Novel Privacy Policy

Effective as of March 10, 2022

1. Purpose of this Privacy Policy 

Please read the following policy to understand how your personal information will be treated as  you make full use of our Application or access the Website. When we talk about our Application or our Service, we are referring to the Novel application (“Application”), a mobile application  

operated by Cadenza, Inc. (“Cadenza”) and its subsidiary (“Novel”) in conjunction with the website located at www.benovel.com (“Website”; the Application and Website are collectively referred to herein as  “Service”), and any services provided by us through such Application and/or Website. When we  talk about Novel, “we”, ‘’our’’ or ‘’us’’ in this policy, we are referring to Cadenza, Inc., the  company that provides the Application and Website. If you have any questions, concerns or  complaints related to this Privacy Policy or our processing of your personal information, please  email us here: info@benovel.com. This email address is monitored on a regular basis, and we aim  to respond to your query as soon as possible. 

The Privacy Policy has three main purposes:

1. Explain the way we use information that you share with us in order give you a great  experience with our Application; 

2. Ensure that you understand what information we collect with your permission, what we  do with it and with whom we share it; and 

3. Explain your rights under applicable law. 

All the information we collect is related to providing our Service. By agreeing to our Privacy Policy, you give us the right to collect your information as detailed in this Privacy Policy and use 

it for the purposes described in this Privacy Policy. If you don't agree with the terms of this Privacy Policy, then please don't use the Service.

2. Information we collect 

The information we collect can be divided into the following broad categories:  

• Technical Data includes internet protocol (IP) address, your login data, device type,  device version, browser type and version, browser plug-ins types, time zone setting and  location, traffic data, search criteria, weblogs and other communications data, operating  system and platform and other technology on the devices you use to access the Service. 

• Usage Data includes information about how you use our Service, such as the particular  pages you interact with, how often and how long you use the Service, surveys, and the  emails you interact with. 

• Verification Data includes proof of identity and proof of address, as further detailed in  our Subject Access Request Form. 

• Financial Data includes payment card details you provide, including expiration date. It  also includes details about your payment history and services or products you have  purchased from us. 

• Identity Data includes your full name, email address, date of birth, username and password, and your username(s) and your friends’ usernames that we may access  through the social media accounts you give us access to. 

• Image Data includes photographs and videos of you that you upload or that we may  access through the social media accounts you give us access to. 

More specifically, we may collect and store the following information relating to you:

2.1 Anonymous data

When you visit our Service, we collect some basic information that does not identify individual  users. This includes which pages are visited, which videos are viewed, and any feedback from  our visitors. We then aggregate this information with other pieces of information to improve our  Service and make your experience on the Service as valuable and efficient as possible. We may  also collect and accumulate anonymous data that will help us understand and analyze the online experience of our users. For instance, we may accumulate visitor data relating to referring  domain names, the type of browsers used, operating system software, screen resolutions, color  capabilities, browser plug-ins, language settings, cookie preferences, search engine keywords  and JavaScript enablement. 

2.2 Direct Interactions 

We collect information from you when you voluntarily submit information directly to us or via  our Service. For members, this refers to personal data you provide when, for example, you  create an account, complete a profile, or by corresponding with us via phone, email or live chat.  If you connect to the Service using credentials from a third-party application (e.g., Facebook),  you authorize us to collect your authentication information, such as your username and 

encrypted access credentials. We may also collect other information available on or through  your third-party application account, including, for example, your name, profile picture, country,  hometown, email address, date of birth, gender, friends’ names and profile pictures, and  networks. 

You may decide to provide us with another person's contact information so that person may be  invited to download the Application or so that we may facilitate your communication with other  people through the Service (such as when you upload an address book or a contact list). You  may also provide us with another person's contact information for purposes of delivering  information through social networking applications. We store the information that you provide  so that the respondents may be added to your network, and also to send reminders of the  invitations. All invitees are provided with the option not to receive further invitations from us. 

In addition to the information we may collect upon your initial registration, we may ask you for  personal information at other times. We will not share that information in a manner that  identifies you as an individual with any other entity unless we have your permission.  

