Privacy Policy

Novum Inc. (“Novum”, “we”, “us”, or “our”) is committed to protecting the privacy and security of your personal information. This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you access our website, place orders, use our services, participate in our Gift with Purchase (GWP) promotions, or engage with us across all 11 product categories.

This Privacy Policy forms an integral part of our Terms of Service. Capitalized terms used herein have the same meaning as in our Terms of Service, Gift with Purchase Promotion Rules, Shipping Policy, International Shipping Info, and Return & Refund Policy. By using our website or services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy.

1. Definitions

· Personal Information / Personal Data: Any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a specific individual or household, as defined under applicable privacy laws including the California Consumer Privacy Act (CCPA/CPRA), the EU General Data Protection Regulation (GDPR), the UK GDPR, and Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA).

· Data Controller: The entity that determines the purposes and means of processing personal information. Novum Inc. is the Data Controller of personal information collected through our website and services.

· Service Provider: Any thirdparty entity that processes personal information on our behalf and under our instructions, for the purposes described in this policy.

· Final Paid Amount: The total amount actually paid by the customer for a single individual order, including merchandise subtotal, shipping charges, and all applicable taxes, after all discounts, coupons, gift cards, store credits, promotional codes, refunds, and any other adjustments have been applied.

· MSRP: Manufacturer’s Suggested Retail Price, the official retail price published by the manufacturer of a product or GWP item. MSRP is the sole and exclusive valuation reference for all GWP items for all purposes.

· GWP: Gift with Purchase, a conditional promotional gift program under which complimentary goods are provided to customers who meet specified purchase thresholds.

· Sale of Personal Information: As defined under the CCPA, exchanging personal information for valuable consideration. We do not sell your personal information.

2. Information We Collect

We collect personal information that you provide directly to us, information we collect automatically when you use our services, and information we obtain from thirdparty sources. We only collect information that is reasonably necessary for the purposes described in this policy.

2.1 Information You Provide Directly

· Account & Registration Information: Name, email address, password, phone number, and other information you provide when you create an account, update your profile, or register for promotions.

· Order, Transaction & GWP Information: Billing name, shipping address, email address, phone number, payment details, order history, and information related to GWP promotion eligibility verification, tier qualification, fulfillment, returns, refunds, and exchanges. We do not store full credit card numbers; payment information is processed exclusively by our authorized payment processors.

· Customer Support Information: Information you provide when you contact customer service, submit inquiries, report issues, request warranty assistance, or initiate returns or refunds.

· Promotional & Marketing Information: Information you provide when you opt in to marketing communications, enter contests, participate in surveys, or claim GWP offers.

· Custom & Special Order Information: Information you provide for custom, personalized, madetoorder, or specialty products across all categories.

2.2 Information Collected Automatically

· Device & Usage Information: Device type, operating system, browser type, IP address, approximate geographic location, pages visited, time spent, click patterns, cart contents, and other usage data when you interact with our website or services.

· Cookies & Similar Technologies: Information collected through cookies, pixel tags, web beacons, local storage, and similar technologies as described in Section 7 below.

· Fraud & Security Information: Information related to account verification, payment authentication, fraud detection, and security monitoring.

2.3 Information from Third Parties

We may obtain information about you from thirdparty service providers, including:

· payment processors and financial institutions for payment verification, authorization, and fraud prevention;

· address verification and logistics providers for shipping accuracy, delivery confirmation, and customs processing for international orders;

· identity verification services for security, regulatory compliance, and highvalue order processing;

· analytics providers for service improvement and website optimization.

3. How We Use Your Personal Information

We process personal information only for specific, documented purposes and on the basis of applicable lawful grounds, including performance of a contract, legitimate business interests, compliance with legal obligations, and your consent where required.

3.1 Primary Purposes

1. Order Fulfillment & Contract Performance
To process and fulfill your orders, including payment processing, shipping, delivery, logistics coordination, customs declaration for international orders, GWP promotion eligibility verification and fulfillment, returns, refunds, and customer support. This includes sharing necessary information with logistics providers, payment processors, and customs brokers.

2. GWP Promotion Administration
To verify GWP tier eligibility, process GWP fulfillment, coordinate GWP returns and refund adjustments, enforce quantity limits and antiarbitration rules, and communicate GWPrelated updates. This is a legitimate business interest in administering our promotional programs in accordance with applicable law.

3. Account Management & Security
To create and maintain your account, verify your identity, authenticate transactions, prevent fraud, detect suspicious activity, and secure our systems and services.

4. Service Improvement & Optimization
To improve our website, products, services, and customer experience; to analyze usage patterns, performance, and conversion; and to develop new features, offerings, and promotions.

