Privacy Policy

Effective Date: July 19, 2023

Thank you for visiting https://www.thenovodowntown.com/ (the “Website”). Your privacy is important to us. This Privacy Policy (the “Policy”) describes the types of information Novo Downtown LLC (the “Company”, “us”, “we”, or “our”) may collect from you or that you may provide when you visit the Website and the products, features, materials, and services we offer (collectively with the Website, the “Services”). This Policy also describes our policies and procedures for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on the Website and through your use of the Services generally (including when you register for an account), and through communications between you and the Website (including email, text, and other electronic messages).

This Policy does not apply to information collected by third parties, including any websites, services, and applications that you elect to access through the Services.

Please review this Policy carefully. By accessing or using the Services (or by clicking on “accept” or “agree” to this Policy when prompted), you agree to the terms of this Policy on behalf of yourself or the entity or organization that you represent. If you do not agree to any term in this Policy, you should refrain from further use of our Services.

Changes to Our Privacy Policy

This Policy was last revised on the date noted at the top of this page. We may update this Policy from time to time. If we make material changes, we will post the updated Policy on this page and notify you of such changes by means of an email to the email address specified in your account, a message on the Services, or through a notice on the Website home page. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Information We Collect

We receive several types of information about you from various sources, including:

(A) Information and content that you give us
(B) Automatically-collected information
(C) Demographic information or other aggregate information

Information and Content That You Give Us

We collect personal information that you knowingly choose to disclose. This may include:

Personal Information (or Data)

Personal information, such as your name, address, email address, phone number, username, password, and any other information you directly provide us on or through the Services. This includes information you provide when you register or create an account, complete a questionnaire or contest entry form, or make a request for customer service.

Correspondences

Records and copies of your email messages together with your email address and our responses, if you correspond with us via email, and records of your phone number, phone calls, and voice messages if you communicate via phone.

User Content

Information or content you submit to be published or displayed on public areas of the Services or transmitted to other users or third parties (“User Content”). Your User Content is posted at your own risk. We cannot guarantee that it will not be viewed by unauthorized persons.

Transaction Information

Information about any purchases or transactions made on the Services, including payment information (credit or debit card number), authentication information, billing details, shipping details, and contact details.

Search Queries

Your search queries conducted on the Website.

Information We Collect Automatically

We may use various technologies to collect information about your equipment, browsing actions, and usage patterns.

Activity Information

Details of your visits, including content viewed, features used, actions taken, time spent, frequency of activity, and interactions with other accounts.

Equipment Information

Information about your computer and internet connection, including operating system, IP address, browser type, and browser language.

Location Information

Information about your device location, including GPS data, to enhance Services and deliver relevant advertising.

The gathering of this information helps maintain service quality and compile general usage statistics.

Technologies Used for Automatic Data Collection

Cookies

A cookie is a small data file stored on your device either temporarily (“session cookies”) or for a fixed period (“persistent cookies”). We use cookies to improve user experience.

Web Beacons

Small embedded files (pixel tags) that allow us to track webpage visits and email engagement.

JavaScripts

Code snippets embedded in websites to monitor usage and enhance functionality.

Entity Tags

HTTP mechanisms allowing portions of websites to be cached for performance improvements.

HTML5 Local Storage

Allows websites to store data locally within your browser for faster retrieval.

Resettable Device Identifiers

Advertising identifiers found on mobile devices (e.g., IDFA on iOS or Google Advertising ID on Android) used to deliver relevant advertising.

This Policy does not cover third-party tracking technologies. We do not control third-party cookies or tracking tools. We encourage you to review the privacy policies of those third parties.

Demographic Information

We may collect statistical or aggregate information that does not individually identify you, such as age, gender, household income, or political affiliation.

Information from Other Sources

We may receive information about you from third-party sources such as data providers, public databases, social networks, and service providers. This helps us improve security, correct inaccurate information, and provide more relevant offers.