2.3 Information submitted by you for inclusion on the Application 

Information and media files you may upload to the Service will be posted on the Service, subject  to our Terms of Use and accessible to all our users; we have no control over how such users will  use such materials. Please remember that if you post any of your personal information in  public areas of the Service, such as in online forums or chat rooms, such information may be  collected and used by others over whom we have no control. We are not responsible for the use  made by third parties of information you post or otherwise make available in public areas of the  Application. You should take care to not use personal information in your screen name or other  information that might be publicly available to other users.

2.4 Tracking technologies 

We use “cookies” and similar tracking technologies (as described in Section 5 below and in our  Cookie Policy) to track your activities on our Service, and may also receive data about you if you  visit other websites employing our cookies. When we send you emails that include a link to the  Website, that link may contain an alphanumeric identifier that allows us to identify the person  to whom we sent the message so that we can personalize our content for that individual. 

2.5 Automated technologies or interactions 

As you interact with our Service, we may automatically collect technical and usage data about  your device, browsing actions and patterns. For example, we collect information which may  include your IP address, browser type, your location, language preferences, device information  and access times. While an IP address does not identify an individual by name, it may, with the  cooperation of the ISP, be used to locate and identify an individual. Your IP address can reveal  what geographic area you are connecting from, or which ISP you are using. Finally, other  websites you visit have IP addresses, and we may collect the IP addresses of those websites and  their pages. We also collect IP addresses for system administration and to report aggregate  information to any sponsors. We may also receive information from our web logs, which  automatically record anything a web server sees, which may include email addresses you enter  into a form or pages viewed by a user at a particular IP address. We collect this personal data  by using cookies, pixel tags and other similar tracking technologies. The sole purpose of  passively collecting your information is to improve your experience when using our Service.

2.6 Promotions & surveys 

From time to time, we may offer you the opportunity to participate in promotions such as  sweepstakes, contests, offers, and/or surveys (“Special Promotions”) through the Service. A  Special Promotion may be governed by a privacy policy and/or terms and conditions that are  additional to, or separate from, this Privacy Policy and our Terms of Use. If the provisions of the  Special Promotion’s privacy policy or terms and conditions conflict with this Privacy Policy or  our Terms of Use, those additional or separate provisions shall prevail. If you participate in a  Special Promotion, we may ask you for certain information in addition to what is stated in this  Privacy Policy, including personal information. That additional information may be combined  with other account information and may be used and shared as described in this Privacy Policy or in the Special Promotion. 

2.7 Information received from our service providers and partners 

We may also receive information about you from our service providers and partners, which we  use to personalize our Service, and to offer you opportunities to purchase products or services  that we believe may be of interest to you. 

2.8 Payment data 

If you purchase a subscription to our Service or make other purchases through the Service, your  credit or debit card information (such as card type and expiration date) and other financial data  that we need to process your payment may be collected and stored by us and/or the payment  processors with which we work. We may also collect some limited information, such as your  postal code, mobile number, and details of your transaction history, all of which are necessary  to process your purchase. In addition, the payment processors generally provide us with some  limited information related to you, such as a unique token that enables you to make additional  purchases using the information they’ve stored, and your card’s type, expiration date, and  certain digits of your card number.

3. How we use the information we collect

We have set out below, in a table format, a description of all the ways we process your personal  data, and the legal basis we rely on to do so.

