About our Privacy Policies

Controller: NGlobal Holding AB (together with its subsidiaries, “Nova”)

Contact for all data protection matters: privacy@novatalent.com

Nova operates several digital services under the same corporate group. These services process personal data for different purposes and on different legal bases.

For this reason, Nova provides separate privacy policies depending on the service you use or the way in which we obtained your personal data.

This page explains which privacy policy applies to you and where to find it.

1. Nova Network Privacy Policy

Nova Network Privacy Policy

When this applies

This policy applies when you interact with Nova as a member, applicant or participant in our community services, including (without limitation):

• applications to become a Nova member;
• use of Nova Connect or other member platforms;
• Gravity, Nova 111 and similar community initiatives;
• Nova events, programs and partner opportunities;
• newsletters and other editorial / talent communications.

What it covers

This policy describes, among other aspects:

• The categories of personal data Nova collects directly from you (identification, contact, education, professional background, preferences)
• How and when your profile may be visible to other Nova members (never to the general public)
• In which cases Nova shares your data with universities, companies or partners because you have applied or asked to be put forward
• How you may choose to make limited professional information visible to vetted recruiters using Nova Recruiter
• Your data protection rights under the GDPR and the contact point to exercise them

2. Nova Recruiter Privacy Policy

Nova Recruiter Privacy Policy

When this applies

This policy applies when:

• you are a recruiter, hiring manager or corporate client using the Nova Recruiter platform; or
• your professional profile appears in the Nova Recruiter database because Nova obtained it from publicly available sources or from licensed professional data providers (for example, ContactOut).

What it covers

This policy explains:

• Which professional data is processed for recruitment purposes (name, role, employer, LinkedIn URL, business email, education, career history)
• That Nova may act as data controller (for its own candidate database and for client account data) and, in some cases, as data processor (when a client uploads or syncs its own candidates)
• That part of the data may have been obtained indirectly (Article 14 GDPR) from public sources or licensed datasets and is made available only to authenticated Nova Recruiter clients for legitimate hiring purposes
• How international data transfers are safeguarded (EU–U.S. Data Privacy Framework, Standard Contractual Clauses, and additional technical/organisational measures)
• How to object, request access or request erasure if your professional data appears in Nova Recruiter.

3. Transparency Notice for Public / Licensed Data (Article 14 GDPR)‍

Transparency Notice – Nova Recruiter (Article 14 GDPR)

Why do we have such notice

Because part of the professional data used in Nova Recruiter is not collected directly from the data subject but obtained from public, professionally oriented sources (e.g. company websites, professional networks) and/or licensed third parties such as ContactOut Limited, Nova publishes a dedicated Transparency Notice pursuant to Article 14 GDPR.

This notice specifies:

• the source of the data
• the categories of data concerned
• the purpose (enabling legitimate recruitment activity by Nova clients)
• the legal basis (legitimate interest, Art. 6(1)(f) GDPR)
• the right to object and to request deletion/suppression from Nova Recruiter
• the contact point for all such requests

4. Single Contact Point for Data Subjects

Irrespective of which policy applies to you, Nova provides one contact point for the exercise of rights, questions about international transfers, or requests for copies of Standard Contractual Clauses:

Email: privacy@novatalent.com

Postal: Data Protection Contact, NGlobal Holding AB, C/O Talent Venture Group AB, Postbox 3053, Stockholm, Sweden

Nova has designated a Data Protection Contact (not a formal DPO under Article 37 GDPR) to oversee compliance across all Nova services.

5. Why there are 2 policies

• Different purposes: community/networking vs. sourcing/recruitment.
• Different sources: data given directly by the user vs. data obtained from third parties and public sources.
• Different roles: in the community Nova mostly processes data directly provided by the member; in Nova Recruiter Nova may act as a subsequent controller for licensed professional data.
• Different transparency requirements: Nova Recruiter must additionally comply with Article 14 GDPR for indirectly collected data.

Separating the policies makes the information more transparent and easier to audit for supervisory authorities and the general public.

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6. Legitimate Interest Assessment (LIA)

For certain recruitment-related processing operations, Nova relies on legitimate interest as the legal basis under Article 6(1)(f) GDPR. In line with regulatory guidance, Nova has carried out a written Legitimate Interest Assessment (LIA) to document the purpose, necessity and balancing test for this processing. A concise public summary of that assessment is available here:

Legitimate Interest Assessment - LIA (GDPR Article 6)