Privacy Notice

Last updated: March 2023

About this Privacy Notice

This Privacy Notice is meant to give you information about what personal data we collect about you, how we use it, why we use it, and how you control the data processing.

Table of Contents

1. The Basics:
   1. Who We Are
   2. Our Role
   3. Definitions
2. Personal Data we Collect as a Processor
3. Personal Data We Collect as a Controller, How We Use it, and Why
   1. Website Visitors
   2. Users
4. Our Marketing Activities
5. Sharing the Personal Data We Collect
6. International Transfers
7. Security
8. Your Rights – How to Control Our Use of Your Personal Data
9. Data Retention
10. Cookies and Similar Technologies
11. Third-Party Services
12. Children
13. Changes to the Privacy Notice

1. The Basics
   1. Who We Are
      1. Noti-Fire Apps Ltd. d/b/a offers an open-source notification infrastructure, built for engineering teams to help them build rich product notification experiences. Our offices are located at Derech Ben Gurion 132, Ramat Gan, Israel, and our registration number is 516509775. 
      2. If you have questions about our company or your privacy, or want to exercise your rights, you can contact us at support@novu.co.
   2. Our Role: Controller and Processor. Certain data protection laws, including the laws in the EU, differentiate between a party that determines why and how personal data is processed (called a “controller”) and a party that processes personal data solely on the controller’s behalf and according to the controller’s instructions (called a “processor”). We are the controller in respect of the processing described in this Privacy Notice. That said, in respect of certain personal data, we serve as a processor. Please see the section below on Personal Data We Collect as a Processor for more information.
   3. Definitions and Recommendations
      1. When we refer to “services“, we mean our open-source notification infrastructure, built for engineering teams to help them build rich product notification experiences.
      2. When we refer to “personal data“, we mean information that is defined as personal data under law. This includes information that identifies you directly or indirectly, including unique identifiers like IP addresses or cookie IDs.
      3. When we refer to “you“, we mean visitors to our website and users of our services.
      4. This Privacy Notice is meant to be read together with our Terms of Service, which you can find at https://novu.co/terms/. In general, we recommend that you routinely review this privacy notice and your preferences on our services.
   4. A Note on Legal Bases. Certain jurisdictions only allow the processing of personal data where a legal basis has been established. Under the EU’s General Data Protection Regulation (“GDPR“), the possible legal bases include (but are not limited): your consent, the processing is necessary to perform a contract with you, the processing is necessary to fulfill our legal obligations, or a company has a legitimate business interest to process your personal data. Where we are a controller, we only collect and process data where we have established a legal basis. Below you can find more details about specific legal bases.
2. Personal Data We Collect as a Processor. We process certain personal data about our customers’ end subscribers or contacts when we provide services to our customers. In that case, we serve as a processor and the customer serves as a controller. We process that data on behalf of the relevant customer and according to its instructions. If you are an end subscribers or contacts of one of our customers, we may process personal data about you that includes your full name, email address, phone number, gender, photograph, data of birth, and IP address. We may share this data with the relevant customer. To learn more about our processing activities in this capacity or to exercise your privacy rights regarding them, please contact the applicable customer directly.
3. Personal Data We Collect as a Controller, How We Use It, and Why. Below is a description of the types of personal data we collect, how we use it, and the reason why we consider each use lawful. You have no legal obligation to provide us with personal data, but if you don’t provide us with certain information, we may not be able to provide you with the associated services.
   1. Website Visitors. When you visit our site, we may collect the following types of data about you.
      1. Contact Form Information – When you send us a message through our site, we collect any data you provide, such as your name, company, email, and the content of your message. When you sign up for our newsletters, we collect your email address. 
         
         How We Use this Data: To respond to your message and to provide you with newsletters about our products and services if you have requested to receive them.
         
         Legal Basis: We process this personal data based on the performance of a contract with you when we respond to your inquiries or send you newsletters.
      2. Activity and System Data (Cookies) – When you visit our site, we automatically collect data about your computer or mobile device, including personal data such as your IP address, device ID, browsing history (e.g. the other sites you’ve visited before ours), and your activity on our site (e.g. what pages you visited, for how long, and what links you clicked on). For more information about the cookies we use and how to adjust your preferences, see the Cookies and Similar Technologies section below. 
         
         How We Use this Data: We mainly use this data to generate analytics data about the use of our site so we can maintain and improve the site and develop new products or services. We also use statistical data to prevent fraud and protect the security of our site.
         
         Legal Basis: We process this personal data based our legitimate interests to develop and improve our products and services, and to prevent fraud. Additional information regarding Our Marketing Activitiesis provided below.
   2. Users. If you are a user of our services, we collect the following information from and about you.
      1. Registration Data – In order to access our services, you must first create an account. When creating an account, you will be asked to provide your full name and email address. If you register for our services using a third-party account, we also receive personal data about you from that service. For example, when you register using your Github account, we receive your email address, full name, GitHub nickname/username, and profile photo.
         