How We Use Your Information

We may use the information we collect about you to:

Provide the Services and related content
Respond to comments and customer service requests
Fulfill the purpose for which you provided the information
Communicate about purchases or subscriptions
Notify you about important updates
Improve and personalize the Services
Monitor usage and trends
Prevent fraud and security breaches
Enforce contractual rights
Maintain administrative records
Enable interactive features
Send promotional communications
Develop new features and conduct research
Use for any other disclosed purpose or with your consent

We may display advertisements to target audiences. If you interact with an ad, the advertiser may assume you meet its targeting criteria.

How We Share Your Information

We may disclose aggregated or anonymized information without restriction. We will not share personal information except in the following circumstances:

Subsidiaries and Affiliates: For management and business purposes.
Service Providers: Payment processing, hosting, IT services, analytics, and other support services under confidentiality agreements.
Business Transfers: In case of merger, restructuring, or sale.
Legal Compliance: To comply with court orders or laws.
Enforcement: To enforce our Terms of Use at https://www.thenovodowntown.com/terms
Protection of Interests: Fraud prevention and security protection.
With Consent: For any purpose disclosed at the time of collection.
Marketing Providers: For promotional campaigns.
Business Partners: Strategic marketing alliances.
Third-Party Platforms: If you connect via social media or other linked accounts.

Information posted publicly may be visible to others. Please exercise caution when sharing personal information publicly.

Detailed Information on the Personal Information We Collect

Access to Third-Party Accounts

This type of service allows the Website to access Data from your account on a third-party service and perform actions with it. These services require explicit authorization.

Facebook Account Access (Facebook, Inc.)

This service allows the Website to connect with the User’s Facebook account.

Permissions asked: Business Management API; Chat; Mobile Messaging on behalf of Page; Page Messaging.

Place of processing: United States – Privacy Policy

Category of personal information collected according to CCPA: Internet information.

Advertising

This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Website, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Trackers to identify Users or they may use behavioral retargeting techniques, i.e., displaying ads tailored to the User’s interests and behavior, including those detected outside Website. For more information, please check the privacy policies of the relevant services.

In addition to any opt-out feature offered by any of the services below, Users may opt out by visiting:
https://www.youronlinechoices.com/

Google Ad Manager (Google LLC)

Google Ad Manager is an advertising service provided by Google LLC that allows the Company to run advertising campaigns in conjunction with external advertising networks that the Company, unless otherwise specified in this document, has no direct relationship with.

In order to opt out from being tracked by various advertising networks, Users may make use of YourOnlineChoices.

To understand Google’s use of data, consult Google’s partner policy.

This service uses the “DoubleClick” Cookie, which tracks use of Website and User behavior concerning ads, products, and services offered.

Users may disable DoubleClick Cookies by visiting:
Google Ad Settings

Personal Data processed: Tracker and Usage Data.

Place of processing: United States –
Privacy Policy

Category of personal information collected according to CCPA: Internet information.

This processing constitutes a sale based on the definition under the CCPA. Users can find additional information regarding opt-out rights in the section detailing the rights of Californian consumers.

Facebook Lookalike Audience (Facebook, Inc.)

Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience to display ads to Users with similar behavior to Users already in a Custom Audience list based on their past use of Website or engagement across Facebook apps and services.

Based on these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.

Users can opt out of Facebook’s use of cookies for ads personalization by visiting:
Facebook Ad Settings

Place of processing: United States –
Privacy Policy –
Opt Out

Category of personal information collected according to CCPA: Internet information.

This processing constitutes a sale based on the definition under the CCPA. Users can find additional information regarding opt-out rights in the section detailing the rights of Californian consumers.

Analytics

The services contained in this section enable the Company to monitor and analyze web traffic and can be used to track User behavior.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Website, prepare reports on Website activities, and share them with other Google services. Google may use the Data collected to contextualize and personalize ads of its own advertising network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States –
Privacy Policy –
Opt Out

Category of personal information collected according to CCPA: Internet information.

This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.

Google Ads Conversion Tracking (Google LLC)

Google Ads conversion tracking is an analytics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on Website.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States –
Privacy Policy

Category of personal information collected according to CCPA: Internet information.