Purpose/Activity

Type of Data

Legal Basis

To allow you to use the Service

Technical Data 

Usage Data 

Image Data

Consent

To allow you to create an account

Identity Data 

Usage Data

Consent

To register you as a paid member and process  renewal of your membership

To register you as a paid  member and process  renewal of your  

membership

To register  

you as a paid member and  process renewal of  

your membership

To manage our relationship with you. For example  general inquiries such as how the Service works,  complaints and payment queries

Any data you choose to  share with us or request  us to view

Consent

To administer and protect the Service (including  troubleshooting, fraud prevention, spam  prevention, security incident prevention and  correction, data analysis, testing, system  maintenance, support, reporting and hosting of  data), operate the Service (including notifying you  of any changes), optimize your user experience, and  send you service and support messages such as  updates, patches and security alerts

Financial Data 

Identity Data 

Technical Data 

Usage Data 

Image Data

Consent

To send you promotional messages, marketing, and  other such information we think may be of interest  to you, either directly or through one of our  partners; you may opt out from receiving certain  messages, as described in Section 7

Financial Data 

Identity Data 

Technical Data 

Usage Data

Consent

To enable you to partake in a prize draw,  competition, referral scheme, rewards program,  promotional activities, events, complete a survey or  invite you to participate in Application testing

Financial Data 

Identity Data 

Technical Data

Consent

To analyze your use of the Service and deliver  relevant content, for example by providing  customized, personalized, or localized content,  recommendations and features.

Usage Data

Consent

To enable third parties to advertise products or  services in which you may be interested, including  via emails

Identity Data 

Usage Data 

Technical Data

Consent

To enforce this Privacy Policy, our Terms of Use,  and any other terms that you have agreed to,  including to protect the rights, property, or safety  of our users, or any other person.

Identity Data 

Usage Data 

Technical Data 

Image Data

For purposes  of legitimate interests

To maintain and retain records in connection with  actual and potential legal claims and regulatory  investigations; and for governance & compliance purposes

Financial Data 

Identity Data 

Usage Data

Technical Data

Necessary for  the  

compliance with a legal  

obligation to  which we are  subject

We will only use your personal data for the purposes for which we collected it, unless we  reasonably consider that we need to use it for another reason, and that reason is compatible  with the original purpose.  

Please note that we may process your personal data without your knowledge or consent, in  compliance with the above rules, where this is required or permitted by law.

4. How we share the information we collect

This section describes how the information collected or generated through your use of the  Service may be shared by us with third parties. 

4.1 Service providers  

We may from time to time, share your information with third-party service providers to perform  functions and process user data and help provide our Service, consistent with this Privacy Policy.  For example, we work with analytics providers to help us understand the use of our Service.  Where a third party processes user data on our behalf, it is subject to security and  confidentiality obligations consistent with this Privacy Policy and applicable law; we only permit  them to process your personal data for specified purposes and in accordance with our  instructions. Where a third party processes user data on its own behalf, its processing is subject  to its own Privacy Policy and applicable law.

To provide you with the best experience, we use third parties who automatically process your  Usage Data on our behalf. Where possible, we will make sure this data is anonymized. 

For your information, click here to view some examples of how third parties process your  personal data. 

4.2 Promotions and surveys 

When one or more of our business partners co-sponsor a service, promotion,  contest/sweepstakes, or survey, we may share some or all of the information collected in  connection with such service, promotion, contest/sweepstakes, or survey with the co-sponsor(s). If we intend to share such information, you will be notified prior to the collection of  that information. If you do not want your information to be shared, you will be able to choose  not to allow the transfer by not using or signing up for that particular service, promotion,  contest/sweepstakes, or survey. 

4.3 Marketing and advertising 

Our policy is not to disclose personal information collected online to a third party for direct  marketing purposes without your opt-in. We may share information with advertising partners in  order to send you promotional communications about our Service or to show you more tailored  content, including relevant advertising for third-party products and services that may be of 

interest to you, and to understand how users interact with advertisements. The information we  share is in a de-identified format (for example, through the use of hashing) that does not  personally identify you. We may also share aggregate user information in a non-personally  identifiable manner with advertisers and other third parties in order to present to users more  targeted advertising, products and services. We do not provide any personally identifiable  information to third-party advertising companies without your approval. Note, however, that if  an advertiser asks us to show an advertisement to users with certain characteristics (for  example, women ages 18-24) or a segment of that group (for example, women ages 18-24 who  have viewed certain categories of content) and you respond to that advertisement, the third party advertising company may conclude that you have the characteristics of the audience that  they are trying to reach.  

