(Effect on _______________, 2025)

 

NOVASEER Inc. and its subsidiaries and affiliated companies (collectively: “NOVASEER,” “us,” or “we” or “the Company”) are committed to providing users with the highest level of transparency and control over the use of their information. To provide you with our services (as defined below), we need to collect and process certain personal data about you and your activities.

 

By entrusting your information to us, you acknowledge and agree that we are committed to maintaining the confidentiality of such information. We have implemented commercially reasonable and appropriate technical and organizational measures to safeguard the confidentiality, security, and integrity of all information provided.

 

When you use our services, you agree to our collection, storage, use, disclosure, and other uses of your personal data in accordance with this Privacy Policy. We urge you to read this Privacy Policy carefully and ensure you fully understand and agree to it. If you do not agree to this Privacy Policy, please stop and refrain from using our services.

 

  1. Objective

 

This Personal Data Privacy Policy (“Policy” or “Privacy Policy”) aims to establish standards and guidelines for the processing of personal data collected by NOVASEER Inc. (“NOVASEER”) in accordance with applicable regulations. By agreeing to this Privacy Policy, the data subject agrees to the terms described herein and consents to the processing of personal data for the purposes stated herein.

 

The legal basis for our collection and use of your personal data will depend on the specific purpose for which we process your data. However, we generally use the following purposes:

 

  1. Performance of a Contract– We will use this basis for necessary processing to provide you with services (including support services) and to send you service communications.

 

  1. Consent– In limited circumstances (if you choose to sign up for direct marketing emails and you accept cookies on our website), we will process your personal data based on your consent. You can withdraw your consent at any time by contacting us using the details provided below.

 

  1. Legitimate Interests– Where permitted by law, we will process your personal data based on our legitimate interests to maintain and improve our services, such as understanding the use of our services and improving them, our customer service and support operations, and protecting our users, ourselves, and our services.

 

  1. Compliance with Legal Obligation– In limited circumstances, we may process your personal data where we need to comply with a legal obligation (such as obligations stipulated in applicable laws) or if we receive an order from a court or regulatory body.

 

  1. Interpretation and Definitions

 

  1. Words capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear singular or plural.

 

  1. For the purposes of this Privacy Policy:

 

  1. Accountmeans a unique account created for you to access our Services or parts of our Services.
  2. Applicationmeans the software program provided by the Company downloaded by You on any electronic device.
  3. Company(referred to as “the Company,” “We,” “Us,” or “Our” in this Agreement) refers to Novaseer Inc., with its address at 4010 Moorpark Avenue, San Jose, CA 95117.
  4. Countryrefers to: United States.
  5. Devicemeans any device that can access the Service such as a computer, a cellphone, or a digital tablet.
  6. Personal Datais any information that relates to an identified or identifiable individual.
  7. Servicerefers to the Application.
  8. Service Providermeans any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service, or to assist the Company in analyzing how the Service is used.
  9. Usage Datarefers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
  10. Youmeans the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

 

  • Collecting and Using Your Personal Data

 

  1. Data Collected

 

 

The Company collects information from multiple resources. The Company will collect information directly from you; The Company will collect information from third parties; and, the Company will collect Meta Data Information (as described below) from your browser or personal devices.

 

The Company may collect information from you during or after your use or access of the Service, including but not limited to:

 

  • Information collected when you are registering for an Account;
  • Information collected when you fill out any forms or surveys;
  • Information collected when you request information;
  • Information collected when you communicate with The Company.
  • Information collected when you use applications; or
  • Information collected when you enroll for receiving newsletters.

 

The information you provide directly to the Company regarding you or others may include but not limited to:

 

  • Name;
  • Username
  • Email;
  • Contact Information
  • Organizational Information
  • Cookies
  • Any other information when you communicate with The Company.

 

It may also include information specific to the Application offering to you through the Service. The Company will collect information such as a business name, qualifications and credentials, description of services.

 

The Company may collect information about you or others through governmental agencies or third party service providers which to the extent permitted by law, The Company may under its sole discretion, request information on your credit information from social security office, credit bureau or other third party service provider to verify your identity, credit or trustworthiness for payment, safety protection and fraud investigation purposes. To enforce the Terms of Use and for service and training quality purposes, the Company may collect communication information between you and the Company.

 

  1. Metadata Collected

 

The Company and its third-party service providers may collect your browser or personal devices’ metadata information through cookies, web beacons, and other tracking technologies during and after your use or access to the Service.

