Privacy policy

Our Privacy Policy explains you how we use your personal data (your “Information“).

It applies to Information we collect about you when:

  • you are a Customer of Nova (see our “Policy for Customers“)
  • you are a Prospect of Nova (see our “Policy for Prospects”)
  • you are a recruitment candidate (see our “Policy for Recruitment candidates”)
  • you are a User of our Jinko Platform (see our “Policy for Users“)
  • you are a Visitor of our Website (see our “Cookie Policy“)

Finally, it contains information applicable to all our Policies (see our section “Information applicable to all our Policies“).

This Privacy Policy became effective on July 2”rd, 2022Privacy

We may change this Privacy Policy at any time and We will notify you thereof, either by email or by any means of electronic notice, within a reasonable time period prior to any later version coming into force.

  • 1. BASICS PROVISIONS

    1.1. Who are we ?

    Novadiscovery is a Société par actions simplifiée (SAS) having its address at 1 Place Giovanni da Verrazzano, Lyon (69009) FRANCE, and registered under number SIREN 521885368 (hereinafter referred as “Nova“).

    1.2. How can you contact us ?

    If you have any questions about the protection of your Information, you can contact our Data Protection Officer (DPO) by one of the following means:

    • By email: dpo@novadiscovery.com
    • By phone: 0972531300
    • By post: Novadiscovery – For the attention of the Data Protection Officer (DPO) – 1 Place Giovanni da Verrazzano – 69009 Lyon

    1.3. Definitions

    When we use capitalized terms in our Privacy Policy, we refer to the definitions below:

    “Candidate” means any individual who responds to one of our job offer or sends in us a speculative application.

    “Customer” means you if we have already entered into a business agreement together. You should not consider yourself to be one of our Customers if you are merely a User authorised by your Organisation to use our Platform.

    “Information” means personal data about you, whether that information directly or indirectly identifies you.

    “Organisation” means the legal entity to which you are attached (e.g. your employer) and which has entered into a commercial agreement with Nova to allow you to use our Platform.

    “Platform” means our Jinko platform which operates as a software as a service.

    “Policy” means one of the policies in our Privacy Policy that applies to a particular category of individuals.

    “Privacy Policy” means this document in its entirety.

    “Prospect” means you if you have expressed a commercial interest in our company or if we have identified you as potentially interested in our company.

    “SaaS Services” means the provision of access and use rights to our Jinko Platform and any associated services that you may access pursuant to your Subscription.

    “Services” means all the services we can provide to you.

    “Subscription” refers to the subscription that your Organisation has signed up for with us which determines the SaaS Services you can use.

    “User” means you if your Organisation has created a user account for you on our Platform.

    “Visitor” means you when you navigate on our Website.

    “We“, “us“, “our” and “Nova” mean our Novadiscovery company as identified in the “Who are we ?” section.

    “Website” means our website accessible at the following address: https://www.novadiscovery.com/.

    “Workspace” means the workspace created and managed by your Organisation, accessible from our Platform, and on which you are required to collaborate at the request of your Organisation.

    “Workspace Data” means all data and content of any kind (personal data or non-personal data) that may be uploaded to the Workspace.

  • 2. POLICY FOR CUSTOMERS

    This Policy explains the processing of personal data we do with your Information when you are a Customer.

    It does not apply to Users who have been invited by their Organisation to use our Platform. If you are a Jinko User, please see our Policy for Users.

    2.1. What Information do we collect about our Customers ?

    When you are a Customer, we use different categories of Information about you, which you may provide to us or which we may collect indirectly.

    Categories of Information Description
    Identity Company name and company registration number (only for companies), surname and first name and title, address (billing address, delivery address), telephone number, email, fax number, date of birth, customer code that we assign internally.
    Personal account Username, password, and email associated with the account
    Work situation Job title, Company name
    Payment Payment, terms and conditions of payment (discounts, advance payments, rebates), methods of payment : SWIFT/ IBAN
    Transaction Transaction number, details of purchase (product, service or subscription)
    Customer relationship Requests for documentation or tests, products purchased or services and subscriptions taken out, orders, invoices and payment terms and deadlines, history of purchases, correspondence with you, after-sales service, exchanges between you and our customer relations department
    Outstanding debt Personal details, payment incident (date of outstanding debt, relevant invoice , amount possible reason), means of payment used)
    Registration to our communication events Name, first name, contact details (email, address, phone), eventually your employer and job title for professional events

    2.2. Why do we use Customer Information and for how long?

    When you are a Customer, We may use your Information for a variety of reasons:

    • we may need it to provide you with the Services you have ordered from us (Performance of a contract)
    • we may need it to meet our legal obligations (Compliance with the law)
    • we may have legitimate interests in using your Information (Our legitimate interest)
    • we may do so after obtaining your consent (Consent). You can withdraw your consent at any time.

