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Website Leads Privacy Policy

1. About this Policy

This Privacy Policy explains how, when and why Nova processes the personal data that you provide voluntarily through Nova’s public websites (including, without limitation, novatalent.com and any landing page, demo form, contact form, newsletter sign-up, content download or event sign-up operated by Nova) for the purpose of being contacted by Nova about its products and services.

For the purpose of this Policy, any reference to “Nova” shall mean any applicable company within NGlobal Holding AB, company registration no. 559240-0864, with registered address at C/O Talent Venture Group AB, Postbox 3053, 10361 Stockholm, Sweden, including its subsidiaries:

  • Nova Talent AB (Sweden), reg. no. 559152-1603;
  • Nova Global Italy SRL (Italy), reg. no. MI - 2609948; and
  • Nova Global Spain S.L. (Spain), CIF B-87600391, with registered address at Avenida Pablo Iglesias 15, Esc D 3A, 28003 Madrid, Spain.

This Policy applies in addition to, and does not replace, the following Nova policies:

  • Nova Network Privacy Policy — applies if you also become a Nova member;
  • Nova Recruiter Privacy Policy — applies if you also start using the Nova Recruiter platform;
  • Cookie Policy — applies to information collected via cookies and similar technologies.

2. Who is the Data Controller

The Data Controller of the personal data collected through Nova’s websites is NGlobal Holding AB, acting jointly with the Nova subsidiary that corresponds to your country of contact (Spain, Italy, Sweden or, by default, NGlobal Holding AB).

Contact: privacy@novatalent.com

DPO / Data Protection Contact: dpo@novatalent.com

Postal: Attn: Data Protection, NGlobal Holding AB, C/O Talent Venture Group AB, Postbox 3053, 10361 Stockholm, Sweden.

3. What personal data we collect

When you submit your information through one of Nova’s web forms, Nova may collect:

  • Identification and contact data: full name, business email address, phone number (where you provide it), country, language.
  • Professional context: company name, job title, role, company size, industry, country of operation.
  • Inquiry data: the message, request or use-case you describe in the form; the product or content you are interested in.
  • Marketing preferences: whether you have opted in to receive newsletters, product updates or other commercial communications.
  • Technical and source data: IP address, browser, device, the page from which you submitted the form, marketing campaign or UTM parameters, and similar metadata.

Nova does not request, and asks you not to provide, any special-category data (e.g. health, political views, religion) through these forms.

4. Purposes and lawful bases

Nova processes the data described above for the following purposes:

Purpose: Responding to your inquiry, scheduling a demo or replying to the specific request you submitted through the form.
Lawful basis (GDPR): Performance of pre-contractual steps taken at your request (Art. 6(1)(b) GDPR)

Purpose: Storing your contact data in Nova’s commercial CRM (HubSpot) and contacting you (by email, phone, LinkedIn or other professional channel) for commercial purposes — including product updates, demos, follow-ups, events and offers.
Lawful basis (GDPR): Your explicit consent (Art. 6(1)(a) GDPR), given by actively ticking the unchecked consent box on the form at the moment of submission. You can withdraw your consent at any time, without affecting the lawfulness of prior processing.

Purpose: Measuring the effectiveness of our marketing campaigns and improving our website and offering (in aggregated form).
Lawful basis (GDPR): Legitimate interest (Art. 6(1)(f) GDPR).

Purpose: Complying with legal obligations and managing legal claims.
Lawful basis (GDPR): Legal obligation (Art. 6(1)(c) GDPR) and legitimate interest (Art. 6(1)(f) GDPR).

You are not obliged to provide your data or to give consent, but if you do not, Nova will not be able to contact you or respond to your request.

Nova does not rely on “soft opt-in” or on a generic B2B legitimate-interest basis to send you commercial communications: the lawful basis for commercial outreach is exclusively your explicit, opt-in consent.