Facebook Ads Conversion Tracking (Facebook Pixel) (Facebook, Inc.)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram, and Audience Network.

Personal Data processed: Tracker; Usage Data.

Place of processing: United States –
Privacy Policy

Category of personal information collected according to CCPA: Internet information.

Contacting the User

Mailing List or Newsletter (Website)

By registering on the mailing list or subscribing to the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of a commercial or promotional nature concerning the Website. Your email address may also be added to this list as a result of signing up to the Website or after making a purchase.

Personal Data processed: Email address.

Category of personal information collected according to CCPA: Identifiers.

Handling Payments

Unless otherwise specified, Website processes payments by credit card, bank transfer, or other means via external payment service providers. In general, and unless otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers.

Website is not involved in the collection or processing of payment information. Instead, it will only receive a notification from the relevant payment service provider as to whether payment has been successfully completed.

Stripe (Stripe Inc.)

Stripe is a payment service provided by Stripe Inc.

Personal Data processed: Various types of Data as specified in Stripe’s privacy policy.

Place of processing: United States –
Privacy Policy

Category of personal information collected according to CCPA: Internet information.

Managing Contacts and Sending Messages

This type of service makes it possible to manage a database of email contacts, phone contacts, or other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Mailgun (Mailgun Technologies, Inc.)

Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.

Personal Data processed: Email address.

Place of processing: United States –
Privacy Policy

Category of personal information collected according to CCPA: Identifiers.

Twilio (Twilio Inc.)

Twilio is a phone numbers management and communication service provided by Twilio, Inc.

Personal Data processed: Phone number.

Place of processing: United States –
Privacy Policy

Category of personal information collected according to CCPA: Identifiers.

Remarketing and Behavioral Targeting

This type of service allows Website and its partners to inform, optimize, and serve advertising based on past use of Website by the User.

This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.

Some services offer a remarketing option based on email address lists.

In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting:
Network Advertising Initiative Opt-Out Page

Users may also opt out of certain advertising features through applicable device settings, such as mobile device advertising settings or general ad settings.

Google Ads Remarketing (Google LLC)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of Website with the Google Ads advertising network and the DoubleClick Cookie.

Users can opt out of Google’s use of cookies for ads personalization by visiting:
Google Ads Settings

Personal Data processed: Tracker and Usage Data.

Place of processing: United States –
Privacy Policy –
Opt Out

Category of personal information collected according to CCPA: Internet information.

This processing constitutes a sale based on the definition under the CCPA. Users can find additional opt-out information in the section detailing the rights of Californian consumers.

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Website with the Facebook advertising network.

Users can opt out of Facebook’s use of cookies for ads personalization by visiting:
Facebook Ad Settings (Opt-Out Page)

Personal Data processed: Email address and Tracker.

Place of processing: United States –
Privacy Policy –
Opt Out

Category of personal information collected according to CCPA: Identifiers; Internet information.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Website with the Facebook advertising network.

Personal Data processed: Tracker and Usage Data.

Place of processing: United States –
Privacy Policy –
Opt Out

Category of personal information collected according to CCPA: Internet information.

Tag Management

This type of service helps the Company manage tags or scripts needed on Website in a centralized fashion. This may result in Users’ Data flowing through these services and potentially being retained.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data processed: Usage Data.

Place of processing: United States –
Privacy Policy

Category of personal information collected according to CCPA: Internet information.

Your Choices

Mechanisms to Control Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

Cookies and Other Tracking Technologies. You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the Help menu in your browser to learn how to modify your browser settings. Please note that you cannot remove Flash cookies simply by changing your browser settings. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies or other tracking technologies, please note that some parts of the Services may become inaccessible or may not function properly.

Promotional Communications from the Company. If you do not wish to have your contact information used by the Company to promote our own or third-party products or services, you can opt out by (i) informing us of your preference at the time you register for an account, complete an order form, sign up for our newsletter, or complete any other form on or through the Services which we collect your data]; (ii) modifying your user preferences in your account profile; (iii) following the opt-out instructions in the promotional emails we send you; or (iv) sending us an email stating your request. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your account or purchases.