         How We Use this Data: We use your registration information to allow you to access to our services, save your preferences, protect the security of our services, prevent fraud, and address any issues that arise. We use your contact details to communicate with you about our services. In addition, we use this data in order to generate analytics data so that we can maintain and improve our services and develop new products or services. We also use your contact details to send you informational newsletters and promotional materials about our products and services. For more information about our marketing activities and how you can control your preferences, see the section on Our Marketing Activities below.
         
         Legal Basis: When we process your registration data to provide you with our services, we do so to perform a contract with you, in this case our Terms of Service. When we process your registration data to maintain our services, including to prevent fraud, protect the security of and/or address issues with our services, or for analytics purposes, we do so on the basis of our legitimate interest to maintain our assets. When we use your contact details to send you newsletters and promotional materials, we do so based on our legitimate interest to market our products and services.
      2. Activity and System Data (Cookies) – We collect data about your device and your activity, as described more fully above in section 3.1.2, when you use our services.
4. Our Marketing Activities. As described above, we may use personal data we collect for advertising and marketing purposes. We try to limit the marketing material we send to a reasonable and proportionate level. Below we describe how you can control the marketing material you receive from us.
   1. Email Marketing and Services Communications
      1. We use your contact details to send you informational about our products and services.
      2. You can stop the delivery of all marketing emails by following the “unsubscribe” link in any messages we send you. Alternatively, you can contact us at support@novu.co to request to unsubscribe. 
      3. Note that if you are a registered user, we may need to contact you about administrative or service-related issues as part of the services we provide to you. This is not marketing communication and you will continue to receive these messages even if you opt-out of marketing emails.
5. Sharing the Personal Data We Collect. We share your personal data as follows:
   1. Customers. If you use our services in connection with a company that is our customer, that customer may have access to information about your use of our services. For example, a user with an administrator account may be able to see your data.
   2. Service Providers. Below is a list of the types of service providers we use, the service each provides, and the types of data shared with each. All service providers have agreed to confidentiality restrictions and have undertaken to use your personal data solely as we direct.

      Type of Service	Description	Personal Data Shared
      Cloud service providers	We use service providers that offer cloud computing services. They offer us space on their servers for us to store our files and programs, including your personal data.	All personal data that we collect from you is stored on third party servers.
      Communication and support	We use independent vendors to assist us in sending out emails and communicating with our clients, including for the purposes of support.	Name, email address, phone number, and any information provided over email with our support team
      Error tracking and monitoring	We use service providers to track errors and monitor use of our services.	Name, email address, IP address
      Analytics Providers	We use a service provider to assist us with analytics services.	Registration data and Data collected automatically through our site, including IP addresses and cookie information.