    Below you will find the purposes for which we process your Information (the purposes of our processing) and the periods for which we retain your Information:

     

    Purpose Legal basis Period of data retention
    Management of our commercial relationship (order processing, delivery, after-sales service) Performance of a contract The entire duration of our contractual relationship
    Management of our legal, accounting and tax obligations as part of our contractual relationship Compliance with the law Storage for the legal retention period to which we are bound (e.g. up to 10 years for our accounting obligations)
    Management of outstanding payments (Identification of outstanding payments and exclusion of customer from future transactions in the event of unpaid invoices) Performance of a contract No later than 48 hours after the outstanding amount has been regularised
    Management of complaint and litigation  Legitimate interest of Nova to establish proof of a right or the proper performance of our contractual obligations For the duration of the statute of limitations applicable to our business relationship (e.g. up to 5 years for civil statute of limitations)
    Storage of connection data when publishing content online Compliance with law (Decree of 24 march 2006, CPCE,
    art. L. 34-1)    		 12 months
    To carry out satisfaction surveys or request feedback  Legitimate interest of Nova to carry out satisfaction surveys aimed at collecting the impressions of its Customers 5 years
    Sending our newsletter Consent Until you withdraw your consent
    Organisation of our communication events (managing registration, communication in relation to the event you have registered for) Legitimate interest Up to 15 days after the last event you registered for.
    Prospecting in relation to services similar to those already purchased by you Legitimate interest of Nova Up to 3 years from our last contact with you.

    You have the right to object to receiving our commercial prospecting
    Management of an opposition list Legitimate interest of Nova to no longer send prospecting to its customers who have objected For 3 years from the time you exercise your right to object

    2.3. Who are the recipients of your Customer Information ?

    2.3.1. To our teams

    Your Information are communicated to all our teams who need it to carry out their missions within the framework of the commercial management of our Customers. For example: our Sales team to contract with you, our Support/Service team to handle your questions or complaints, etc.

    2.3.2. To our service providers

    We use different service providers for different reasons:

    Service provider’s name Reasons
    Google Managing Customer information
    2.3.3. To administrative or judicial authorities

    We may be required to disclose some of your Information to administrative or judicial authorities when we receive a court order.

    2.4 Where do we process your Customer Information?

    Our main computer servers are geographically located inside the European Union.

    Some of our subcontractors may host some of your Information outside the European Union. Where this is the case, we ensure in advance that our subcontractors take adequate safeguards that comply with the General Data Protection Regulation (GDPR).

    Below is a list of the data transfers outside the European Union that may take place and the adequate safeguards we take:

    Recipient’s name Adequate safeguards taken
    Google Standard Contractual Clauses
  • 3. POLICY FOR PROSPECTS

    This Policy explains the processing of personal data we do with your Information when you are a Prospect of Nova.

    3.1. What Information do we collect about our Prospects ?

    When you are a Prospect, we use different categories of Information about you, which you may provide to us or which we may collect indirectly (e.g. from publicly available sources).

    Categories of Information Description
    Identity Company name and company registration number (only for companies), surname and first name and title, address, telephone number, email, fax number,
    Prospect relationship Prospecting activities carried out by Nova, requests for documentation or tests received from the Prospect, direct requests received from the Prospect, correspondence with you, scheduling of appointments for demonstrations, etc.
    Registration to our communication events Name, first name, contact details (email, address, phone), eventually your employer and job title for professional events

     

    3.2. Why do we use Prospect Information and for how long?

    When you are a Prospect, We may use your Information for a variety of reasons:

    • we may have legitimate interests in using your Information (Our legitimate interest)
    • we may do so after obtaining your consent (Consent). You can withdraw your consent at any time.

    Below you will find the purposes for which we process your Information (the purposes of our processing) and the periods for which we retain your Information:

    Purpose Legal basis Period of data retention
    Managing our prospecting relationship (following up on our requests, responding to your requests, making appointments, etc.) Legitimate interest of Nova to develop its commercial activity Up to 3 years from the last contact with you.
    Sending our newsletter Consent For 3 years from our last contact with you or until you withdraw your consent
    Sending our white papers Consent For 3 years from our last contact with you or until you withdraw your consent
    Organisation of our communication events (managing registration, communication in relation to the event you have registered for) Legitimate interest Up to 15 days after the last event you registered for.
    Organization of our webinars Legitimate interest Up to 15 days after the last event you registered for.
    Prospecting by email to professionals for offers related to the prospect’s profession Legitimate interest of Nova to send its commercial offers to prospects who may be interested. For a period of 3 years from our first canvassing or last exchange with you. You may object to our canvassing.
    Prospecting by post mail Legitimate interest of Nova to send its commercial offers to prospects who may be interested. For 3 years from the date of our first canvassing or our last exchange with you. You have the right to object to such processing.
    Prospecting by phone Legitimate interest of Nova to send its commercial offers to prospects who may be interested. For 3 years from the date of our first canvassing or our last exchange with you. You have the right to object to such processing.
    Management of an opposition list Legitimate interest of Nova to no longer send prospecting to its customers who have objected For 3 years from the time you exercise your right to object

    3.3. Who are the recipients of your Prospect Information ?

    3.3.1. To our teams

    Your Informations are communicated to all our teams who need it to carry out their missions within the framework of the commercial management of our customers. Example: our sales team to send you commercial requests, to answer your requests for documentation, etc.

    3.3.2. To our service providers

    We use different service providers for different reasons:

    Service provider’s name Reasons
    HubSpot Lead generation and nurturing process
    Salesforce Demo/Quote for sales process

     

    3.4. Where do we process your Prospect Information?

    Our main computer servers are geographically located in the European Union.

    Some of our subcontractors may host some of your Information outside the European Union. Where this is the case, we ensure in advance that our subcontractors take adequate safeguards that comply with the General Data Protection Regulation (GDPR).

    Below is a list of the data transfers outside the European Union that may take place and the adequate safeguards we take:

    Recipient’s name Adequate safeguards taken
    HubSpot Standard Contractual Clauses
    Salesforce Standard Contractual Clauses
  • 4. POLICY FOR RECRUITMENT CANDIDATES

    This Policy explains the processing of personal data we do with your Information when you are a Candidates.

    4.1. What Information do we collect about our Candidates ?

    When you are a Candidate, we use different categories of Information about you, which you may provide to us or which we may collect indirectly (e.g. from third parties recruiters).

    Categories of Information Description
    Identity First name, last name, gender, nationality
    Contact information Address, email, telephone
    CV Professional experiences and job titles, diplomas, hobbies, driving license, languages spoken, skills, family situation, etc.
    Interview summary Salary expectations, mobility, skills assessment, etc.

    4.2. Why do we use Candidates Information and for how long?

    When you are a Candidates, We may use your Information for a variety of reasons:

    • You may consent to the use of your Information (Consent)
    • we need to process your Information prior to entering into a contract with you (Performance of a contract)

    Below you will find the purposes for which we process your Information (the purposes of our processing) and the periods for which we retain your Information:

    Purpose Legal basis Period of data retention
    Processing application and managing interviews Performance of a contract For the duration of the employment contract, when the candidate is hired.

    For unsuccessful candidates, the information are archived for up to 5 years from the decision not to hire them.
    CV database Consent Maximum 2 years from the last contact with you

    4.3. Who are the recipients of your Candidate Information ?

    4.3.1. To our teams

    Your Information are communicated to all our teams who need it to carry out their missions within the framework of the human resources management. Example: our recruiters, our HR managers, managers supervising the job on which you applied, Nova managing director, etc.

    4.3.2. To our service providers

    We use different service providers for different reasons:

    Service provider’s name Reasons
    Google Workspace For the HR applications process

    4.4. Where do we process your Candidates Information?

    Our main computer servers are geographically located in the European Union.

    Some of our subcontractors may host some of your Information outside the European Union. Where this is the case, we ensure in advance that our subcontractors take adequate safeguards that comply with the General Data Protection Regulation (GDPR).

