Privacy policy

Novalis is a limited partnership (“commanditaire vennootschap”/”societé en commandite”) under Belgian law, whose registered office is located at Ottergemsesteenweg-Zuid, 808, box 511, 9000 Ghent, Belgium and which is registered with the Crossroads Bank of Enterprises under number 0705.809.018 (RLE Ghent, section Ghent)  (“Novalis” or “we”). References to “you” and “your” are to persons external to Novalis (users of our Website, clients, prospects, suppliers and job applicants).

This Privacy Policy is intended to inform you about the processing of personal data that takes place via Novalis’ Website (https://noval.is) (“Website”) or the use of our contact details referenced on the Website (e-mails, phone numbers, post). This Privacy Policy must be read in conjunction with the Cookie policy, which can be found via [LINK]. This Privacy Policy applies only to the processing of data of physical persons, not of legal persons.

If you have further questions about this Website or about this Privacy Policy, you may contact us via the contact form.

This Privacy Policy may be modified, for example, in connection with new features on the Website or to comply with new legal, contractual or administrative obligations. We therefore recommend that you regularly consult this Privacy Policy. Important changes will be announced on our Website. This version of the Privacy Policy was last modified on the date referred to above.

The protection of your personal data is really important to us. We will ensure that your personal data is processed safely and lawfully, and always in accordance with applicable data protection legislation, and in particular with the General Data Protection Regulation (“GDPR”).

  1. Who is responsible for processing your personal data?

Novalis is the controller, in the meaning of the GDPR, for the processing of your personal data.

  • What personal data do we process?

We will process directly identifying information about you when you provide us with such personal data (for example, through a contact form on one of the pages on our Website our via e-mail) or when you contact us directly by e-mail, phone or fax.

Such personal information can include the following information:

  • Contact information (e.g. your name, email address, address, phone number, your job title, your company);
  • if you are a job applicant, your current role and name of your employer, the industry sector where you work, your CV, covering letter and LinkedIn profile;
  • Information in the framework of regulatory compliance (including compliance with all applicable laws and appropriate guarantees in respect of anti-money laundering, in particular but not limited to the 5th AML Directive).

We will also process certain non-directly identifying data when you visit our Website, such as the type of browser you are using, the operating system you are using, your IP address, browsing history etc.

  • Why do we process your data and under which legal basis?

Novalis undertakes not to process your personal data for any purpose other than the purposes mentioned below, unless you give Novalis express prior permission to do so. Novalis guarantees that your personal data will not be retained if Novalis no longer requires them for the execution of our investment activities and management, or if it is no longer subject to a statutory retention obligation.

For the technical and functional management of the Website

We process personal data for the technical and functional management of our Website and to make the Website easy to use. By using your data, we can check how our Website is used and we can improve its content and layout. This data also allows us to adequately secure our Website.

For this, we can process data such as your IP address, the pages you visit, the browser you are using, the sites you visited earlier, and the time and duration of your visit. We do this, for example, by using cookies. More information about the use of cookies can be found in our Cookie Policy to be found here[JOVE1] .

We process this data based on the legitimate interest of Novalis in providing a readily accessible, understandable, appropriate, comprehensive, well-functioning and secure Website.

To provide you with our services and manage your account

If you are one of our clients, we process your personal data to provide you with the services you requested us to perform as well as to send you our invoice. Such services include Novalis’ investment activities and management.

To this end, we can process data such as your name, your job, your company name, your address, your e-mail address, your invoicing information.

The above data are processed with a view to duly perform our investment activities and management in the ordinary course of business.

Novalis justifies the processing of personal data in this case on the basis that it is necessary for the performance of a contract, or in absence hereof, legitimate interest. We process this information for the performance of the contract with you. Without your personal data, we cannot perform the contract and provide you with our services.

To keep you informed of our services and activities and for direct marketing

We process your personal data to keep you informed of our activities, for example, with our newsletter, deal announcements, invitations to seminars, workshops or other events.

To this end, we can process data such as your name, your job, your company name, your address, your e-mail address and your preferred language.

We process this information based on our legitimate interests to keep our prospects informed of our activities and services, as well as with a view to personalizing our newsletters, deal announcements and invitations. You can object to this processing of your personal information at any time (see point 6).

In connection with the compilation and analysis of anonymized statistics

We process your personal data to compile and analyze anonymized statistics.

To this end, we can process data such as the sequence of pages you visit on the Website and the number of times you visit our Website.

We process this information based on our legitimate interests in continually subjecting our Website to evaluation and improvement. You can object to this processing of your personal information at any time (see point 6).

To answer your questions

If you ask us a question by telephone, via a contact form on the Website or by e-mail, we will process your personal data in order to answer that question.

For this, we can process data such as your name, your contact information, your correspondence with Novalis, and any other personal data you provide that may be relevant to answering your question.

We process this information based on our legitimate interests. You are free to choose to provide us with your personal data, and you object at any time (see point 6).

To make contact in the context of a selection and recruitment process

When you apply for a job through the Website or by e-mail, we process your personal data in order to contact you and to follow up your application.

For this, we can process data such as your name, your contact information, your correspondence with Novalis, your resume, and other documents you provide us with.

The processing of your personal data for this purpose is based on your request to take steps prior to entering into a contract.

