Effective Date: 6/1/2019

Thank you for visiting this Novastep, Inc. (“Novastep,” “we,” or “us”) owned Internet website (“Site”) located at www.mifoot.wp.staging.celfcreative.com. This Privacy Notice describes how Novastep collects, uses, and shares the information that you provide to us through your use of the Site or any Novastep owned website, service, or web-based and mobile application (collectively, “Services”) that link to this Privacy Notice.

The Data Controller

Novastep Inc., with registered office in the United States, and which can be contacted at the following address 30 Ramland Road, Suite 200

Orangeburg, NY 10962 is the data controller of the processing of your personal information collected through the Site and Services.

Information We Collect

Personal Information

Generally, you can visit our Site without revealing your personal data. However, we can collect identifying data, such as for instance name, surname, email address, residence and any other information that you voluntarily provide by communicating with us, such as by sending an email or submitting an online information request form.

Additionally, we can collect any other personal information that you choose to provide to us through our Services. This includes information you provide to us (or our service provider) to apply for a job. Other information provided through a job application may include, for example, your educational and employment background, your contact information, and immigration status.

Data Collected Automatically

Like most other websites and services, Novastep uses cookies to help provide site stability, security, and a user experience free of interruption. These cookies are essential to the proper functioning of our Site and Services.

We may also use service providers, such as Google Analytics, a web analytics service provided by Google, Inc. (“Google”), that may use cookies to collect information about your online activities across this and other sites over time for non-advertising purposes, such as those described above. We use this aggregated data analysis to gain insights on user activity and improve the content and functionality of the website.

If there are any changes to our practice in the future, this will be reflected in an updated Privacy Notice.

Use and Disclosure of Information

If you do voluntarily provide personal data through our Site or Services, we may use this information to provide you the business service or to respond to your requests (including to consider you for employment).

Furthermore, we may send you communications in order to provide other information that we think may be of interest to you. Please see below the “Marketing Communications” section for more information on your options for such communications.

We may process personal data in order to fulfil legal obligations relevant to us.

To the extent permitted by applicable local law, we may provide your personal information to other entities – which can process your data as our processors or as autonomous controllers – as described in this section:

• We may provide your personal information to our parent, subsidiary and affiliate entities within our corporate family, and our partner entities that are not within our corporate family.
• In the United States, we may use your personal information to communicate with you via email or share with vendors and service agencies that we may engage to assist us in providing our Services to you. For example, we may provide your personal information to a marketing, research and/or advertising agency to send advertising to you on our behalf.
• We reserve the right to release contained personal information concerning any user when that user partakes (or is reasonably suspected of partaking) in any illegal activity where permitted by applicable local law. If permitted by applicable law in your jurisdiction, we may make such disclosures without a subpoena, warrant, or other court order, and we may also make such disclosures when we suspect a user is in violation of our Terms of Use or other published guidelines.
• We may release any information, including personal information, in response to court and governmental orders, civil subpoenas or discovery requests where permitted by applicable local law, and as otherwise required by law. We cooperate with law enforcement agencies in identifying those who may be using our servers or services for illegal activities. We also reserve the right to report any suspected illegal activity to law enforcement entities for investigation or prosecution.
• We may transfer your personal information to a successor entity in connection with a merger, acquisition, consolidation or other corporate reorganization in which Novastep participates or to a purchaser of all or substantially all of Novastep’s assets to which this Site relates, including a sale in bankruptcy where permitted by applicable local law.
• We may also share your personal information with your consent, such as if we ask your permission to use your testimonial in our advertising. You can withdraw such consent at any time.

You may request for us to provide an accurate list of our processors by writing to the email contact below.

Marketing Communications

In jurisdictions that require prior consent for marketing communications, we may send you promotional e-mails if you have consented to receiving such communication. At any time, you may revoke your consent for the receipt of communications that Novastep sends to you by following the unsubscribe process or contacting us at privacy@Novastep.com. Please follow the instructions in our emails to unsubscribe from receiving future marketing communications from us.

Please note that even if you unsubscribe from newsletters and promotional emails, we may still need to contact you with important transactional information about your account or your equipment.

Legal Basis for the Processing

Novastep will only process (i.e. use) your personal data when the law allows us to, that is, when we have a legal basis for processing.

We use your personal data in the following circumstances:

• Performance of a contract: where we need to perform a contract which we are about to enter into or have entered into with you as a party or to take steps at your request before entering into such a contract;
• Legal or regulatory obligation: where we need to comply with a legal or regulatory obligation that we are subject to;
• Legitimate interests: where necessary for our interests (or those of a third party), provided that your fundamental rights do not override such interests. 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; and
• Consent and explicit consent: where you have provided your consent to processing your personal data.

Novastep does 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).

We only rely on consent as the legal basis for processing your personal data where it is required by applicable local law (for instance, in relation to some of our electronic marketing). You have the right to withdraw your consent at any time.  When you withdraw your consent, we will stop the data processing.

Data Retention Period

Novastep will keep your personal data for as long as is reasonably necessary or required by law for the purpose of the processing.

Purpose Limitation and Data Integrity

Novastep will only process personal information in a way that is compatible with and relevant to the purpose for which it was collected or authorized for by the individual. Novastep will take reasonable steps to ensure that personal information is accurate, complete, current, secure and reliable for its intended use.

Links to Third Party Sites

The Site may provide links to other web sites or resources over which Novastep does not have control (“External Web Sites”). Such links do not constitute an endorsement by Novastep of those External Web Sites. You acknowledge that Novastep is providing these links to you only as a convenience, and further agree that Novastep is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on those Web Sites. We encourage you to read the privacy policy of any website that you visit before you provide any information to the operator of that website.

Security

We employ procedural and technological security measures that are designed to protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction.