This Privacy Policy applies to personal data collected, processed and stored during your use of the novamarket.com website (hereinafter the “Site”).
In the context of the Privacy Policy, the term “personal data” refers to any information that, alone or in combination with other information, allows an identified natural person to be identified, such as name, email address, telephone number or IP address.

ADS LEADS LTD undertakes to process your personal data in accordance with applicable laws and regulations, and in particular with Law No. 78-17 of January 6, 1978 as amended by the Law of June 20, 2018 and with the European General Data Protection Regulation No. 2016/679 (hereinafter the “GDPR”).

ARTICLE 1 - DATA CONTROLLER
The controller of the personal data concerning you collected during your use of the Site is the company ADS LEADS LTD, Company number 15390247, whose registered office is Suite 5 39-41 Chase Side, Southgate, London, United Kingdom, N14 5BP (hereinafter "ADS LEADS LTD" or "we").
Personal data collected by ADS LEADS LTD

ADS LEADS LTD collects and processes the following personal data concerning you:

The data that you communicate to ADS LEADS LTD

This is the personal data that you communicate to ADS LEADS LTD when you create a customer account on the Site, when you place orders on the Site or when you contact us. This data includes in particular your name, first name, postal address, billing address, email address, customer account password and telephone number.


Unless otherwise stated, the information requested from you in the collection forms accessible on the Site (such as the customer account creation form) is mandatory. If you do not provide this information, you will not be able to validate the corresponding form. You are solely responsible for the accuracy of the data you communicate to ADS LEADS LTD.

If you make a purchase via the Site, we do not collect or store data relating to your payment card. This data is collected directly by our payment service provider and is therefore subject to the privacy policy of this service provider.

ARTICLE 2 - DATA RELATING TO YOUR NAVIGATION ON THE SITE

ADS LEADS LTD collects information each time you visit the Site, including the IP address used to connect your computer to the Internet, your connection information, browser type and version, and time zone setting.

In addition, ADS LEADS LTD and its partners collect information about how you use the Site, through cookies or any other similar technology, as indicated in Article 7 below.

ARTICLE 3 - USE OF YOUR PERSONAL DATA

ADS LEADS LTD collects and processes your personal data for the purposes described in the table below.

Nature of data processing

Management of your customer account (creation, modification and deletion of the account)

Management of our commercial relations (tracking and sending orders, management of product return/exchange requests)

Management of your contact requests

Sending invitations by email to finalize the order

Sending the newsletter

Sending the newsletter

Management of your requests to exercise your rights regarding personal data (as described in Article 8 below)

Management of pre-litigation and litigation Justification for data processing

The management of your customer account is necessary for the execution of your customer contract, in accordance with our general terms and conditions of sale

... ... Your subscription to the ADS LEADS LTD newsletter is based on your consent.

The management of your requests to exercise rights is based on the legal obligation of ADS LEADS LTD to respond to requests to exercise rights from persons whose personal data ADS LEADS LTD processes.

The management of your contact requests is based on the legitimate interest of ADS LEADS LTD to assert its rights in the context of pre-litigation or litigation.

ARTICLE 4 - RECIPIENTS AND TRANSFERS OF YOUR PERSONAL DATA

Within ADS LEADS LTD, and with regard to each processing purpose, the personal data concerning you are collected, processed and stored by the authorized personnel of ADS LEADS LTD, only within the framework of their respective skills, and in particular by our sales department, our marketing department and our IT department.

Your personal data may be communicated to third parties with regard to the processing purpose concerned, and in particular to our service providers in charge of shipping orders, to our service providers in charge of development, hosting and maintenance operations of the Site, data storage as well as to our potential investors or any other third party involved in the context of a merger, acquisition of all or part of the activity of ADS LEADS LTD, change of control or collective proceedings.

Your personal data is processed by our IT service provider Shopify Inc. [change if other service provider], in charge of hosting and displaying our Site, and which is located in Canada. In this regard, the appropriate level of data protection is guaranteed by an adequacy decision of the European Commission which can be consulted here.

ARTICLE 5 - Duration of storage of your personal data

ADS LEADS LTD only stores your personal data for the duration that is strictly necessary with regard to the purpose of the processing. More specifically, your personal data is stored in accordance with the durations indicated in the list below.

* Management of your customer account - 5 years after the closure of your customer account or from a period of inactivity of 3 years
* Management of our commercial relations - 10 years from the end of the commercial relationship
* Management of your contact requests - Duration necessary to process and respond to contact requests
* Sending invitations by email to finalize the order - 3 years from the last connection to the customer account
* Sending the newsletter - Duration of the subscription to the newsletter
* Management of your requests to exercise rights in terms of personal data - 5 years after the closure of the request
* Management of pre-litigation and litigation - Until definitive amicable resolution of a pre-litigation or until exhaustion of appeals.

ARTICLE 6 - SECURITY OF YOUR PERSONAL DATA

We are committed to protecting the personal data that we collect. To do this, ADS LEADS LTD ensures that it takes all necessary physical, technical and organizational measures to prevent any unauthorized or illicit processing, as well as any accidental loss, destruction or damage to your personal data.

ARTICLE 7 - POLICY ON THE USE OF COOKIES AND OTHER TRACKERS

Cookies are small text files that are placed on your device (phone, computer, tablet, etc.) by ADS LEADS LTD and our partners when you browse our Site. By extension, and within the meaning of this cookie policy, the term cookie more generally covers all tracking technologies used on our Website and which collect information relating to your browsing and your interactions on it.

Cookies can be:

* Session, when they are stored on your device exclusively for the duration of your browsing on the Site and deleted when you close your browser.
* Persistent, when they are stored on your device for a longer period, until they expire or until they are deleted by the user.

In some cases, the cookies used on our Site may collect personal data about you.

When personal data is collected by ADS LEADS LTD as data controller, it will be processed in accordance with the provisions of this cookie policy.

Since April 1, 2021, publishers of sites/applications must comply with the CNIL's recommendations on cookies, which requires an in-depth analysis of the cookies used and the resulting personal data processing.

When third-party cookies allow our partners to collect and process personal data about you, we invite you to consult their privacy policy in order to learn about the conditions under which your personal data will be processed.

CATEGORIES OF COOKIES THAT MAY BE PLACED ON YOUR DEVICE

Several categories of cookies may be placed on your terminal equipment: essential cookies strictly necessary for the operation of the site, audience measurement and analytical cookies intended to measure the performance of our Site as well as advertising cookies.

* Essential cookies

Essential cookies, such as functionality, session, authentication and security cookies are essential for the proper functioning and security of the Site and are strictly necessary for the provision of the services you wish to access through the site. They are enabled by default on the Site.

These cookies allow in particular:

* To ensure smooth navigation on our Site, to facilitate and accelerate the loading of the various web pages, and to guarantee the operation of all the Site's functionalities;
* To memorize the user interface display preferences (language used and presentation of the service) and to adapt the presentation of the Site for a personalized experience when it is an intrinsic element of the services offered on the Site;
* To memorize certain information as part of your purchasing process (for example, cookies that allow the contents of the shopping cart to be stored);
* To allow you to access reserved and personal areas of the site, such as your customer account, using the authentication mechanism;
* To implement security measures and detect any fraudulent connection to your customer account;
* To retain your choice regarding cookies and ensure the operation of our cookie management tool;
* To ensure the operation of certain features of the purchasing and ordering process (for example, the payment process).

Through the use of some of these cookies, ADS LEADS LTD is required to collect and process certain personal data in order to pursue the aforementioned purposes. This includes your IP address, your session identifiers, information relating to your browser and/or terminal, your browsing data and your preferences (including the expression of your choice regarding cookies).

The legal basis for processing this data is the legitimate interest of ADS LEADS LTD in ensuring that the Site functions properly, securely and according to the preferences indicated by each user. The data is shared within ADS LEADS LTD only with those persons who need to know it for the purposes of the aforementioned purposes, such as, for example, the teams involved in managing the Site and those providing technical support. ADS LEADS LTD may also share this data with external service providers for the same purposes. In the event of data transfer outside the European Economic Area, ADS LEADS LTD will implement appropriate safeguards to supervise the transfer in accordance with the GDPR. Your personal data is kept only for the period necessary to achieve the aforementioned purposes, and in any event for a maximum period of 6 months. Data relating to your consent may be retained for a longer period in order to anticipate any action or investigation aimed at verifying or contesting ADS LEADS LTD's compliance with its obligation to collect user consent.


* Audience measurement and analytical cookies

Our partners place audience measurement and analytical cookies on the Site to enable us to measure the Site's audience, optimise its performance and improve our services. If you do not accept these cookies, we will not be able to take your browsing into account in our performance and audience measurement statistics.

These cookies allow in particular:

To establish attendance statistics (for example, the number of visits, the most visited pages, etc.) to understand how visitors interact with our Site and improve the quality of our services and the user-friendliness of the Site;
To analyse your behaviour on our Site (for example, mouse movement, scroll height).

When using these cookies, ADS LEADS LTD will only access aggregated statistical data.

* Advertising cookies

Our partners use cookies to provide you with personalized advertising content that is relevant to you, on our Site as well as on third-party sites. If you do not accept these cookies, you will not be able to access this personalized advertising content.

If you do not accept these cookies, you will not be able to access this personalized advertising content.

These cookies allow in particular:

* To adapt the advertising content inserted on our Site to your interests, your location and your behavior on our Site;
* To limit the number of times the same advertisement is presented to you;
* To produce statistics concerning advertising on our advertising spaces and your interaction with these spaces to measure the effectiveness of an advertisement;
* To offer you advertising content relating to our Site and our services when you access third-party sites and social networks, following your visit to our Site.



COOKIE MANAGEMENT

Here is a list of cookies that we use. We have listed them here so that you can choose whether or not you want to allow them.

_session_id, unique session identifier, allows Shopify to store information relating to your session (referrer, landing page, etc.).

_shopify_visit, no data held, Persistent for 30 minutes from the last visit. Used by our website provider's internal stats tracker to record the number of visits.

_shopify_uniq, no data held, expires midnight (relative to the visitor) of the next day. Counts the number of visits to a store by a unique customer.

cart, unique token, Persistent for 2 weeks, Stores information about your shopping cart.

_secure_session_id, unique token, sessional

storefront_digest, unique token, indefinite If the store has a password, this is used to determine if the current visitor has access.


ARTICLE 8 - YOUR RIGHTS OVER YOUR PERSONAL DATA

You have the right to access, rectify, erase, limit and object to the processing of your personal data, as well as the right to define guidelines regarding the fate of your data after your death and the right to the portability of your personal data.

These rights are exercised under the conditions set out in the applicable regulations:

The right of access means that you can ask us at any time to indicate whether we are processing personal data concerning you and, if so, to indicate which personal data are concerned and the characteristics of the processing carried out.

The right of rectification means that you can ask us to rectify your personal data when it is inaccurate. You can also ask that your personal data, if incomplete, be completed to the extent that this is relevant to the purpose of the processing in question.

The right to erasure means that you can request that your personal data be erased, in particular when: (i) their retention is no longer necessary in relation to the purposes for which they were collected; (ii) your personal data are processed on the basis of your consent, you wish to withdraw this consent, and there is no other legal basis that could justify the processing; (iii) you have objected to the processing of your personal data and therefore wish them to be erased; (iv) your personal data have been subject to unlawful processing; (v) your personal data must be erased to comply with a legal obligation provided for either by European Union law or by French law.

The right to limitation means that you can ask us to limit the processing of your personal data (i) when you contest the accuracy of your personal data for a period allowing us to verify its accuracy; (ii) when, following processing established as non-compliant, you prefer the limitation of processing to the complete erasure of your personal data; (iii) when we no longer need your personal data for the purposes of the processing but you still need them for the establishment, exercise or defense of legal claims; (iv) when you have objected to the processing of your personal data and you wish to restrict the processing for the period enabling us to verify whether the legitimate ground you invoke is justified. Restriction of processing means that the processing of your personal data will then be understood to mean only the storage of your corresponding personal data. We will then no longer carry out any other operations on the personal data in question.