4.4 Affiliate networks 

If you access our Service through an offer that you received or purchased from a third party, we  may also share information with that third party about your use of the Website, such as  whether and to what extent you have used the offer, activated an account, or actively used our  Service. 

We may also share aggregated data relating to video views with our partners.

5. Cookies and other tracking technologies  

A cookie is a small text file that is placed on your computer, mobile phone, or other device when  you visit a website. The cookie will help website providers to recognize your device the next  time you visit their website. There are other similar technologies such as pixel tags (transparent  graphic images placed on a web page or in an email, which indicate that a page or email has  been viewed), web bugs (similar to pixel tags), and web storage, which are used in desktop  software or mobile devices. 

There are also technologies such as mobile device identifiers and SDK integrations to help  companies recognize your device when you return to an app or otherwise use a service. 

Our policy regarding cookies can be found here.

6. Information collected by third parties 

Some entities that have links on our Service may collect personally identifying information about  you when you access or utilize those links. We do not control the collection or use of such  information, and the practices of those entities are not covered by this Privacy Policy. Links can  be from content providers and/or partners who may use our logo and/or style as a result of a  co-branding agreement, yet they may still not follow the same policies as this Privacy Policy with  respect to collection of your personal information. In addition, our Application includes social  media features, such as the Facebook Like button. These features may collect your IP address,  which page you are visiting on our Application, and may set a cookie to enable the feature to  function properly. Social media features and related widgets are either hosted by a third party  or hosted directly on our Application. Your interactions with these features are governed by the  privacy policy of the company providing them.

Please read these third parties’ privacy policies to find out how they collect and process your  personal information.

7. Email Opt-out 

Users who no longer wish to receive email updates or other notifications may opt out of  receiving these communications by following the instructions contained in the applicable email.  Please know that such a decision will not stop advertising or content that is generated prior to  the time when we can accomplish the removal of your information.

8. Credit Card Processing  

Credit card transactions are handled by a third-party processor that receives credit card  numbers and other personally identifying information only to verify credit card accounts and  process transactions.  

Credit card security is an important aspect of the online experience. We use encryption  technology to keep your credit card information safe. To ensure that your information is even  more secure, once we receive your credit card information, it is stored on a server that isn't  accessible from the Internet.

BY ACCEPTING THE PRIVACY POLICY, YOU EXPRESSLY AUTHORIZE US TO USE AND SHARE WITH  CERTAIN TRUSTED BUSINESS PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED  OUTSIDE THE COUNTRY OF YOUR RESIDENCE (INCLUDING COUNTRIES WHICH DO NOT  PROVIDE THE SAME LEVEL OF PROTECTION FOR THE PROCESSING OF PERSONAL DATA AS THE  COUNTRY OF YOUR RESIDENCE), THE INFORMATION PROVIDED BY YOU TO US, EVEN IF SUCH  INFORMATION IS COVERED BY LOCAL BANKING SECRECY LAWS. YOU ACKNOWLEDGE AND  AGREE TO THE IMPORTANCE OF SHARING SUCH INFORMATION FOR THE PROCESSING OF YOUR  PURCHASE(S) AND ALSO AGREE THAT, BY ACCEPTING THIS PRIVACY POLICY, WHERE APPLICABLE  AND TO THE EXTENT PERMITTED BY APPLICABLE LAW, YOU EXPRESSLY WAIVE YOUR RIGHTS  UNDER SUCH BANK SECRECY LAWS WITH REGARD TO US AND ANY TRUSTED BUSINESS  PARTNERS AND SERVICE PROVIDERS, WHICH MAY BE LOCATED OUTSIDE YOUR COUNTRY OF  RESIDENCE. THIS CONSENT IS GIVEN FOR THE DURATION OF YOUR RELATIONSHIP WITH US.