    Below is a list of the data transfers outside the European Union that may take place and the adequate safeguards we take:

    Recipient’s name Adequate safeguards taken
    Google Standard contractual clause
  • 5. POLICY FOR USERS

    This Policy explains the processing of personal data we do with your Information when you are a User of our Jinko Platform.

    5.1. When does our Policy for Users not apply?

    Our Policy for Users does not apply to the processing of your Information that your Organisation carries out when you use our Platform.

    This is the case when:

    • your Organisation decides how to use your Information (when it decides to create a User account for you on the Platform, when it sets the SaaS Services you can access, when it withdraws your rights to use the Platform, etc.)
    • you use, store, exchange, import files, content, messages and information on the Workspace that is administered by your Organisation.

    In these cases, your Organisation acts as a data controller within the meaning of the law and must inform you itself of how and why it processes your Information.

    5.2. What Information do we collect about our Users?

    When you are a User of our Platform, we may use different categories of Information about you, which you may provide to us yourself or which we may collect indirectly.

    Categories of Information Description
    User personal account Username, password and email associated with the account, ID information provided by you or your Organisation, name of the organisation to which you belong, rights and privileges on the Platform defined by your Organisation
    Technical support Exchange with you (questions asked and answered, reporting of anomalies, opening of tickets)
    Connection data when you share content online Credentials, IP address, date and time and type of content created on the Platform.
    Usage metadata This metadata relates to actions taken on our Platform, such as the features you use most, the types of files downloaded, interactions with other Users, etc.
    Information about your device: This information concerns the type of devices you use to access our Platform (computer, tablet, mobile), the type of operating system and internet browser used, the resolution of your screen.

     

    5.3. Why do we use User Information and for how long?

    When you are a User of our Platform, We may use your Information for a variety of reasons:

    • we may need it to provide you with the SaaS Services subscribed by your Organisation in accordance with our T&Cs which apply to you (Performance of a contract)
    • we may need it to meet our legal obligations (Compliance with the law)
    • we may have legitimate interests in using your Information (Our legitimate interest)
    • we may do so after obtaining your consent (Consent). You can withdraw your consent at any time.

    Below you will find the purposes for which we process your Information (the purposes of our processing) and the periods for which we retain your Information:

    Purpose Legal basis Period of data retention
    Management of our contractual relationship with our Users (T&C’s) Performance of a contract The entire duration of our contractual relationship, itself determined by the duration of the Subscription taken out by your Organisation
    Provision of technical assistance to the User Legitimate interest of Nova to provide technical assistance to Users experiencing difficulties using its Platform During the entire duration of the contractual relationship
    Storage of connection data when publishing content online Compliance with law (Decree of 24 march 2006, CPCE,
    art. L. 34-1)    		 12 months
    Security of our Platform (prevention and detection of computer attacks) Legitimate interest of Nova to detect malicious behaviour in order to protect the security of its Platform, as well as the availability, integrity and confidentiality of the
    data contained therein (including personal data).    		 6 months
    Sending transactional emails related to the operation of the Platform Execution of a contract During the entire duration of the contractual relationship
    To carry out satisfaction surveys or request feedback  Legitimate interest of Nova to carry out satisfaction surveys aimed at collecting the impressions of its Users 5 years
    Sending our newsletter Consent For 3 years from our last contact with you or until you withdraw your consent
    Organisation of our communication events (managing registration, communication in relation to the event you have registered for) Legitimate interest Up to 15 days after the last event you registered for.
    Management of an opposition list Legitimate interest of Nova to no longer send prospecting to its customers who have objected For 3 years from the time you exercise your right to object
    Statistics on the use of SaaS Services  Legitimate interest of Nova to have metrics on the use made by Users of its Platform 25 months maximum

     

    5.4. Who are the recipients of your User Information ?

    5.4.1. To our teams

    Your Information may be communicated to all our teams who need it to carry out their missions in the framework of the commercial management of our Users. For example: our Support team to deal with your questions or complaints, etc.

    5.4.2. To your Organisation and other Users in your Organisation

    When you contribute to the Workspace managed by your Organisation, you may provide some your Information that your Organisation and other Users in your Organisation may consult and process.

