managed by the same browser settings as are used for browser cookies.
Web Beacons. Pages of the Services and our e-mails may contain small electronic files
known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the
Company, for example, to count users who have visited those pages or opened an e-mail and for other
related website statistics (for example, recording the popularity of certain website content and
verifying system and server integrity).
Other Technologies. We may also use device identifiers, local storage, html modifiers,
and different types of caching to help us understand the devices and users who access the Services.
Those methods include device identifiers that are either hardware-based or software-based, persistent or
non-persistent, and which may identify either a device or a software module within a device (such as a
7. YOUR CHOICES REGARDING OUR USE AND DISCLOSURE OF YOUR DATA
By using our Services, you agree that we may use your Data to market our other Services to you. If, after
giving your consent, you wish to opt-out of our using your Data to market Services to you, please follow the
Receiving electronic communications from us: If you no longer want to receive
marketing-related emails from us on a going-forward basis, you may opt-out of receiving these
marketing-related emails by sending a request for list removal to firstname.lastname@example.org.
anonymized and aggregated Data and except for Data that is processed by us pursuant to a lawful basis
other than your consent, you may instruct us to cease disclosure or use of your Data by contacting us at
We will comply with your request(s) as soon as reasonably practicable. Please also note that if you do
opt-out of receiving marketing-related emails from us, we may still send you messages for administrative or
other purposes directly relating to your use of the Services, and you cannot opt-out from receiving those
8. PRIVACY FOR EU RESIDENTS
The General Data Protection Regulation made effective in Europe on May 25, 2018 (“GDPR”)
requires that we clearly describe to data subjects residing in Europe the data we collect and how we use
data collection, you will write us at email@example.com.
The GDPR also requires that we have a lawful basis for our processing of any personal data about an
individual residing in Europe. For an individual browsing our website or otherwise accessing our Services,
our lawful basis is our legitimate interest in providing the Services to you in the manner that you desire,
and all the Data that we collect from such individuals will be used only for those purposes, as described in
contract under which you purchase those products or services, and the Data we collect from such individuals
will be used only in connection with our contractual relationship with you and only in a manner that
For employees and other authorized users operating in their role as administrators or users of our services,
our lawful basis is the legitimate interest we have in providing the services to their employer.
The GDPR also requires us to take appropriate technical and organizational measures to protect the security
of Data relating to residents of Europe. We make commercially reasonable efforts to ensure the privacy and
security of the Data of our European visitors and customers, and we are happy to give you a complete
description of our most current efforts, if you will write us at firstname.lastname@example.org. You may also write us at that address to communicate with
our data protection officer.
Pursuant to the GDPR, residents of Europe have the right to obtain our confirmation of whether we
maintain personal information relating to them in the United States. If you are a resident of Europe,
upon request from you, we will provide you with access to the Data that we hold about you. You may also
correct, amend, or delete the Data we hold about you, subject to our rights and obligations under the
or delete Data transferred to the United States, should direct their queries to email@example.com. If requested to remove Data, we will respond within a
The security of your Data is important to us. We use commercially reasonable efforts to store and maintain
your Data in a secure environment. We take technical, contractual, administrative, and physical security
steps designed to protect Data that you provide to us. We have implemented procedures designed to limit the
dissemination of your Data to only such designated staff as are reasonably necessary to carry out the stated
purposes we have communicated to you.
We will keep your information for as long as it remains necessary for the identified purpose or as required
by law, which may extend beyond the termination of our relationship with you. We may retain certain data as
necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of
aggregated, non-personally-identifiable data, account recovery, or if required by law. All retained
your information be removed from our databases, it may not be possible to completely delete all of your
information due to technological and legal constraints.
11. CHILDREN AND STUDENTS
Pursuant to our License and
, Permission of a parent or guardian (or an educational institution, where applicable) is
always required before children or students under the age of 18 can use the Services.
Once permission is provided, the Services may be used by children and students in various contexts, such as
(1) in an educational context, where our video conferencing platform is used for communication between
students and teachers, (2) in a health-related context, where a doctor or therapist may meet with a child
using our Services, or (3) in other contexts.
We collect very little information about children and students in those contexts. For example, while we do
gather the name and contact information of children and students, and while we do “process” the sessions in
which they participate, in the sense that the streaming sessions pass through servers configured or managed
by us, we never record those sessions or any of the content of those sessions, and the names of children and
students that we do gather are never made available to third parties (other than to our service providers,
who are also under confidentiality and security obligations). We only use the information we receive from
children and students for purposes of providing the Services, including improving those Services. We never
use the information for marketing purposes, either for ourselves or third parties, and we comply with the
requirements of the Family Educational Rights and Privacy Act (FERPA) and the Child Online Privacy
Protection Act (COPPA).
Parents and guardians of children and students have certain rights under COPPA and FERPA. Upon request, where
required by those laws, we will (1) disclose to parents and guardians the information that we have
collected, (2) delete or correct that information, and (3) cease processing the information. Parents can
make this request by e-mailing us at firstname.lastname@example.org.
As with the other Data we collect, the information we collect from children and students may be de-identified
and aggregated, and the resulting information, which no longer contains any personally identifiable
information, belongs to us and may be used by us for our own purposes.
effective on the date that is 30 days from their posting on the Services or sent via email to your listed
you and your account. The date on which the latest update was made is indicated at the top of this document.
time to time to ensure you are aware of any changes. Your continued use of the Services signifies your
acceptance of any changes.
13. ACCESS AND ACCURACY
You may, under applicable law, have the right to access the information we hold about you in order to verify
the information we have collected in respect to you and to have a general account of our uses of that
information. Upon receipt of your written request, and as required by applicable law, we will provide you
with a copy of your information, although in certain limited circumstances we may not be able to make all
relevant information available to you, such as where that information also pertains to another user. In such
circumstances we will provide reasons for the denial to you upon request. We will endeavor to deal with all
requests for access and modifications in a timely manner.
We will make every reasonable effort to keep your information accurate and up-to-date, and we will provide
you with mechanisms to update, correct, delete or add to your information as appropriate. As appropriate,
this amended information will be transmitted to those parties to which we are permitted to disclose your
information. Having accurate information about you enables us to give you the best possible service.
14. CONTACT US
You can help by keeping us informed of any changes such as a change of your personal contact information. If
you would like to access your information, if you have any questions, comments or suggestions of if you find
any errors in our information about you, please contact us at email@example.com.
If you have a complaint concerning our compliance with
applicable privacy laws, we will investigate your complaint and if it is justified, we will take appropriate