NOVM PRIVACY POLICY

NOVM PRIVACY POLICY The Policy

This policy will explain how Novm Group Pty Limited and its related bodies corporate (together, Novm) collect, store, use, disclose and manage your personal information (Policy).By providing your personal information to Novm, you consent to the collection, use, storage, disclosure and management of your personal information in accordance with this Policy.In this Policy, ‘personal information’ includes any information, opinion, whether true or not, that is capable of identifying an individual.

Novm’s business

Novm’s key business activities revolves around property development, funds management and real estate agency services.

Collecting personal information

Novm generally collects personal information in the following ways:

• directly, or indirectly from you (when you interact with Novm);
• indirectly from you, when you communicate with Novm by telephone, mobile, email, face to face, or through online and social media interactions;
• when you participate in Novm’s surveys or promotions; and
• when you use Novm’s websites

Whenever you interact with Novm, your personal information may be collected. The type of personal information collected will depend on the nature of your interactions.Novm may collect any personal information that may be required to assist your dealings and interaction with Novm, including (but not limited to):

• financial information (including bank account details, credit card numbers, your income and credit standing);
• information about your preferences or requirements that are relevant to Novm’s products and services;
• information about your identity (including name, date of birth, gender, visa or residency status, identification documents, address, email, telephone and mobile number);
• your device type or ID, location information, IP address, browsing information and any personal information you may provide to Novm directly or indirectly through Novm’s websites and mobile applications; and
• your preference of Novm’s products, services, facilities and lifestyle activities.

Your personal information may also be collected from third parties, such as:

• credit reporting bodies, law enforcement and government entities;
• marketing agencies, data collection and research organisations; and
• other individuals.

No obligation

You do not have to provide personal information to Novm. You can choose to deal with Novm anonymously. However, if you decide not to provide your personal information, Novm may not be able to provide you with products or services that are tailored to your needs.

Purpose of collecting personal information

Novm collects, stores, uses and discloses your personal information for the following purposes:

• for security and risk management purposes;
• for the general management and conduct of Novm’s business;
• to communicate with you;
• to comply with Novm’s legal obligations;
• to do business with you;
• to help manage, develop and enhance Novm’s services (including websites);
• to investigate incidents; and
• to provide and market Novm’s products and services.

Novm will not use or disclose your personal information for any purpose other than the purpose it was collected for (or a related purpose) unless Novm first obtains your consent to that purpose, or Novm is permitted to do so by law.

Disclosure of personal information

Novm may disclose your personal information for the purposes for which it was collected for (or a related purpose) to the following:

• other companies, service providers and individuals who assist Novm to perform certain functions on our behalf, such as hosting and data storage providers;
• other companies, services providers and individuals who assist Novm with provision of our services;
• regulatory authorities, police, government agencies or where required by law;
• related parties and entities of Novm; and
• social medial channels which Novm has a presence on (such as Facebook, Instagram, Youtube, LinkedIn and WeChat).

Where personal information is disclosed to a third party acting on behalf of Novm, Novm will request for such third parties to not use your personal information for their own purposes and to comply with this Policy and the applicable law in your state and country.

Marketing

Novm and its third-party service providers may send you direct marketing communications and information about Novm’s products, services, discounts and special promotions that may be of interest to you, including any offers or promotions based on our products and services.These communications may be sent in different forms, including telephone, mobile, post, fax, email, SMS, or any other form of electronic communication.When you provide Novm with your contact details, you consent to Novm and its third-party service providers to send you direct marketing messages.

Unsubscribing from marketing communications

You can unsubscribe from any, or all, of the direct marketing communications at any time by contacting Novm using one of the following methods:

• by telephone to +61 2 8011 1556
• by email to info@novm.com.au or
• by post to Novm Group, Suite 30.02, Level 30, 420 George Street, Sydney NSW 2000.

For email communications you will be able to find a link to unsubscribe, usually towards the bottom of the email.If Novm are providing services to you, there may still be a requirement for certain communications to be made to you in providing these services or products as required by law.

Updating personal information

If you would like to update, access or correct your personal information that Novm holds, you can contact Novm using the methods listed above. Depending on the nature of your request, Novm may require further information to verify your identity or ask you to put in writing the information you need. There may be instances where access cannot be granted to your personal information (for example, legal exception or breach of confidentiality), and Novm will provide you with written reasons for the refusal.

Security

Novm may hold your personal information in electronic or hard copy format. The confidentiality and security of your personal information is important to Novm, and reasonable steps will be taken to protect your personal information from misuse, interference and loss, as well as unauthorised access, modification or disclosure.Novm uses several physical, administrative, personnel and technical measures to protect your personal information. However, given the nature of the internet, there is always a risk that an unauthorised party may find ways to overcome our security measures, and it is not possible to guarantee the security of your personal information. You should also be aware that email communications are usually not encrypted and should not be considered secure. Where required by law, Novm will notify you and the relevant regulatory authorities of data breaches affecting your personal information.When Novm no longer needs your personal information, reasonable steps will be taken to destroy it.

Third party links

Novm’s website and mobile applications may contain links to websites owned and operated by other parties. When you click on these links, you are leaving Novm’s website. Novm is not responsible for the privacy practices or content on such websites. You should read the privacy policies and other terms that apply to those websites as they may differ from this Policy.

Questions or complaints

If you have any questions about how Novm handles your personal information, or would like to make a complaint, please direct them to Novm using one of the communication methods identified above.Novm will investigate your complaint after our investigation and contact you to advice the outcome and invite a response to the findings.

Updates to this Policy

Novm may update this Policy from time to time to take into consideration new laws and technology, and changes to our business operations and practices.Effective Date: December 2022