9. Security  

We have put in place appropriate security measures to prevent your personal data from being  accidentally lost, altered or disclosed, used or accessed in an unauthorized way. In addition, we  limit access to your personal data to those employees, agents, contractors and other third  parties who have a business need to know it. They will only process your personal data on our  instructions and they are subject to a duty of confidentiality. However, the transmission of data  via the internet is not completely secure and we cannot guarantee that unauthorized parties will  not be able to defeat those measures: unauthorized entry or use, hardware or software failure,  and other factors may compromise the security of our user information at any time. 

We have put in place procedures to deal with any suspected personal data breach and will  notify you and any applicable regulator of a breach where we are legally required to do so.

10. Children and COPPA compliance 

We have designed this privacy policy in order to comply with the Children's Online Privacy  Protection Act. Our Service is not directed to children under the age of 13 years. However, in  some countries, stricter age limits may apply under local law. We do not knowingly collect  personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If  we obtain actual knowledge that we have collected personal information about a child under the  Age Limit, that information will be immediately deleted from our database. Because we do not  collect such information, we have no such information to use or to disclose to third parties. If a  parent believes that his or her child has submitted personal information to us, he or she can  contact us via e-mail or postal mail as listed below. We will promptly delete the information  upon learning that it relates to a child under the Age Limit. Please note that it is possible some  of this information may remain archived in web logs and back-up archives after we delete the  information from our active database. 

We believe that parents should supervise their children’s online activities and consider using  parental control tools available from online services and software manufacturers that help  provide a kid-friendly online environment. These tools can also prevent children from otherwise  disclosing online their name, address and other personal information without parental  permission.

11. Business transitions 

In the event we go through a business transition, such as a merger, acquisition by another  company, or sale of a portion of our assets, users' personal information will, in most instances,  be part of the assets transferred. In such instance, the new owners may use your personal data  in the same way as set out in this Privacy Policy.

12. Users located outside the United States 

We make an effort to protect the personal information of all users of our Service. If you are  unsure whether this privacy policy is in conflict with the rules applicable where you are located,  you should not submit your personal information. IN ADDITION, IF YOU ARE LOCATED WITHIN  THE EUROPEAN UNION, YOU SHOULD NOTE THAT YOUR INFORMATION WILL BE  TRANSFERRED TO THE UNITED STATES, THE LAWS OF WHICH MAY BE DEEMED BY THE  EUROPEAN UNION TO HAVE INADEQUATE DATA PROTECTION. Users of our Service located in  countries outside the United States who submit personal information do thereby consent to  the transfer of that information to and/or storage of the information in the United States.

13. EU users’ rights under the GDPR  

If you are located in the European Union, or if the EU’s General Data Protection Regulation  (“GDPR”) otherwise applies to your data as processed by us, you have the right to: 

  1. request access to your personal data. This enables you to receive a copy of the personal  data we hold about you and our full list of third parties who process your data, and to  check that we are lawfully processing it. 

  1. request confirmation as to whether your personal data is being processed.

  1. request the correction of your personal data that you consider to be inaccurate. This  enables you to have any incomplete or inaccurate data we hold about you corrected. However, we may need to verify your identity and the accuracy of the new data you  provide to us. 

  1. request erasure of your personal data. This enables you to ask us to delete or remove  personal data, for example: i) where there is no good reason for us continuing to  process it; ii) where you have successfully exercised your right to object to processing  (see below); iii) where we may have processed your information unlawfully; iv) where  we are required to erase your personal data to comply with local law. Note, however,  that we may not always be able to comply with your request of erasure for specific legal  reasons and our need to keep appropriate archives for our business operations. These  reasons will be notified to you at the time of your request. In addition, as explained in  Section 2.3, certain information may always be publicly available to others and other  information is made publicly available to others by default.

  1. object to processing of your personal data. This enables you to object to the processing  of your personal data if you feel it impacts on your fundamental rights and freedoms.  For example, this can be where we are processing your personal data for direct  marketing purposes. In some cases, we may have compelling legitimate grounds to  process your information which can override your right to object. 