5. Who has access to your data

Nova does not sell your personal data. We share it only with the following categories of recipients:

a. Nova personnel. Members of Nova’s sales, marketing, partnerships and customer-success teams who need to evaluate, qualify and follow up on your request, all bound by confidentiality obligations.

b. Service providers acting as data processors on Nova’s behalf, including:

  • HubSpot, Inc. (CRM, marketing automation and email outreach) — United States, EU–U.S. Data Privacy Framework + SCCs.
  • Google (Workspace) — email, calendars, productivity tools.
  • AI / LLM providers (e.g. OpenAI, Anthropic) under zero-retention, no-training contractual terms, where AI is used to assist with drafting or summarising commercial communications.
  • Communications platforms (e.g. LinkedIn outreach tooling, calendar booking tools, telephony providers).
  • Cloud infrastructure providers (e.g. Amazon Web Services in the EU).

Each provider is bound by a Data Processing Agreement consistent with Article 28 GDPR, processes data only on Nova’s documented instructions, applies appropriate security measures, and may not use the data for its own purposes (including for AI model training).

c. Public authorities where legally required, or in the context of a corporate transaction (merger, acquisition, restructuring) under appropriate confidentiality and data-protection safeguards.

6. International transfers

Some of Nova’s service providers (notably HubSpot and AI providers) are established in the United States. Whenever your personal data is transferred outside the EEA, Nova relies on one or more of the following safeguards under Chapter V GDPR:

  • Adequacy decisions issued by the European Commission, including the EU–U.S. Data Privacy Framework for certified U.S. recipients;
  • Standard Contractual Clauses (SCCs) approved by the European Commission, together with supplementary technical and organisational measures (encryption, pseudonymisation, restricted access);
  • Intra-group transfer agreements between Nova entities incorporating SCCs.

You may request a copy of the relevant safeguards at privacy@novatalent.com.

7. No use of your data to train AI models

Nova does not use the personal data you submit through our websites — including your name, contact details, company information or the content of your inquiry — to train, fine-tune or otherwise improve the underlying foundation models or generative-AI systems we rely on, whether developed by Nova or by third-party AI providers.

Nova’s contracts with its AI sub-processors expressly exclude training on Nova’s data and require zero-retention or short, security-only retention windows.

Nova may use aggregated, anonymised or de-identified information that cannot reasonably be associated with you to improve its commercial processes and content. Such information is not considered personal data under the GDPR.

8. Retention

Nova retains your personal data only for as long as necessary to fulfil the purposes described above:

  • Active leads (engaged with Nova or where commercial follow-up is reasonably expected): for as long as the commercial relationship or interest is reasonably active, plus the statutory limitation periods.
  • Inactive leads (no interaction or response after a reasonable period): up to 24 months after the last meaningful interaction, after which the record is either deleted, anonymised or moved to a suppression list to honour your opt-out.
  • Marketing consent records: for as long as the consent remains valid, plus the period required to evidence its lawful collection (typically 5 years from withdrawal).
  • Legal, accounting and tax records: for the statutory periods applicable in each relevant jurisdiction.

You can request earlier deletion at any time (see Section 9).

9. Your rights

Under the GDPR you have the right to:

  • Access the personal data Nova holds about you;
  • Rectify inaccurate or incomplete data;
  • Erase your data (“right to be forgotten”), subject to legal retention obligations;
  • Restrict or object to the processing, in particular to direct marketing — in which case Nova will stop sending you commercial communications immediately;
  • Withdraw your consent at any time, without affecting the lawfulness of prior processing;
  • Data portability, where applicable;
  • Lodge a complaint with your local Data Protection Authority — for example, the Spanish AEPD (www.aepd.es), the Italian Garante or the Swedish IMY.

To exercise any of these rights, please contact privacy@novatalent.com with the subject line “Data Rights Request – Web Leads.” Every commercial email we send also includes an unsubscribe link.

10. Security

Nova applies appropriate technical and organisational measures to protect your data, including encryption in transit and at rest, least-privilege access control, multi-factor authentication for internal systems, vendor due-diligence and incident-response procedures.

11. Children

Nova’s products and websites are addressed exclusively to professional and adult audiences. Nova does not knowingly collect personal data from individuals under 18 through its commercial web forms.

12. Updates to this Policy

Nova may update this Policy from time to time to reflect legal, technical or business changes. The “Last update” date at the top of this page indicates the latest revision. Material changes will be communicated through the website or, where appropriate, by email.

13. Contact

NGlobal Holding AB (Nova)

privacy@novatalent.com

dpo@novatalent.com

© 2026 NGlobal Holding AB. All rights reserved.

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