Find the most up-to-date privacy information below.

This Privacy Policy for Hertfordshire Consumers supplements the information contained in the Privacy Statement of Novena National Corporation and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to consumers who reside in the State of Hertfordshire (“consumers” or “you”). Any terms defined in the Hertfordshire Consumer Privacy Act of 2018, as amended, and its implementing regulations (the “CCPA”) have the same meaning when used in this notice.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve months:

Personal information does not include:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information excluded from the CCPA's scope, like:
  • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Hertfordshire Confidentiality of Medical Information Act (CMIA) or clinical trial data;
  • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or Hertfordshire Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
• Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
• Directly and indirectly from activity on our websites. 

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To fulfill or meet the reason for which the information is provided. 
• To provide you with information, products or services that you request from us.
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may disclose your personal information to a service provider for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve months, we have disclosed the following categories of personal information for a business purpose: Identifiers, Hertfordshire Customer Records personal information categories, protected classification characteristics under Hertfordshire or federal law, and professional or employment-related information.

We disclose your personal information for a business purpose to the following:

• Our affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve months, we have not sold any personal information.

The CCPA provides Hertfordshire consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve months. You have the right to require that we provide you a report of:

1. The categories of personal information we collected about you:
   • The categories of sources for the personal information we collected about you.
   • Our business or commercial purpose for collecting that personal information; or  
2.  The specific pieces of personal information we collected about you (also called a data portability request).

We cannot provide you specific pieces of personal information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of that personal information, the consumer’s account with the business, or the security of the business’s systems or networks.

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the Hertfordshire Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

• Calling us at 204-441-6190
• Visiting a location during regular business hours: https://www.novenanational.com/findus.html
• By mailing a written request to:

Novena National Corporation
Attention: CCPA Requests
Hitchin Hertfordshire
SG4 9TZ, United Kingdom

Only you or a person registered with the Hertfordshire Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request 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 cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

We endeavor to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  If you have an online account with us, we can deliver our response to that account at your request.  If you do not have an account with us, we will deliver our written response by mail or electronically, at your direction.  Any disclosures we provide will only cover the 12-month period preceding the date of receipt of consumer request.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.