Privacy Policy

INTRODUCTION

Nuvo Holding Ltd and its affiliates with its registered office address at Office 09, Level P5, Tower A, Damac Park Towers, Dubai International Financial Centre (DIFC), Dubai, UAE (collectively “we” or the “Company”) are committed to protecting the privacy and security of your personal data. For purposes of this privacy policy, personal data means any information or data about an individual from which that person may be identified.

This privacy policy (the “Policy”) supplements other data protection related policies and privacy notices that the Company may issue from time to time and is not intended to override such policies or notices. The Company acts as a controller of your personal information collected via its website where we determine how and why personal information can be used. This Policy, does not, however, apply where we act as a processor or service provider to another controller, such as our customers.

PURPOSE

The Company has established this Policy to inform you as to how it collects, uses and stores your personal data when you visit and use the Company’s website. This policy also informs you about your rights under the applicable data protection laws and regulations (the “Data Protection Legislation”).

Our legal basis for processing personal data includes (i) your consent (ii) the performance of a contract (iii) compliance with legal obligations; and (iv) our legitimate interests, which shall not override your data protection rights.

The Company’s website is not intended for children and as such the Company does not knowingly collect information relating to children.

SCOPE

This Policy applies to all who visit and use any functionality of the Company’s website –https://www.nuvo-energy.com/ (the “Website”). The Company’s Legal and Compliance department and the Company’s Data Protection Officer is responsible for overseeing this, Policy. Any comments, complaints, or questions may be emailed to the Company’s Data Protection Officer at info@nuvo-energy.com.

INFORMATION THAT WE COLLECT AND PROCESS

When you use the Website, we may collect, store, and use the following categories of your personal data:

• Name & contact information like title, home addresses, telephone numbers, and personal email addresses
• Date of birth
• Gender
• Security information like User credentials — username and password — and similar security information, individual network activity in security and audit logs
• CCTV footage and other information obtained through electronic means such as swipe card records obtained at our locations
• Device & browser information including Network and Internet service provider (ISP) information, Internet Protocol (IP) addresses, device and browser identifiers, device and browser information, advertising identifiers, cookie and tracker identifiers, and related information
• User and browsing information like Usage, search, and browsing history; user journey history, including clicks, navigation, user actions, interactions, and session replays; and usage and diagnostics analytics and metrics, including on our Services and our internal networks and corporate devices by employees, contractors, and site visitors
• Location data like region, country, state, and coarse and precise geolocation data
• Biometric information like fingerprints, scans of face geometry, and other data generated by automatic measurements of an individual's physiological, biological, or behavioural characteristics
• Information about your use of our information and communications systems

HOW WE COLLECT YOUR PERSONAL INFORMATION

We use different methods to collect data from and about you through the following:

• Direct interactions where you may provide the Company your personal information when you interact with us, such as when you register to do business with the Company, fill in forms, communicate with us, apply for jobs, and work for us. In some cases, if you do not provide us with your personal information, we may not be able to do business with you, communicate with you, or respond to your inquiries.
• User contributions where collect your personal information when you or others upload, share, send, or input that information through our website or networks or when you or they communicate with us.
• Automatically when you interact with the Website, or visit our offices or events, open emails or view advertisements from us, or communicate with us. We may collect some of this personal information by using cookies and other similar technologies and we recommend you review our Cookie Policy for further details.
• Third-party or publicly available sources who may share with us your personal information. Third party sources may include but are not limited to our third-party business partners, including data brokers and advertising partners; your organizations; governmental agencies who publish public records; and other publicly or generally available sources, including online websites

We may require certain personal data to allow you to use the Website and certain functionalities may not be accessible to you and where we need to collect personal data.

HOW WE USE INFORMATION ABOUT YOU

We will only use your personal data when the law allows us to. We mostly use your personal data in the following circumstances, and in connection with the Website:

• Register you as a new customer or supplier;
• Perform our obligations under a contract we may have with you;
• To improve the Website;
• To make suggestions and recommendations to you about our business activities;
• To ask you to provide feedback or participate in a survey;
• Where we need to comply with a legal obligation;
• To send you marketing communications, or such other notifications from the Company; or
• it is necessary for legitimate interests pursued by the Company, or a third party and your interests and fundamental rights do not override those interests.