    5.4.3. To our service providers

    We use different service providers for different reasons:

    Service provider’s name Reasons
    Amazon Web Services EMEA SARL Hosting of Jinkō® Database
    WP Engine Hosting
    5.4.4. To administrative or judicial authorities

    We may be required to disclose some of your Information to administrative or judicial authorities when we receive a court order.

    5.5. Where do we process the Information of our User?

    Our main computer servers are geographically located inside the European Union.

  • 6. COOKIES POLICY

    6.1. Preamble

    When you visit our Site as a Visitor, we can store or read cookies on your terminal. Our Cookies Policy also applies to our Users when they log in to our Platform.

    6.2. What is a cookie?

    A cookie is a small file stored or read on your terminal (computer, tablet, smartphone). They enable us to store information on your terminal in connection with your browsing on our Website. Reading and depositing cookies generally requires your consent; however, certain so-called technical cookies may be deposited without your consent.

    6.3. Who use these cookies ?

    Only Nova stores or read cookies on your terminal.

    6.4. What types of cookies do you use?

    We use different types of cookies:

    6.4.1. Technical cookies

    We use technical cookies necessary for the operation of our Website:

    • we store a cookie on your terminal to remember your choice (acceptance, refusal) concerning the cookies
    • we store cookies to securely authenticate you when you log in to our Platform

    These cookies do not require your prior consent due to their technical nature.

    Cookie name Purpose Duration
    Discreto To keep your choice about cookies 12 months
    WordPress_*, wordpress_logged_in_* To store authentication details on login Session
    6.4.2. Cookies for audience measurement

    We use audience measurement cookies in order to establish statistics on the number of visitors to our Site and statistics on the use of our Platform.

    Cookie name Purpose Duration
    Google Analytics

    _gid, _ga, _ga_*, _gat, _gat_*, __utm*

    		 To obtain statistics on the use of our website. 13 months max.
    6.4.3. Discre.to third party cookie
    Cookie name Purpose Duration
    Discret.to We use third parties cookies in order to share your preferences about cookies with any other website using the Discret.to consent manager services. 12 months max.

    6.5. How can I withdraw my consent?

    You can withdraw your consent at any time by setting it on our cookie manager.

  • 7. INFORMATION APPLICABLE TO ALL OUR POLICIES

    7.1. What are your rights?

    The Personal Data Protection Regulations give you several rights:

    Right of access You can ask us to access all the Information we hold about you.
    Right of rectification You can ask us to correct your Information if it is inaccurate.
    Right to object You can ask us to stop using your Information where we do so because of a legitimate interest. You may also ask us to stop receiving commercial marketing.
    Right to withdraw your consent Where any of our processing is based on your prior consent, you may withdraw your consent at any time. We will then stop using your Information for that processing.
    Right to erasure You can ask us to erase your Information and stop using it.
    Right to Limitation You may ask us to temporarily stop using your Information but require us to temporarily retain it.
    Right to portability You may ask us to provide you with an export of your Information in a reusable format and, where possible, ask us to transfer it to another organisation for reuse.
    Right to not to be subject to an automated individual decision You have the right not to be subject to a decision based solely on automated processing that produces legal effects concerning you or significantly affects you
    Right to set instructions regarding your data in the event of your death You have the right to set, update or revoke instructions regarding the retention, deletion or disclosure of your Information after your death.
    Right to lodge a complaint You may lodge a complaint with the authority responsible for protecting personal data (in France, the CNIL, www.cnil.fr) if you believe that your rights have not been respected.

     7.2. How to exercise your rights?

    To exercise your rights, please contact us using the details in the “How can you contact us ?” section.

    We will do our best to provide you with a response within one month.

    The rights you can exercise are defined by the GDPR and depend on the legal basis of our processing. There may therefore be occasions when we cannot accept a request to exercise rights because the right claimed cannot be exercised. If this is the case, we will inform you.

    We may also ask you for proof of identity to ensure that it is you who is exercising your rights and where we have no other means of ensuring this. You should only send us proof of identity if we ask for it.

    Please also note that we will only be able to answer requests that relate to the processing of personal data by us and that are indicated in this Privacy Policy. As a reminder, this Privacy Policy does not apply to processing carried out by your Organisation on the Workspace on which you collaborate or on the Workspace Data.