As referenced above, the Company may collect below metadata information:

 

  • Information of the Browser;
  • Information of ISP and Operating System;
  • Information of Domain Name and IP Address;
  • Information of Using or Accessing Time of Service
  • Information of Viewing, Referring or Exiting Pages; and
  • Information of Personal Device (e.g. Android ID);

 

The Company will use this information (including the information collected by third-party service providers) for Service improvement in order to make the Service a better tool to assist and serve you. The Company will also use such information for marketing analysis to evaluate the strategies.

 

The Company may collect location information (e.g. through IP address) during or after your use or access of the Service. If you install The Company’s application, The Company may ask you to grant Company access to your mobile device’s geolocation data.

 

  1. About Cookies

 

Cookies are files that may be stored on a user’s device, containing small pieces of data shared when the device accesses or uses NOVASEER online services.

 

The collected information (typically the name of the site that created it, its lifespan, and randomly generated values) is interpreted and processed by the NOVASEER portal or application, enabling users to be recognized and to identify their interests and needs in the future.

 

We use cookies and similar technologies for session management, analytics, and personalization. Where required by law, we ask for your consent before placing non-essential cookies through our cookie banner. You can manage your preferences at any time.

 

  1. Use ofYour Personal Data

 

The Company may use your information for any of the following reasons:

 

  • For any purposes which you provided such information;
  • For any purposes that allow you to use the Service;
  • For any purposes related to customer support;
  • For any purposes related to billing and payment, including but not limited to sharing with third-party payment gateways and payment service providers in connection with the Service;
  • For any purposes on fraud investigation, wrongdoing correction or safety concerns;
  • For any purposes related to improving and maintaining the Service;
  • For any purposes related to surveys and promotions;
  • For any purpose to conduct internal records collection;
  • For any purposes, with your consent, to contact you by telephone or text message regarding Service features, improvements, or other services that may interest you;
  • For any purposes on the Company’s market research, including, but not limited to, contacting you about goods and services that may interest you; and
  • For any purposes related to dispute resolution and to enforce any terms and conditions that govern your use or access of the Service.
  • For any other purposes that the Company will notify you.

 

The Company may aggregate and/or de-identifies information collected through the Service. The Company may use aggregated or de-identified information and share such information with any third-party service providers for purposes, including but not limited to marketing research, investigation, payment and other purposes.

 

The Company may, under its absolute and sole discretion, either directly or through other third-party service providers to retrieve and analyze your communications with each other via the Service for fraud investigation, risk assessment, regulatory compliance, customer support, marketing research, Service improvement and other purposes. Note, by registering, using and accessing the Service or engaging in offline communications related to the Service, you consent that the Company, under its absolute and sole discretion, may either directly or through other third party service providers to retrieve and analyze your communications.

 

  1. We may shareyour personal information in the following situations:

 

Unless otherwise specifically described in this Policy, the Company may share your information under the following circumstances (list below is illustrative, not exhaustive):

 

  • The Company may disclose your information to third parties who perform assistance to the Service, including without limitation to billing, sales, marketing, advertising, market research, fulfillment, data storage, analysis and processing, identity verification, fraud and safety protection and legal services.
  • The Company may disclose your information under the requirement and decree of law, or The Company believes in good faith that such disclosure is necessary to: (a) comply with subpoenas, court orders, or other legal process the Company receive; (b) establish or exercise legal rights; or (c) defend the Company against legal claims. The Company will use commercially reasonable efforts to notify you of such disclosure unless (1) the Company believes in our sole discretion that providing notice could create further harms; or (2) the Company is precluded from providing notice by law.
  • The Company may disclose your information government agencies or third party service providers when the Company believes in good faith that it is appropriate to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Use or any other legal terms governing use of the Service, and/or to protect the Company’s rights and property and the rights and property of other users.
  • The Company may disclose or transfer your information when there is a sell, buy, merge or partner with other companies or businesses, or sell some or all of the Company’s assets.
  • The Company may disclose or share your information with third parties for academic and research purposes.
  • The Company will share information with its affiliates.
  • Besides all the third-party service providers, companies and agencies mentioned in this Policy and Term of Use, the Company will share information with any other third parties under your specific consent.

 

  1. Retention of Your Personal Data

 

  1. The Company will retainYour Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data only to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. For example, inactive accounts may be deleted after 24 months unless legally required to retain them for longer.

