Last updated: 2023-04-07
We collect this information to continually improve and enhance the functionality of Novopath. We gather certain information automatically. This information may include IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We link this automatically collected data to other information we collect about you.
“Personal Information” means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Personal Information may include the following: name, address, date of birth, gender, and contact data (i.e., email address, telephone number, and employer name).
We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information.
We take your privacy seriously and employ information protection controls in keeping with industry standards and practices to safeguard your information and protect your anonymity. Personal Information about you may be collected from you through various sources, including information i) that is entered manually and voluntarily by you on the site’s application and other forms or postings on the site; ii) that you provide regarding your preferences (for example, based on your activity on our website); iii) from other sources with your consent (for example, from other institutions such as auditors or administrators); iv) from sources in the public domain; and v) from other interactions you may have with us (for example, discussions or emails with our staff, including through the use of the site’s contact features).
In addition, when you visit our website(s) and our related services, we may gather anonymous technical and navigational information, such as computer browser type, Internet protocol address, cookie information, pages visited, and average time spent on our website. This information does not personally identify you and may be used, for example, to alert you to software compatibility issues, to customize any advertising or content you see, fulfil your requests for products and services, contact you, conduct research or analyze and improve our site design and functionality.
Such information collected by us may be stored and processed in the United States or any other country in which our agents or we maintain facilities. By using the website and our services, you consent to the foregoing collection and use of information and any such transfer of information outside of your country. We make no representation or warranty with respect to any duty to permanently store any Personal Information you may provide.
In order to provide the best experience when you visit our website, we may ask you for Personal Information. Personal Information includes, for example, your name and e-mail address, both of which you may be asked to provide when registering with Novopath. A description of some of the ways that you may provide Personal Information to us, as well as further details on how we may use such Personal Information, is given below.
If you email us using a “Contact us” link on our website, we may ask you for information such as your name and e-mail address so we can respond to your questions and comments. If you choose to correspond with us via e-mail, we may retain the content of your e-mail messages, your e-mail address and our response to you.
We may occasionally ask website visitors to complete online surveys and opinion polls about their activities, attitudes, and interests. These surveys help us improve our products and services. When asking for participation in these surveys, we may ask you to provide us with your name and email address.
Our website may offer visitors contact forms to request additional details and to download collateral. If you fill out one of our web forms, we may ask you for information such as your name and email address so we can respond to your questions and comments. If you choose to correspond with us via web forms, we may retain the form data which can include name, email address and other contact related details.
Our website offers individuals the opportunity to ask questions and answer questions in our Novopath Community site that may contain self-reported demographics. If you choose to correspond with us and the community, we may retain the data which could include name, email address and other contact related details.
Technologies such as: cookies, beacons, tags, and scripts are used by NovoPath and our marketing partners, analytics providers, and customer support systems. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our userbase as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
Most web browsers can be set to tell you when a cookie has been sent to you and give you the opportunity to refuse that cookie.
Refusing a cookie may in some cases prevent you from using or negatively impact the display or function of our website or certain areas or features of our website. There are numerous resources on the Internet that can provide more information about how cookies work and how you can manage them.
Web Beacons, also known as pixel tags and clear GIFs, (“Web Beacons”), are electronic images that allow a website to access cookies and help track marketing campaigns and general usage patterns of visitors to those websites. Web Beacons can recognize certain types of information, such as cookie numbers, time and date of a page view, and a description of the page where the Web Beacons is placed. No personally identifiable information about you is shared with third parties through the use of Web Beacons on the site. However, through Web Beacons, we may collect general information that will not personally identify you, such as: Internet browser, operating system, IP address, date of visit, time of visit and path taken through the site.
Internal use of Web Beacons: NovoPath may use Web Beacons internally to count visitors and recognize visitors through cookies. Access to cookies helps personalize your experience when you visit the Site.
Email: NovoPath may include Web Beacons in HTML-formatted email messages that NovoPath sends to you. Web Beacons in email messages helps determine your interest in and the effectiveness of such emails.
External use of Web Beacons: NovoPath may also use Web Beacons externally. For example, NovoPath may report aggregate information about visitors, such as demographic and usage information, to its affiliates and other third parties. NovoPath may also include other Web Beacons within the site.
You may “opt in” and/or “opt out” of certain uses of your Personal Information. For example, you may have the opportunity to choose whether you would like to receive email correspondence from us. Your Personal Information will not be shared with third-party service providers unless you give consent. You will have the opportunity to opt out of NovoPath marketing emails by clicking the “opt out” or “unsubscribe” link in the email you receive. Requests can be sent to email@example.com.
Please take note that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, activities, transactions, and communications with us.
NovoPath uses your Personal Information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your Personal Information to support our business functions, such as fraud prevention, marketing, and legal functions. To do this, we combine Personal and non-Personal Information, collected online and offline, including information from third-party sources.
Disclosure of Personal Information
NovoPath does not sell or otherwise disclose the Personal Information it holds to third parties, except for the following exceptional circumstances:
We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:
We also may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
NovoPath may be required to disclose collected information in order to (i) respond to investigations, court orders or legal process, (ii) to investigate, prevent or take action regarding illegal activities, suspected fraud, potential threats to the physical safety of any person, (iii) violations of the company’s terms of service, or (iv) as otherwise required by law.
You may request access to your personal data to update, correct or delete, or to limit the use or disclosure of, your personal data.
Individuals wishing to view, update, delete, or supplement their personal data may do so by contacting the business that provided NovoPath your personal data directly to make your requests, or alternatively, requests can be sent to firstname.lastname@example.org.
Right to Correct Personal Information
Your Right to Correction. You have the right to request the correction of any inaccurate personal information that we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information. We will use commercially reasonable efforts to correct the inaccurate personal information as you may direct.