5. Marketing & Promotional Communications
To send you information about products, promotions, GWP offers, and news that may be of interest to you, in accordance with applicable law and your marketing preferences. You may opt out of marketing communications at any time.

6. Legal & Regulatory Compliance
To comply with applicable laws, regulations, tax obligations, customs requirements, court orders, subpoenas, and other legal processes.

7. Product Safety, Quality & Warranty Assistance
To assist with product warranty claims, product recalls, quality investigations, and safety notifications for products across all 11 categories. We may share limited order and contact information with the relevant product manufacturer solely for these purposes.
Each product manufacturer is an independent data controller with its own privacy policy governing its use of your information. We do not control and are not responsible for the privacy practices of any manufacturer.

3.2 Retention of Information

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, including:

· for the duration of our contractual relationship and to fulfill our legal and contractual obligations;

· for tax, accounting, and recordkeeping purposes as required by applicable law;

· for the establishment, exercise, or defense of legal claims;

· for fraud prevention, security, and regulatory compliance purposes.

4. Disclosure of Personal Information

We may disclose your personal information in the circumstances described below, subject to applicable legal requirements. We do not disclose more information than is reasonably necessary for the stated purpose.

4.1 Service Providers

We may disclose personal information to thirdparty service providers that perform services on our behalf and under our instructions, including:

· payment processors and financial institutions;

· shipping, logistics, fulfillment, and customs brokerage providers;

· customer support and ticketing providers;

· website hosting, IT, and technology service providers;

· analytics, marketing, and advertising providers;

· fraud prevention, identity verification, and security services.

All service providers are contractually required to:

· process personal information only as instructed by us and for no other purpose;

· implement appropriate technical and organizational security measures;

· not use personal information for their own independent commercial purposes;

· maintain the confidentiality and security of personal information;

· only retain information as long as necessary to perform the services.

4.2 Product Manufacturers

We may disclose limited order and product information to the manufacturers of products you purchase or receive as GWP items, solely for the purposes of:

· processing warranty claims, returns, and product replacements;

· product recall and safety notifications;

· quality control, product improvement, and regulatory reporting;

· fulfillment of GWP promotions where the manufacturer ships directly to the customer.

Manufacturers are independent data controllers. Their use of your personal information is governed by their respective privacy policies. We do not control and are not responsible for the privacy practices of any manufacturer.

4.3 Legal & Regulatory Disclosures

We may disclose personal information if we believe in good faith that disclosure is necessary to:

· comply with applicable laws, regulations, legal processes, or governmental requests;

· protect our rights, property, or safety, or that of our users, employees, or the public;

· detect, prevent, or address fraud, security, or technical issues.

4.4 Business Transfers

In the event of a merger, acquisition, sale of assets, bankruptcy, insolvency, or other business transition, personal information may be transferred as part of the transaction. We will notify you of any such change in ownership or control of your personal information via email or a prominent notice on our website prior to the transfer.

4.5 No Sale of Personal Information

We do not sell your personal information to third parties for valuable consideration. We also do not sell or share personal information for crosscontext behavioral advertising purposes in a manner that constitutes a “sale” under the CCPA or applicable state laws.

5. International Data Transfers

We are headquartered in the United States. Personal information we collect may be stored and processed in the United States or other countries where we or our service providers operate. These countries may have data protection laws that differ from those in your country of residence.

When we transfer personal information from the European Economic Area (EEA), the United Kingdom, or other jurisdictions requiring adequate safeguards for international transfers, we rely on appropriate and lawful transfer mechanisms, including:

· European Commission Standard Contractual Clauses (SCCs);

· UK International Data Transfer Addendum;

· other legally recognized transfer mechanisms as applicable.

6. Your Privacy Rights & Choices

Depending on your location, you may have the following rights regarding your personal information under applicable privacy laws.

6.1 Rights for California Residents (CCPA / CPRA)

If you are a resident of California, you have the following rights under the California Consumer Privacy Act:

1. Right to Know: You may request details about the personal information we collect, use, and disclose about you, including categories of information, sources of information, purposes of processing, and categories of third parties with whom we share information.

2. Right to Delete: You may request deletion of your personal information, subject to certain exceptions (such as to comply with legal obligations or complete transactions).

3. Right to OptOut of Sale: You may opt out of any “sale” of your personal information. As stated above, we do not sell your personal information.

4. Right to NonDiscrimination: We will not discriminate against you for exercising your CCPA rights. We will not deny you goods or services, charge you different prices, or provide a different level of service.

To exercise your CCPA rights, contact us at 1427150614@qq.com or through our online privacy portal. We will verify your identity and respond within 45 days as required by law. We may deny requests where permitted by law and will explain the reason for denial.

You may designate an authorized agent to make requests on your behalf. Agents must provide written proof of authorization and verify their own identity.