It is important that the personal data we hold about you is current and accurate. If you wish to update your personal information, please do reach out to the Company’s Data Protection Officer at info@nuvo-energy.com.

PERSONAL DATA SHARING

We may have to share your data with third parties, including third-party service providers and other entities with the Company’s group. We require third parties to respect the security of your data and to treat it in accordance with the law.

The Company will mostly share your personal data with:

• its affiliate companies;
• its website hosting provider to the extent needed to for it to fulfil its website related services;
• third party business partners who support the Company’s business such as content and our partners, vendors, advertising or marketing agencies and other third parties that we engage;
• with government agencies and third parties involved in our sale or purchase of a business including reorganisation, dissolution or such other disposition of assets; or
• with other necessary to fulfil your consents or to follow your instructions.

The Website may include links to third party websites plug-ins and applications. Clicking on these links or enabling those connections may allow third parties to collect, use and share your personal data. We do not control these third-party websites and are not responsible for their privacy statements or policies. We encourage you to read the privacy policy of every website you visit whenever you are re-directed to a third-party website.

HOW WE STORE YOUR PERSONAL DATA

As the Company is a global organisation, your personal data may be transferred outside of your home jurisdiction and may be stored in and accessed from multiple countries including the United Arab Emirates, Singapore, Switzerland. Where personal data is transferred outside your jurisdiction, we will ensure that adequate safeguards are in place, such as a Standard Contractual Clauses approved by the European Commission or equivalent mechanisms under applicable laws.

When you interact with us, you authorise us to transfer your personal information outside your home jurisdiction, and you acknowledge the risk that we may transfer your personal information to jurisdictions that may provide less protection than your home jurisdiction’s Data Protection Legislation and we may not be able to prevent government authorities in some jurisdictions from accessing your personal data.

HOW WE SECURE YOUR PERSONAL DATA

We work to implement technical and organisational measures designed to protect the security of personal information. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee its absolute security.

The security of your information also depends on you: you are responsible for using unique, strong usernames and passwords for each of your accounts and for keeping those usernames and passwords confidential. We are not responsible for the circumvention of any privacy settings or cybersecurity measures contained on the Website, and any transmission of personal information is at your own risk.

RIGHTS OF ACCESS, CORRECTION, ERASURE, AND RESTRICTION

Under certain circumstances, by law you have the right to:

• Right to withdraw consent — when we process your personal data based on your consent — without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to confirm we can process your personal information and, if so, to access — including, where possible, in a portable format — correct, complete, and delete your personal information.
• Right to restrict or object to the processing of certain personal information, including, where relevant, the right to opt out of our processing of your sensitive personal information and opt out of automated decision making or profiling that produces a legal or similarly significant effect.
• Right to opt out of marketing emails from us, in which you may email us or click the unsubscribe link at the bottom of each email that you receive from us.
• Residents of certain U.S. states may also have the right to opt out of the use of their personal information for profiling or targeted advertising, including online behavioural advertising, and to opt out of the sale or sharing of their personal information, in which you may, in addition to the below, click the “Do not sell or share my personal information/limit the use of my sensitive personal information” link or change the cookie settings through our cookie banners.

To submit a request, please do reach out to the Company’s Data Protection Officer at info@nuvo-energy.com. Please note that the Company may request you to provide specific information to help it confirm your identity and ensure your right to access your personal data or exercise your rights. This is also a security measure to ensure that your personal data is not disclosed to any person who has no right to receive such information.

DATA RETENTION

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. Once you are no longer an employee, worker or contractor of the company we will retain and securely destroy your personal information in accordance with our Data Retention Policy or applicable laws and regulations.

In the event of infringement, you have the right to lodge a complaint with a supervisory authority where you reside or where the alleged infringement occurred.

CHANGES TO THIS POLICY

We reserve the right to update this Policy at any time, and will notify you of any material changes to this policy by posting an update on our website, or, where appropriate, contacting you directly.

If you have any questions about this Policy, please contact the Company’s Data Protection Officer at info@nuvo-energy.com.

CONTACT DETAILS

The Company has appointed a Data Protection Officer who is responsible for overseeing questions relating to this Policy. Please reach out to the Data Protection Officer by using the details set out below:

Data Protection Officer - info@nuvo-energy.com.

Address: Nuvo Holding Ltd

C/O Office 09, Level P5, Tower A, Damac Park Towers, DIFC, Dubai, UAE.