The personal information collected is only used by Novo Downtown LLC staff for the purposes defined at the time of the collection or a use that complies with these purposes. We do not share your information with any third parties.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by modifying your user preferences in your account profile. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. Many advertising companies that collect information for interest-based advertising are members of the Digital Advertising Alliance or the Network Advertising Initiative, both of which maintain websites where people can opt out of interest-based advertising from their members. To opt out on these pages, visit www.AboutAds.info and www.networkadvertising.org

Location Information

You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third parties by:

(a) Disabling location services within the device settings; or
(b) Denying certain websites or applications permission to access location information by changing the relevant preferences and permissions in your device or browser settings.

Please note that your location may be derived from your GPS, WiFi, Bluetooth, and other device settings.

If you have questions about how to disable your device’s location services, we recommend contacting your mobile service carrier or your device manufacturer.

Voice Transmissions

You may be able to adjust the settings of your device so that your voice transmissions are not sent to us or third parties by:

(a) Disabling microphone and speech recognition services within the device settings; or
(b) Denying certain websites or mobile applications permission to access microphone and speech recognition services by changing the relevant preferences or permissions in your device or browser settings.

How We Respond to Do Not Track Signals

“Do Not Track” is a privacy preference you can set in most web browsers. When enabled, it sends a signal to websites indicating that you do not wish to be tracked.

Please note that we currently do not respond to Do Not Track browser settings.

Accessing and Correcting Your Information

You may send us an email to request access to, correct, or remove any personal information that you have provided to us.

You may also access, correct, or remove your personal information by logging into the Website and visiting your account profile page. We cannot delete your personal information except by also deleting your account.

We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Content from the Services or your account, copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other users of the Services.

California Privacy Rights

This part of the document integrates with and supplements the information contained in the rest of this Privacy Policy and is provided by the business running the Website and, if applicable, its parent, subsidiaries, and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users (referred to as “you”, “your”, “yours”) who are consumers residing in the State of California, United States of America, pursuant to the California Consumer Privacy Act of 2018 (CCPA), as updated by the California Privacy Rights Act (CPRA) and subsequent regulations.

For California consumers, these provisions supersede any conflicting provisions contained elsewhere in this Privacy Policy.

This section uses the term “personal information” as defined under the CCPA/CPRA.

Categories of Personal Information Collected, Used, Sold, or Shared

In this section, we summarize the categories of personal information that we have collected, used, sold, or shared and the purposes thereof. More detailed information can be found in the section titled “Detailed Information on the Processing of Personal Data” within this document.

Information We Collect

We have collected the following categories of personal information:

Identifiers
Commercial information
Internet information

We do not collect sensitive personal information. We will not collect additional categories of personal information without notifying you.

Purposes for Using Personal Information

Unless otherwise stated in the section titled “Detailed Information on the Processing of Personal Data”, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) for which it was collected.

Sources of Personal Information

We collect personal information directly and indirectly from you when you use the Website.

Directly from you when you submit information through forms or create an account.
Indirectly when you navigate the Website and information is automatically collected.
From third parties working with us in connection with the Services or the functioning of this Application and its features.

Disclosure of Personal Information for Business Purposes

For purposes of this section, a “third party” means a person who is not a service provider or contractor as defined under the CPRA.

We disclose personal information to the third parties listed in the section titled “Detailed Information on the Processing of Personal Data”. These third parties are grouped and categorized based on the purposes of processing.

Sales of your personal information. For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CPRA (CCPA amendment). This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like. For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CPRA (CCPA amendment). Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CPRA (CCPA amendment), does not constitute a sale or sharing of your personal information.

Your right to opt out of the sale or sharing of your personal information and how you can exercise it. We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing. You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request. Such requests can be made freely, at any time, without submitting any verifiable request. To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document. For a simplified opt-out method you can also use the privacy choices link provided on Website. If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here. We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request. Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.