6.2 Rights for European Union & United Kingdom Residents (GDPR / UK GDPR)

If you are located in the European Union or United Kingdom, you have the following rights under the General Data Protection Regulation:

1. Right of Access: You may request access to your personal information and details about how we process it.

2. Right to Rectification: You may request correction of inaccurate, incomplete, or outdated personal information.

3. Right to Erasure: You may request deletion of your personal information, subject to certain exceptions.

4. Right to Restrict Processing: You may request restriction of processing under certain conditions.

5. Right to Data Portability: You may request a copy of your personal information in a structured, commonly used, machinereadable format.

6. Right to Object: You may object to processing based on our legitimate interests or for direct marketing purposes.

7. Right to Withdraw Consent: You may withdraw any consent you have provided at any time, free of charge.

To exercise your GDPR rights, contact us at 1427150614@qq.com. We will respond within one month as required by law. We may charge a reasonable fee for excessive or repetitive requests or may refuse requests where permitted by law.

You also have the right to lodge a complaint with your local data protection authority at any time.

6.3 Rights for Canadian Residents (PIPEDA)

If you are a resident of Canada, you have the following rights under the Personal Information Protection and Electronic Documents Act:

1. Right of Access: You may request access to your personal information held by us.

2. Right to Correction: You may request correction of inaccurate or incomplete personal information.

3. Right to Withdraw Consent: You may withdraw your consent to processing of your personal information, subject to legal and contractual restrictions.

To exercise your PIPEDA rights, contact us at 1427150614@qq.com. We will respond within 30 days as required by law.

6.4 General Information About Exercising Rights

To protect your privacy and security, we may take reasonable steps to verify your identity before responding to requests. We will not honor requests where we cannot verify identity or where permitted by applicable law.

6.5 Marketing OptOut

You may opt out of promotional email communications at any time by clicking the “unsubscribe” link in any marketing email or by contacting us at 1427150614@qq.com.

Please note that you may still receive transactional and servicerelated communications (such as order confirmations, shipping updates, GWP eligibility notices, and customer service responses) even if you opt out of marketing.

7. Cookies & Similar Technologies

We use cookies and similar technologies (pixel tags, web beacons, local storage) to operate our website, improve your experience, analyze usage, manage cart and GWP eligibility, and for marketing purposes.

7.1 Types of Cookies We Use

· Necessary Cookies: Required for basic website functionality, order processing, cart management, and GWP eligibility functionality. These cannot be disabled.

· Analytical Cookies: Help us understand how visitors use our website so we can improve it and optimize our offerings.

· Functional Cookies: Enable enhanced functionality and personalization.

· Marketing Cookies: Used to deliver relevant advertisements and promotional content.

7.2 Managing Cookies

Most web browsers allow you to control cookies through your browser settings. Disabling certain cookies may affect website functionality, including checkout and GWP features.

For California and EU residents, you may also exercise your cookie choices through our cookie consent tool, available on our website.

8. Data Security

We implement appropriate technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, use, alteration, disclosure, or destruction. These measures include:

· encryption of personal information in transit and at rest;

· access controls and authentication requirements;

· regular security audits and assessments;

· employee training and confidentiality requirements;

· thirdparty service provider security assessments.

However, no method of transmission over the internet or electronic storage is 100% secure. To the fullest extent permitted by applicable law, we cannot guarantee absolute security of your personal information. We are not liable for unauthorized access, disclosure, alteration, or destruction of personal information that is not caused by our willful misconduct.

9. Children’s Privacy

Our website and services are not directed to children under 13 years of age. We do not knowingly collect personal information from children under 13. If you believe we have collected personal information from a child under 13, please contact us immediately and we will take steps to delete such information.

Where we sell products intended for children, such products are purchased by adults. Personal information provided in connection with children’s products is provided by a parent or legal guardian and is used solely to fulfill the order, provide warranty support, and related services.

10. ThirdParty Links & Services

Our website may contain links to thirdparty websites, services, or applications, including manufacturer websites, payment platforms, social media, and logistics providers. We do not control and are not responsible for the privacy practices, content, or policies of any thirdparty sites or services. We encourage you to review the privacy policies of any thirdparty sites you visit.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time in our sole discretion. Material changes will be posted on this page with an updated effective date. Where required by law, we will provide additional notice of material changes (by email or prominent website notice).

Your continued use of our website or services after changes become effective constitutes your acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

Email: 1427150614@qq.com
Mailing Address:
Novum Inc.
Attn: Privacy Office
One Vanderbilt, 1 Vanderbilt Ave
New York, NY 10017
United States

If you believe our processing of your personal information violates applicable privacy laws, you also have the right to lodge a complaint with the competent data protection authority in your jurisdiction.