Privacy Policy

1. Information We Collect

We collect and process the following categories of personal data:

• Identity Data: Name and organization, where provided
• Contact Data: Email address, phone number, postal address, where provided
• Inquiry Data: Information you voluntarily include in website forms or correspondence
• Technical Data: IP address, browser type, device information, cookies
• Usage Data: How you interact with our website and services
• Communication Data: Your preferences and correspondence with us

2. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent: For newsletters, optional communications, and non-essential cookies where required
• Legitimate Interests: To respond to inquiries, operate the website, improve content, and maintain security
• Legal Obligation: To comply with applicable corporate, tax, and regulatory obligations

3. How We Use Your Information

We use your personal data for:

• Responding to information requests and partnership inquiries
• Providing educational resources and corporate updates
• Operating, securing, and improving the website
• Managing newsletter subscriptions and communication preferences
• Complying with legal and regulatory requirements

4. Sensitive Information

This website is not intended for clinical intake and does not request genetic, biometric, or medical-record data. If you voluntarily include sensitive information in an inquiry:

• We will use it only as needed to respond to your inquiry or meet legal obligations
• We may advise you to discuss medical matters with a qualified provider
• We will avoid requesting unnecessary sensitive information through public website forms

5. Data Sharing and International Transfers

We may share your data with:

• Service providers that help us operate the website and communications
• Professional advisers and compliance partners where needed
• Partner clinics or organizations only when you request or consent to an introduction
• Regulatory authorities when required by law

For transfers outside the EU/EEA, we ensure appropriate safeguards through: Standard Contractual Clauses (SCCs), adequacy decisions, or your explicit consent.

6. Data Retention

We retain your personal data for:

• Inquiries: As long as needed to respond and maintain a reasonable business record
• Technical logs: For a limited period needed for security and diagnostics
• Business records: As required by applicable law
• Marketing communications: Until you unsubscribe

7. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion (subject to legal retention requirements)
• Right to Restriction: Limit processing of your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to certain types of processing
• Right to Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact our Data Protection Officer at dpo@novagen-group.com.

8. Cookies and Tracking

We use cookies and similar technologies to:

• Essential cookies: Required for website functionality
• Analytics cookies: To understand website usage (with consent)
• Marketing cookies: For relevant advertising (with consent)

You can manage cookie preferences through our cookie banner or browser settings.

9. Data Security

We implement appropriate technical and organizational measures:

• Access controls and role-based permissions
• Encryption in transit where supported
• Security review and incident response procedures
• Staff training on data protection
• Incident response procedures

10. Children's Privacy

This website is intended for adults. We do not knowingly collect personal data from children through this website.

11. Automated Decision-Making

We do not use fully automated decision-making through this website that produces legal or similarly significant effects. Any AI-assisted content is informational and does not replace professional judgment.

12. Complaints

If you have concerns about our data processing, you can:

• Contact our Data Protection Officer: dpo@novagen-group.com
• Lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens): autoriteitpersoonsgegevens.nl

13. Changes to This Policy

We may update this privacy policy to reflect changes in our practices or legal requirements. We will notify you of significant changes via email or website notice.