We take reasonable and appropriate precautions, including administrative, technical, personnel, and physical measures, to safeguard Personal Data against loss, misuse, theft, and unauthorized access, disclosure, alteration, and destruction. We also use Secure Sockets Layer (SSL) encryption when transmitting sensitive information. Please keep in mind that due to the inherent nature of the Internet, there is no way to make the transmission of electronic data entirely safe from intrusion.
To help protect the privacy of data and personally identifiable information you transmit through use of this site and any other related services, we maintain physical, technical and administrative safeguards. We update and test our security technology on an ongoing basis. We restrict access to your personal data to those employees who need to know that information to provide benefits or services to you. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. We commit to taking appropriate disciplinary measures to enforce our employees’ privacy responsibilities.
All Personal Information is retained only for as long as it is necessary for the purposes for which it was collected or transferred. NovoPath retains your information for business purposes, for as long as your account is active, and/or as long as is reasonably necessary to provide you with our products and services. NovoPath will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreements. We may also retain cached or archived copies of your information for a reasonable period of time. At any point in time, you can withdraw consent and we will immediately stop processing your data.
Transfers of Personal Data
The Services are hosted and operated in the United States (“U.S.”) through and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided in the U.S. and will be hosted on U.S. servers, and you authorize NovoPath to transfer, store and process your information to and in the U.S., and possibly other countries. We take steps to ensure that your personal data receives the same level of protection as if it remained within the EU, including by entering into data transfer agreements using the European Commission approved Standard Contractual Clauses.
In regard to the aforementioned rights to voice questions, make requests regarding your data privacy or withdraw consent, we will respond to your request within 30 days. In some cases, however, we may limit or deny your request if: the law permits or requires us to do so, if it infringes on the privacy of other individuals or internal procedures, if we find the request to be unfounded or excessive or if we are unable to verify your identity.
If the volume or complexity of the request requires internally processing at NovoPath beyond 30 days, NovoPath will inform the requester within 30 days of the reasons for an extension and may charge a reasonable fee to cover administrative costs.
Security of all information is of the utmost importance for NovoPath. NovoPath uses technical and physical safeguards to protect the security of your Personal Information from unauthorized disclosure. We use encryption technology to keep all information secure. We also make all attempts to ensure that only necessary people and third parties have access to Personal Information. Nevertheless, such security measures cannot prevent all loss, misuse, or alteration of Personal Information and, unless otherwise agreed in a written agreement between NovoPath and the applicable party, we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you without undue delay of any loss, misuse or alteration of Personal Information that may affect you. We will notify relevant regulatory bodies within 72 hours of a breach.
By using this site, you agree to take basic steps to ensure your privacy online. You agree to log out of this site when you are finished, protecting your information from other users. You also agree not to share your password or login ID with anyone else. In addition, you agree to take reasonable precautions against malware and viruses by installing an anti-virus software to protect your online activities.
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online. We do not specifically market to children under 13.
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
To be in accordance with CAN-SPAM we agree to the following:
If at any time you would like to unsubscribe from receiving future emails, you can email us at email@example.com and we will promptly remove you from ALL correspondence.
NovoPath may employ and contract with third-party service providers and other entities to assist in providing our services to customers by performing certain tasks on our behalf. These third-party providers may offer customer support, data storage services (data centers), or technical operations. NovoPath maintains contracts with these third parties restricting their access, use and disclosure of personal data in compliance. These third parties may access, process, or store personal data in the course of providing their services. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents. We may be liable for the appropriate onward transfer of UK, EU, and Swiss personal data to third parties.
We acknowledge the right of UK, EU, and Swiss individuals to access their personal data. Your ability to access, limit use and disclosure, for specific instructions on how you can access this right.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred
(i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
Overview of California Consumer Privacy Laws
Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 179883, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
On January 1, 2020, the California Consumer Privacy Act of 2018 (CCPA) took effect and sets new requirements and rights relating to personal information of California consumers. This section for California residents applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||No|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||No|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||No|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||No|
|G. Geolocation data.||Physical location or movements.||No|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
|L. Sensitive Personal Information||Biometric information for purposes of identifying a consumer; personal information collected and analyzed concerning a consumer’s health, and personal information collected and analyzed concerning a consumer’s sex life or sexual orientation||No|
We will use and retain the collected personal information as needed to provide the Services or for:
We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Do Not Track
NovoPath does not track its customers over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on NovoPath’s websites such as a social feature may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific NovoPath website from a certain IP address. Third parties cannot collect any other personal information from NovoPath’s websites unless you provide it to them directly.
To facilitate our business practices, your Personal Data may be collected, transferred to, and stored by us in the United States. As a result, your Personal Data may be processed outside the EEA, and in countries which are not subject to an adequacy decision by the European Commission, and which may not provide for the same level of data protection in the EEA. In this event, we will ensure an adequate level of protection, for example by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Art. 46 GDPR), or we will ask you for your prior consent to such international data transfers.
NovoPath commits to resolve complaints about your privacy and our collection or use of your personal information under GDPR. European Union individuals with inquiries or complaints should use the contact information below to submit complaints about your privacy and our collection or use of your personal information.
Means of contact:
Requests can be sent to firstname.lastname@example.org
or to our mailing address:
100 Somerset Corporate Blvd – 2nd Flr
Bridgewater, NJ 08807
If you have any unresolved privacy concerns that we have not addressed satisfactorily after contacting us, you have the right to contact the EU Data Protection Authorities by clicking on the following link: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
100 Somerset Corporate Blvd – 2nd Flr
Bridgewater, NJ 088077
100 Somerset Corporate Blvd
2nd Floor, Suite 111
Bridgewater, NJ 08807