Your Privacy Rights Under the California Consumer Privacy Act and How to Exercise Them

The Right to Access Personal Information (Right to Know and Data Portability)

You have the right to request that we disclose to you:

The categories of personal information that we collect about you;
The sources from which the personal information is collected;
The purposes for which we use your information;
The categories of third parties to whom we disclose such information;
The specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

The categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past twelve (12) months.

If we deliver our response electronically, the information enclosed will be “portable,” meaning it will be delivered in an easily usable format that enables you to transmit the information to another entity without hindrance, provided that this is technically feasible.

The Right to Request Deletion of Your Personal Information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by law (including, but not limited to, where the information is used to identify and repair errors on the Website, detect security incidents, protect against fraudulent or illegal activities, or exercise certain legal rights).

If no legal exception applies, we will delete your personal information and notify our service providers and any third parties to whom we have sold or shared the personal information to delete it as well, provided that this is technically feasible and does not involve disproportionate effort.

The Right to Correct Inaccurate Personal Information

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of processing that personal information.

The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination) We will not discriminate against you for exercising your rights under the CPRA (CCPA amendment). This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a minor under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Virginia Privacy Rights

This part of the document integrates with and supplements the information contained in the rest of the Privacy Policy and is provided by the controller running this Application and, if applicable, its parent, subsidiaries, and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The provisions contained in this section apply to all Users who are consumers residing in the Commonwealth of Virginia (referred to below as “you”, “your”, “yours”), according to the Virginia Consumer Data Protection Act (the “VCDPA”). For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in this Privacy Policy.

This section uses the term “personal data” as defined in the VCDPA.

Categories of Personal Data Collected, Used, Sold, or Shared

In this section, we summarize the categories of personal data that we have collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed Information on the Processing of Personal Data” within this document.

How and When We Handle Your Personal Data

We summarize the categories of personal data that we have processed and the purposes thereof in this section. You can read more details in the section titled “Detailed Information on the Processing of Personal Data” within this document.

Categories of Personal Data We Collect

We have collected the following categories of personal data:

Identifiers
Commercial information
Internet information

We do not collect sensitive data. We will not collect additional categories of personal data without notifying you.

Why We Process Your Personal Data

To understand why we process your personal data, please refer to the sections titled “Detailed Information on the Processing of Personal Data” and “The Purposes of Processing” within this document.

We will not process your information for unexpected purposes or for purposes incompatible with those originally disclosed without your consent. You may freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

Processing of Personal Data for Targeted Advertising

For our purposes, “targeted advertising” means displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests, as defined by the VCDPA.

To learn more about how we process personal data for targeted advertising, please refer to the section titled “Detailed Information on the Processing of Personal Data” within this document.

Your Right to Opt-Out of Targeted Advertising

You have the right to opt out of the processing of your personal data for targeted advertising. When you request that we stop processing your data for targeted advertising, we will comply with your request.

To fully exercise your right to opt out, you may contact us at any time using the contact details provided in this document.

We will use any personal data collected in connection with your opt-out request solely for the purpose of complying with that request.

Your Privacy Rights Under the VCDPA

You may exercise certain rights regarding your personal data processed by us. These rights include:

Right to Access

You have the right to request confirmation as to whether we are processing your personal data and to access such personal data.

Right to Correct

You have the right to request correction of any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of processing.

Right to Delete

You have the right to request deletion of your personal data.

Right to Data Portability

We will provide your personal data in a portable and usable format that allows you to transfer it easily to another entity, provided this is technically feasible.

Right to Non-Discrimination

We will not discriminate against you for exercising your rights under the VCDPA. This means we will not deny goods or services, charge a different price, or provide a different level or quality of goods or services because you exercised your consumer privacy rights.

However, if you refuse to provide your personal data or request deletion or cessation of its sale, and such data is necessary to provide goods or services, we may not be able to complete the transaction.

To the extent permitted by law, we may offer a different price, rate, level, quality, or selection of goods or services, including offering goods or services at no fee, if such offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to Exercise Your Rights

To exercise the rights described above, you need to submit your request to us by contacting us using the contact details provided in this document.