  2. request restriction of processing of your personal data. This gives you the option to ask  us to suspend the processing of your personal data in the following scenarios: i) if you  want us to establish the data’s accuracy; ii) where our use of the data is unlawful, but  you do not want us to erase it; iii) where you need us to hold the data, even if we no  longer require it e.g. to establish or defend legal claims; or iv) you have objected to our  use of your data, but we need to verify whether we have overriding legitimate ground to  use it. 

  3. request transfer of your personal data. If you request us to do so, we will provide to  you, or a third party of your choice, your personal data in a commonly used, machine-readable format. Note that this right only applies to automated information which you  initially provided consent for us to use, or where we have used the information to  perform a contract with you. 

  4. withdraw consent to the processing of your data. If you request us to do so, we will no  longer process your data. However, this will not affect the lawfulness of any processing  carried out before you withdraw your consent. If you withdraw your consent, we may  not be able to provide our Service for you. Also, we will advise you of this at the time  you withdraw your consent. 

  5. not have a decision made about you based solely on automated processing. 

If you wish to exercise any of the rights set out above or request details about the specific legal  basis we are relying on to process your personal data, please email us at info@benovel.com using  the Subject Access Request Form. 

We will respond to you within 30 days of receipt of your request. Occasionally it may take us  longer than 30 days if your request is particularly complex, or you have made a number of  requests. In this case, we will notify you and keep you updated. 

We may need to request specific information from you to help us confirm your identity and  ensure your right to access your personal data (or to exercise your other legal rights). This is a  security measure to ensure that your personal data is not disclosed to any person who does not 

have the right to receive it. We may also contact you to ask you for further information, in  relation to your request, to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of your other legal  rights). However, we may charge a reasonable fee if your request is clearly unfounded,  repetitive or excessive. Alternatively, we may refuse to comply with your request in these  circumstances. 

You have the right to make a complaint at any time to the Information Commissioner’s Office  (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would,  however, appreciate the chance to deal with your concerns before you approach the ICO, so  please email us at info@benovel.com in the first instance.

14. Data retention 

If you are located in the European Union, or if the GDPR otherwise applies to your data as  processed by us, we will only retain your personal data for as long as necessary to fulfil the  purposes for which we collected it, including for the purposes of satisfying any legal, accounting,  or internal reporting requirements. To determine the appropriate retention period for personal  data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of  harm from unauthorized use or disclosure of your personal data, the purposes for which we  process your personal data and whether we can achieve those purposes through other means,  and the applicable legal requirements. 

In some circumstances we may anonymize your personal data (so that it can no longer be  associated with you) for compliance, governance, legal and/or regulatory purposes, in which  case we may use this information indefinitely without further notice to you.

15. Cooperation with law enforcement; fraud protection 

We fully cooperate with law enforcement agencies in identifying those who use our Service for  illegal activities. We reserve the right to disclose information about members who we believe  are in violation of applicable laws or regulations, or as required to respond to a subpoena, court  orders or other legal process requiring such disclosure. We also reserve the right to report to  law enforcement agencies any activities that we reasonably believe to be unlawful, and to  exchange information with other companies and organizations for fraud protection.

16. Changes to this Privacy Policy 

Occasionally we may, in our discretion, make changes to this Privacy Policy. When we make  material changes to this Privacy Policy, we’ll provide you with prominent notice as appropriate  under the circumstances, e.g. by displaying a prominent notice within the Application and Website, or by emailing you. In some cases, we will notify you in advance, and your  continued use of the Service after the changes have been made will constitute your acceptance  of the changes. Please therefore make sure you read any such notice carefully. If you object to  any of the changes, you have the opportunity to delete your account and any associated  information. Once deleted, your details will be non-recoverable.

Please note that if you opt out of receiving notices from us, change notices will still govern your  use of the Service, and you are responsible for reviewing such legal notices for changes, as  posted on the Application and Website.

17. Who we are

For the purposes of the GDPR, Cadenza, Inc., a Delaware corporation located at 137 N. Wetherly Dr., Apt 202, Los Angeles, CA 90048, is the Data Controller and is responsible for your personal data.  This means that we determine the purposes and ways of the processing of your personal data.