To comply with our legal and regulatory obligations

Novalis has to comply with certain legal and regulatory obligations such as with respect to anti-money laundering, KYC declarations and sanction checks. We must also comply with our tax and accounting obligations.

For this, we can process data such as your name, your contact information, your correspondence with Novalis and your financial data.

The processing of your personal data for this purpose is based on the need for Novalis to respect a legal obligation we need to comply with.

Handling our own disputes

We may process your personal information to handle our own disputes and protect and enforce our rights.

For this, we can process data such as your name, your contact information, your correspondence with Novalis and your financial data.

The processing of your personal data for this purpose is based on our legitimate interests consisting in being able to safeguard our rights in the event of disputes.

  • Who has access to your personal data?

Website Hosting

Novalis makes use of [insert] to manage and host the Website. Cresco has entered into a processing agreement with such entities.

Novalis’ servers are located in Belgium and we will not transfer your personal data to countries outside Belgium or the European Economic Area except (i) at your request, or (ii) to the extent necessary for the institution, exercise or substantiation of a legal claim. In the context of the use of some software applications, personal data may however be temporarily transferred to countries outside the Economic European Area. In such a case, an adequate level of protection is provided through the use of the European Commission’s Standard Clauses and, if required, additional technical and organizational measures.

Google Tag Manager

Google Tag Manager is a tag management system provided by Google that we use on our Website. The Google Tag Manager allows us to add code and other snippets such as pixels to our Website. Google is only processing your IP address as a processor and according to the EU Standard Contractual Clauses.

Social media

Our Websites allows you to follow us on social media channels, e.g., LinkedIn and Twitter. We do not use these buttons to share your personal information with social media providers. When you click on a follow button, the relevant social media provider will gather your personal information directly from you. Please read the privacy notice of any social media provider with which you intend to share your personal information.

Other third parties

We may share your personal information with:

  • (sub)contractors for assisting us in fulfilling the purposes listed above;
  • our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice;
  • any competent judicial, police, governmental or administrative authorities if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, a binding decision of an administrative authority or a court order;
  • investors and other relevant third parties in in the event of a potential sale or other corporate transaction related to Novalis.

Novalis will only share your personal information with these third parties provided that they comply with GDPR if they act as independent controllers or based on a data processing agreement if they act as processors. For a detailed list of these third parties, please contact us via the contact form, by post to Ottergemsesteenweg-Zuid, 808, box 511, 9000 Ghent (Belgium).

  • How do we protect your personal data and how long do we keep your personal data?

Novalis takes reasonable security measures to protect your personal data from destruction, loss, modification or any other unauthorized processing.

Novalis does not store your personal data for longer than necessary for the purposes for which it is stored. If you would like to find out how long we keep your personal information for a particular purpose you can contact us by contact form, by post to Ottergemsesteenweg-Zuid, 808, box 511, 9000 Ghent (Belgium)

  • What rights do you have and how can you exercise your rights?
  • You have the right to inspection of and access to your personal data. This allows you to find out which personal data we process about you. You have the right to access your personal data and the right to verify how they are being used. You may obtain a free copy of your available personal data at any time by simply making a request to this effect, including proof of your identity by attaching a copy of your identity card to your request.
  • You have the right to correct your personal data. This allows you to correct or complete incorrect or incomplete personal data that we process about you.
  • You have the right of deletion of your personal data. This allows you to permanently delete the personal data we process about you. We are not always obliged to delete your personal data at your request – this right only applies in the cases and to the extent provided for by law.
  • You have the right to limit the processing of personal data relating to you. This allows you to freeze our use of your personal data without deleting it. We are not always obliged to limit the processing of your personal data at your request – this right only applies in the cases and to the extent provided for by law.
  • You have the right to object to the processing of your personal data. This allows you to object to the further processing of your personal data. We are not always obliged to accept your objection – this right only applies if we process your personal data on the basis of our legitimate interest. You may oppose the processing of your personal data at any time if your objection is based on serious and legitimate reasons. If you wish to oppose the use of your personal data for direct marketing purposes, you do not have to give any reasons for this. The processing of personal data by Novalis is not carried out on the basis of automated decisions; in other words it is not carried out without human intervention. Novalis does not engage profiling on the basis of the available personal data.
  • You have the right to withdraw your consent when the processing of your personal data takes place on the basis of your consent. Withdrawal of your consent does not affect the lawfulness of the processing based on consent before withdrawal
  • You have the right to object to certain types of processing, on grounds relating to your particular situation, at any time insofar as that processing takes place for the purposes of legitimate interests pursued by us or by a third party. We will be allowed to continue to process your personal information if we can demonstrate “compelling legitimate grounds for the processing which override your interests, rights and freedoms” or we need this for the establishment, exercise or defense of legal claims. You can always object to the processing of your personal data for direct marketing purposes.
  • You may have the right to data portability. This allows you to easily transfer, copy or move personal data from one controller to another. This right can only be exercised if the processing is based on your consent or on an agreement concluded with you.

You can direct your request based on the above rights and your complaints by post to Ottergemsesteenweg-Zuid, 808, box 511, 9000 Ghent (Belgium)

You also have the right to file a complaint with the supervisory authority of the place where you live. For Belgium this is the Belgian Data Protection Authority. It can be reached by mail at Rue de la Presse – Drukpersstraat 35, 1000 Brussels, by e-mail at the following address: contact@apd-gba.be and by phone at: +32 2 247 48 00.