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relates to you. In such cases, we may request that you provide additional information reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected in connection with your request solely for authentication purposes and will not further disclose it, retain it longer than necessary for authentication, or use it for unrelated purposes.

If you are an adult, you may make a request on behalf of a minor under your parental authority.

How and When We Handle Your Request

We will respond to your request without undue delay and, in all cases, within 45 days of receipt. If we require additional time, we will inform you of the reasons and the extension period. Please note that we may take up to 90 days in total to fulfill your request where permitted by law.

If we deny your request, we will provide an explanation without undue delay and no later than 45 days from receipt of the request.

You have the right to appeal our decision by submitting a request to us using the contact details provided in this document. Within 60 days of receiving your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision.

If your appeal is denied, you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request for up to two requests per year. If your request is manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will inform you of our decision and explain the reasons behind it.

How to Exercise Your Rights

To exercise the rights described above, you need to submit your request to us by contacting us using the contact details provided in this document.

For us to respond to your request, we need to know who you are.

If you are an adult, you may make a request on behalf of a minor under your parental authority.

How and When We Handle Your Request

If we deny your request, we will provide an explanation without undue delay and no later than 45 days from receipt of the request.

If your appeal is denied, you may contact the Attorney General to submit a complaint.

How We Protect Your Information.

We take reasonable precautions to secure your personal information. We have implemented technical, physical, and administrative security measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your information. We have put in place appropriate physical, electronic, and managerial procedures to safeguard the information we collect. All information you provide to us is stored on secure servers behind firewalls. When you transmit highly sensitive information (such as a credit card number) through the Services, we encrypt the transmission of that information using Secure Sockets Layer (SSL) technology.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

While we have employed security technologies and procedures to assist in safeguarding your personal information, no system or network can be guaranteed to be 100% secure. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or any other Services.

Terms of Use

If you choose to visit the Services, your visit and any dispute over privacy are subject to this Privacy Policy and our Terms of Use, including limitations on damages, resolution of disputes, and application of the laws of the State of Texas.

Cookie Policy

The Website uses Trackers (cookies and similar technologies). To learn more, you may consult our Cookie Policy.

SMS Communication & Mobile Messaging Policy

Novo Downtown LLC may send SMS messages to users who voluntarily provide their mobile phone number through our website forms.

These messages may include:

Event inquiry responses
Booking confirmations
Appointment reminders
Event updates
Promotional offers

Message frequency may vary. Message and data rates may apply.

You may opt out of receiving SMS messages at any time by replying STOP to any message received.

For assistance, reply HELP or contact us directly at info@thenovodowntown.com.

Your mobile information will not be shared, sold, or transferred to third parties for marketing purposes.

Consent to receive SMS messages is not a condition of purchase.

Information We Collect

We may collect the following information when you use our website:

– Full name
– Email address
– Mobile phone number
– Event details submitted through forms
– IP address
– Browser type and usage data
– Cookies and tracking information

How We Use Your Information

We use the information we collect to:

– Respond to inquiries
– Process event bookings
– Send confirmations and reminders
– Send promotional communications (if consented)
– Improve our website and services
– Comply with legal obligations

Mobile Information Sharing Statement

We do not sell, rent, or share your mobile phone number with third parties for their marketing purposes.

Mobile information is used solely for communication related to your inquiry or services requested.

Cookies & Tracking Technologies

We use cookies and similar tracking technologies to enhance user experience, analyze website traffic, and improve functionality.

You may disable cookies in your browser settings.

Data Security and Handling

We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, disclosure, or misuse.

Your Rights

You have the right to:

– Request access to your personal information
– Request correction of inaccurate data
– Request deletion of your data
– Withdraw consent at any time

To exercise these rights, contact us at info@thenovodowntown.com .

Contact Us.

We welcome your questions, comments, and concerns about privacy. You can contact us at:

Novo Downtown LLC

219 W Buck St

Caldwell Texas 77836

info@thenovodowntown.com