This Privacy Notice explains in detail the types of personal data (“Data”) we may collect about you when you interact with us. It also explains how we’ll store and handle the data and keep it safe.
Your privacy is very important to Novus Aviation and to the extent any information you provide or which we obtain from this website constitutes Data, we have set procedures for the use of that
information. When you are using the Novus website, in the UK and European Economic Area (EEA),
Novus Aviation Capital (UK) Limited is the data controller.
Novus Aviation (‘Novus”) is made up of a number of related businesses including:
- Novus Aviation Capital LLC – this company is the headquarters of Novus and is based in Dubai. This company manages the collation and storage of any Data collected via the website.
- Novus Aviation Capital (UK) Limited – this company is established in England and is a registered Data Controller with the Information Commissioners Office
- Novus Aviation SAL (Offshore) – this company is an affiliate of the Data Controller and is based in Lebanon.
For ease of reference throughout this notice, ‘we’ and ‘us’ means Novus.
Legal Bases we rely on to collect and process your Data
The law on data protection sets out a number of different reasons for which a company may collect and process your Data, including:
In specific situations, we can collect and process your Data with your consent.
For example, when you tick a box to send your details to us to apply for a role at Novus.
When collecting your Data, we’ll always make clear to you which Data is necessary in connection with this process.
If the law requires us to, we may need to collect and process your Data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting Novus to law enforcement agencies.
In specific situations, we require your Data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
When do we collect your Data?
- When you visit our website and use the online portal to apply for a job at Novus.
- When you enter into a contract with Novus.
- When you engage with us on social media.
- When you contact us by any means with queries, complaints etc
What sort of Data do we collect?
- IP Address, we may collect information about your computer (including where available your IP address, operating system and browser type) for system administration. This is statistical data about our visitors’ browsing actions and patterns and does not identify any individual unless you register for a role at Novus or contact us via social media.
- If you apply for a role at Novus, we will collect your name, email address and the information contained in your curriculum vitae.
- If you send any requests to us via the website, we may collect your name, work telephone number, work mobile number, work email, work address, job title.
- Your social media username, if you interact with us through those channels, to help us respond to your comments, questions or feedback.
Here’s how we’ll use your Data and why:
When you apply for a position at Novus, we need to collect your name, email contact and your curriculum vitae to assess your suitability for a role and to be able to contact you regarding your application in respect of that role.
If you make a comment or have a question that you send to us via social media, we may need or wish to contact you in relation to the comment or question.
If you do not wish us to collect and process your Data in this way, please contact us at the email address below or in writing and we will delete your Data.
How to get a copy of your personal information
If you would like a copy of the Data that we hold on you, or you would like a copy of the Data in a digital file you can use yourself or share easily with other third parties, please write to us at the below email address or at the address below:
SubjectAccessRequest@Novus.aero or write to us at:
Data Subject Access Request
Novus Aviation Capital (UK) Limited
15 Stratton Street
W1J 8LQ London.
Novus does not engage in combined direct marketing.
How we protect your Data
We will treat your Data with the utmost care and take all appropriate steps to protect it, including contracting with third parties who themselves have recognized certified compliance security measures such as compliance with
ISO 27001 and who have undertaken accredited GDPR compliance training courses.
We regularly monitor our system for possible vulnerabilities and attacks, and we carry out penetration testing to identify ways to further strengthen security
How long will we keep your Data?
Whenever we collect or process your Data, we’ll only keep it only for as long as is necessary for the purpose(s) for which it was collected and, we will keep it in accordance with the terms of this Privacy Notice and Novus’s internal data privacy policies, as applicable. Your Data will be held by Novus as set out below:
- Data will be held only for as long as we maintain an ongoing relationship with you (e.g., where you are an applicant for a vacant role at Novus);
- Where your Data is held in connection with the lawful purposes set out in this Notice, for which we have a valid legal basis (e.g., where your Data is included in a contract between us and your employer, and we have a legitimate interest in processing the Data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Data),
- For the duration of any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Data, or which your Data may be included in;
- A further 12 months following the end of the applicable limitation period; and
- In addition, if any legal claims are brought, we may continue to hold and process your Data for such additional periods as the Data is needed in connection with any legal claim, or any obligation under applicable law.
At the end of any retention period as set out above, the Data will either be deleted in its entirety, archived so it is put beyond use or anonymized, for example by aggregation with other Data so that it can be used in a non-identifiable way for internal data statistics or business analysis.
Who do we share your Data with?
- Novus group companies
- To third-party service providers, including IT companies who support our website
- To enforce the Terms & Conditions of our website or any other contracts entered into between you and us
- To law enforcement agencies
- To protect our rights or the rights of others, or if we are obligated to do so to comply with any legal or regulatory obligations.
Here’s the policy we apply to those organizations to keep your data safe and protect your privacy:
- We provide only the information they need to perform their specific services.
- They may only use your data for the exact purposes we specify in our contract with them.
- We work closely with them to ensure that your privacy is respected and protected at all times.
- If we stop using their services, Data held by them will either be deleted or rendered anonymous.
For further information please contact us at the email address or by post at the address below.
Where your Data may be processed
Sometimes we will need to share your Data with our group companies and third parties and suppliers outside the European Economic Area (EEA).
Protecting your Data outside the EEA
The EEA includes all EU Member countries as well as Iceland, Liechtenstein and Norway.
We may transfer Data that we collect from you to our group companies and third-party data processors in jurisdictions that are outside the EEA such as Dubai, Hong Kong or Lebanon.
If we do this, we have procedures in place to ensure your Data receives the same or equivalent protection (as applicable) as if it were being processed inside the EEA. Any transfer of your Data will follow applicable laws and we will treat the information under the guiding principles of this Privacy Notice. For those countries not in the EEA or on a White List, we have put in place contractual arrangements to place similar obligations on those third parties to hold the Data in line with (or equivalent to) the requirements of GDPR.
An overview of your different rights in relation to the Data
You are entitled, in accordance with applicable law, to object to or request restriction of processing of your Data, and to request access to, rectification, erasure and portability of your Data. This service is provided free of charge unless requests are manifestly unfounded or excessive. In these circumstances, we reserve the right to charge a reasonable fee or, refuse to act on the request. You can contact us on DPO@novus.aero or write to us at Novus Aviation Capital (UK) Limited, 15 Stratton Street W1J 8LQ London.
If we choose not to action your request, we will explain to you the reasons for our refusal.
If any of the Data that we hold about you is incorrect, please tell us and we will put it right.
Your right to withdraw consent
Whenever you have given us your consent to use your Data, you have the right to change your mind at any time and withdraw any such consent.
Where we rely on our legitimate interest
In cases where we are processing your Data on the basis of our legitimate interest, you can ask us to stop for reasons connected to your individual situation.
We must then do so unless we believe we have a legitimate overriding reason to continue processing your Data.
Contacting the Regulator
If you feel that your Data has not been handled correctly, or you are unhappy with our response to any requests you have made to us regarding the use of your Data, you have the right to lodge a complaint with the Information Commissioner’s Office.
You can contact them by calling 0303 123 1113.
Or go online to www.ico.org.uk/concerns (opens in a new window; please note we can’t be responsible for the content of external websites)
If you are based outside the UK, you have the right to lodge your complaint with the relevant data protection regulator in your country of residence.