   3. Change of Ownership. If we are looking to sell our company, liquidate assets, or merge with another, we may share your personal data with other interested parties as part of negotiations toward that transaction. In such case, or where we do sell our company, your personal data shall continue to be subject to the provisions of this Privacy Notice.
   4. Law Enforcement Related Disclosure. We may share your personal data with government agencies or other relevant parties, such as a law office or independent auditor: (i) if we believe that such disclosure is appropriate to protect our rights, property or safety (including the enforcement of the Terms and this Privacy Notice) or those of a third party; (ii) if required by law or court order; or (iii) as is necessary to comply with any legal and/or regulatory obligations, such as audit requirements. 
6. International Transfers. Some of our service providers are located in countries other than your own. When we transfer your personal data internationally, we will do so safely and securely and in accordance with applicable law.
   1. If you are located in the EU, when we share your personal data with third parties based outside of the European Economic Area (“EEA“), we will ensure that they sign on agreements that require them to comply with applicable law, keep your data secure at similar levels to the level described in this Privacy Notice, and make sure that your data protection rights are protected. We will also implement the following safeguards: 
      1. When we transfer your personal data to Israel, we rely on the decision by the European Commission that says that those countries are considered to provide an adequate level of data protection. 
      2. Where we transfer your personal data to other countries, we (i) take additional security measures to protect the data and (ii) use specific contracts approved by the European Commission, known as the Standard Contractual Clauses, to give your personal data the same protection it has in the EEA. 
      3. Please contact us at support@novu.co if you would like further information on the specific mechanism used by us when transferring your Personal Data out of the EEA. 
7. Security. The security of your personal data is our highest priority. We work hard to make sure that your personal data will be held securely and that it will not be shared or lost accidentally. However, it is impossible to guarantee absolute security. The security of your data also depends on the security of the devices you use and the way in which you protect your user IDs and passwords. For more details about the security measures we use, please see: https://trust.novu.co. 
8. Your Rights – How to Control Our Use of Your Personal Data.  Depending on which laws apply, you have certain legal rights over your data. Below is some general information about rights that may apply to you but we recommend checking the law or consulting with a lawyer to understand what applies in your specific case. To exercise your rights, please contact us at support@novu.co. If you want to exercise your rights regarding your personal data held by other controllers you can contact the applicable controller directly. We may ask for reasonable evidence to verify your identity before we can comply with any request. 
   1. Right of Access. You may have a right to know what personal data we collect about you. We may charge you with a fee to provide you with this information, if permitted by law. If we are unable to provide you with all the information you request, we will do our best to explain why. See Article 15 of the GDPR for more details, if your personal data is subject to GDPR.
   2. Right to Correct Personal Data. You may request that we update, complete, correct or delete inaccurate, incomplete, or outdated Personal Data. See Article 16 of the GDPR for more details, if your personal data is subject to GDPR.
   3. Deletion of Personal Data (“Right to Be Forgotten”). If you are located in the EU, you may have the right to request that we delete your personal data. Note that we cannot restore information once it has been deleted. Even after you ask us to delete your personal data, we may be allowed to keep certain data for specific purposes under applicable law. See Article 17 of the GDPR for more details, if your personal data is subject to GDPR.
   4. Right to Restrict Processing. If you are located in the EU, you may have the right to ask us to stop processing your personal data. See Article 18 of the GDPR for more details, if your personal data is subject to GDPR.
   5. Right to Data Portability. If you are located in the EU, you may have the right to request that we provide you with a copy of the personal data you provided to us in a structured, commonly used, and machine-readable format. See Article 20 of the GDPR for more details, if your personal data is subject to GDPR.
   6. Right to Object. If you are located in the EU, you may have the right object to certain processing activities. See Article 21 of the GDPR for more details, if your personal data is subject to GDPR.
   7. Withdrawal of Consent. If we are processing your data based on your consent, you are always free to withdraw your consent, however, this won’t affect processing we have done from before you withdrew your consent.
   8. Right to Lodge a Complaint with Your Local Data Protection Authority. If you are located in the EU, you have the right to submit a complaint to the relevant data protection authority if you have any concerns about how we are processing your personal data, though we ask that as a courtesy you please attempt to resolve any issues with us first.
9. Data Retention.
   1. We retain your personal data as long as necessary to fulfill each of the purposes we described above. Once we’re done with your data, we delete it.
   2. When deciding how long to store personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized access, the purposes for which the personal data was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business’s retention policy. 
   3. Please contact us at support@novu.co if you would like details about the retention periods for each type of personal data we process.
10. Cookies and Similar Technologies.
    1. What are Cookies. A cookie is a small piece of text that is sent to your browser by a website you visit. This piece of text acts as a sort of tag, letting the website know that it’s you (really, your device) that’s visiting. There are other technologies that act similarly, like web beacons, pixel tags, and Device IDs for apps, but for simplicity’s sake we’ll refer to them all as “cookies”.
    2. Websites can place their own cookies (called “first-party cookies”) but can also place cookies from other sites (called “third-party cookies”). If your browser holds both first and third-party cookies for a given website, both the website and the third party are notified when you visit the site. We may place both first and third-party cookies on our site. 
    3. How We Use Cookies. While the specific names and types of cookies we use may change from time to time, they generally fall into one of the categories listed below.

       Cookie Type	Function
       Necessary	These cookies allow the site to work correctly. They enable your access to the site, move around, and access different services, features, and tools. These cookies cannot be disabled.
       Functionality	These cookies remember your settings, preferences, and other choices you make (like placing an item in a shopping cart) in order to help personalize and streamline your experience.
       Security	These cookies help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.
       Performance/Analytics	These cookies collect analytical information to help us understand how you use our site, for example whether you have viewed messages, clicked on links, and how long you spent on each page. This helps us improve our site to better suit your needs.

    4. Third Party Cookies. In addition to our first-party cookies, we place cookies from the following third parties:
    5. How to Adjust Your Preferences. Most web browsers are initially configured to accept cookies, but you can change the settings, so your browser refuses all cookies or certain types of cookies. In addition, you are free to delete any existing cookies at any time. Please note that some features of the services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit.
11. Third-Party Services. You may have access to third-party services through our services. Please note that all use of third-party services is at your own risk and subject to such third party’s terms and privacy policies. We do not take any responsibility for the performance of other services.
12. Children. We do not knowingly collect personal data from children under the age of sixteen (16). In the event that you become aware that an individual under the age of sixteen (16) has registered without parental permission, please advise us immediately. 
13. Changes to the Privacy Notice. We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business. We will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version.