 

  1. The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retainedfor a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

 

  1. Transfer ofPersonal Data

 

  1. Your information (including Personal Data) is processed at the Company’s operating offices and in any other placeswhere the parties involved in the processing are located. This means that this information may be transferred to, and maintained on computers located outside of Your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of Your jurisdiction. We ensure that any transfer of your personal data outside your country is protected by adequate safeguards, such as Standard Contractual Clauses or equivalent mechanisms. We use encryption in transit and at rest to protect data, where technically feasible.

 

  1. Your consent to this Privacy Policy followed by Your submission of such information represents Youragreement to that transfer.

 

  1. The Company will take all steps reasonably necessary to ensure that Your data is treated securelyand in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

 

  1. HowYour Personal Data is Protected

 

  1. Any Personal Data held by NOVASEER will be stored in accordance with the strictest security standards adopted by the market, which includes taking the following measures:

 

  • Prevent unauthorized access.
  • Limiting access to places where personal information is stored.
  • Adopting procedures for employees, collaborators, service providers, and suppliers who process personal data, committing to absolute confidentiality of the information and adopting best practices for handling such data as stipulated in the company’s policies and procedures.

 

  1. While we strive to protect your information to ensure its confidentiality, we cannot guarantee absolute You need to help us prevent unauthorized access to your account by protecting your password appropriately and limiting access to your account. You will be solely responsible for maintaining the confidentiality of your password and for all usesof your password and account, including any unauthorized use.

 

  1. In any event, should an incident of this nature occur, NOVASEER guarantees its full commitment to remedy the consequences of the incident, always ensuring the transparency owed to the data subject.

 

  • Links toOther Websites

 

  1. NOVASEER may provide links to other websites deemed relevant, company agreements, or provided due to regulatory, judicial, or administrative compulsion.

 

  1. It is worth noting that NOVASEER is not responsible for the privacy policies implemented by these websites. Third parties have their own policies regarding the collection, use, sharing, and any type of data processing related to the services, and these third parties will be responsible for properly maintaining the data. NOVASEER recommends reading the policies of these third parties.

 

  • Children’sPolicy

 

We understand the importance of protecting children’s privacy, especially in an online environment. The Services are not designed for or directed at anyone under the age of 13, a “Minor”. We do not knowingly collect any Personal Data from Minors. If a parent or guardian becomes aware that his or her child has provided us with Personal Data, he or she should contact us using the details provided above.

 

  1. Email Marketing

 

By signing up to receive email marketing from NOVASEER, the user declares consent for NOVASEER to compile personalized news and offers, and to evaluate Service usage patterns to send personalized communications that meet the user’s needs and interests. If the user wishes to stop receiving such communications, he or she can unsubscribe at any time.

 

  1. Applicable Law and General Provisions

 

This document is prepared in accordance with applicable regulations on information security, privacy, and data protection, as well as international guidelines on these matters. This policy is linked to the Terms of Use, which can be found in the Privacy Portal or Privacy Statement, and should be interpreted in light of the legislative framework for personal data protection in the United States. If any term of this Privacy Policy is found to be illegal or unlawful by a public authority, the remaining terms shall remain in full force and effect. The user acknowledges that all communications made via email (sent to his/her informed address), SMS, instant messaging applications, or any other digital and virtual form are also valid as written evidence, and are valid and sufficient for disclosing any subject involving the services provided by NOVASEER and their conditions of provision, except for different terms expressly set forth in this Privacy Policy.

 

  1. Contact Us

 

If the data subject has any other questions, please contact us through the channels provided in the Privacy Portal or Privacy Statement, or if you prefer, please contact the DPO directly for personal data processing at privacy@ novaseer.com. If you have any questions about this Privacy Policy, You can contact us by email at privacy@novaseer.com or by phone at: __________________.

 

  • Updates to This Policy

 

The NOVASEER Privacy Policy (available through the channels mentioned in the Privacy Portal or Privacy Statement) is the most current version of this document. However, NOVASEER may, at its sole discretion, update this policy at any time to improve security, improve our services, or comply with legal, regulatory, or administrative obligations. NOVASEER encourages you to periodically review this Privacy Policy to stay informed about how your data is being processed. If the user does not accept and agree to this Privacy Policy, including any changes, the user should not access or use NOVASEER’s Services, services, and products.