1. Introduction

Welcome to Headway NOVA (“us,” “we,” “our” or the “Company,” the “App”). This Privacy Policy defines the rules and purposes for processing Headway NOVA clients’ personal data and outlines the actions our employees take to protect this data from unauthorized access by third parties. The Company affirms its commitment to laws on privacy, data protection, and data security.

2. Purpose

The purpose of the Privacy Policy is to determine what data or information the Company may collect, with whom the company could share this information, and the general usage of it. By using the App and the Website (hwnova.site), you agree to the collection and use of information in accordance with this Privacy Policy. If you disagree with any part of this policy, please do not use the App and the Website.

3. Collecting personal data

3.1. By registering in the company’s website(s) and app(s), you agree to have your personal data processed and specifically consent to the collection, systemization, aggregation, storage, revision (updating, changing), usage, anonymization, blocking, deletion, and distribution (transfer) of said personal data to third parties in accordance with the conditions set forth in this Privacy Agreement. 

3.2. We ask you for the necessary data while registering in the Headway NOVA app to provide functional service. Providing this data is required for client identification, and we may also collect data to improve our understanding of your needs and preferences by communicating through Live Chat. Please note that you provide this data to us voluntarily.

3.3 We use the data that you directly provide when communicating. If you do not want your personal information to be collected, please do not submit it. 

3.4. Personal information: 

The information that we may collect from you includes the following: 

• Full name, residential address and contact details (e.g., email address, telephone number, fax etc.); 
• Date of birth, place of birth, gender, citizenship; 
• Information about your income and wealth, including details about your source of funds, assets and liabilities, bank account information, FATCA and CRS information, and financial statements;
• Information on whether you hold a prominent public function (PEPs); 
• Profession and employment details; 
• Authentication data (e.g., signature); 
• Location data; 
• Investment performance, knowledge and experience; 
• Verification information, which includes information necessary to verify your identity such as a passport or driver’s license (examples also include background information we receive about you from public records or from other entities not affiliated with us); furthermore, we may collect other identifiable information such as identification numbers and/or Passport/Tax registration numbers; 
• Digital wallet addresses connected to the app that you may use to transfer and receive your Headway NOVA tokens (note that we do not require or collect private keys, and it is of utmost importance that you keep your private key confidential and secure);
• Any other information customarily used to identify you and about your investment experience which is relevant to us providing our services to you.

3.5. Device and Usage Information:

We may collect technical information about your device, including the unique device identifier, operating system, and mobile network information. We may also gather information about your use of the App, such as transaction details, IP address, and pages visited, activity, and movement on the website and/or the app.

4. How We Use Your Information

4.1. Provide and Improve Services:

We use your personal information for the following purposes:

• to confirm your identity;
• to maintain your personal profile;
• to provide you with our investment services;
• to communicate with you when necessary or appropriate in relation to the services being provided to you;
• to process transactions;
• to improve our offerings based on your feedback.

4.2. Security and Fraud Prevention:

We may use your information to monitor and prevent unauthorized activities, detect fraud, and enhance the security of our App and the Website.

We prioritize the security of your personal information. While we implement industry-standard measures to protect your data, it is important to note that no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but will continuously strive to protect your information to the best of our abilities.

4.3. Personalization:

We may use your information for the following purposes:

• to provide you with information about our products and services, and offer you information or opportunities that we believe might be relevant to you;
• to provide personalized content, recommendations, and advertisements based on your interests and preferences;
• to tailor the website, the app, or other services we provide to you according to your needs and interests, and to create anonymous statistical data;
• When you access the company’s website(s) and the app(s), we may automatically (i.e., not necessarily with registration) collect statistical information that is not personally identifiable, such as the type of internet browser or mobile application store and computer or mobile operating system used, the domain name of the website you come from, and the number of visits, average time spent, and pages viewed, etc. The Company may use this information and share it within the Company’s group for statistical reasons (i.e., measure the use of its app or website and/or improve its content).

5. Disclosure of Your Personal Information

5.1. The Company shall not disclose any of its clients’ confidential information to a third party, except: 

• to the extent that it is required to do so pursuant to any applicable laws, rules, and/or regulations;
• if there is a duty to the public to disclose;
• if our legitimate business interests require disclosure;
• at your request or with your consent or to anyone authorized by you.

5.2. As part of this policy, The Company disclose your personal information to the following: 

1. our regulator and all regulatory companies and governmental bodies that the Company is required to disclose information to;
2. service providers (for business purposes), including third parties such as business service providers and specialist advisers who have been contracted to provide us with administrative, financial, legal, tax, compliance, insurance, research, or other services; 
3. payment service providers (PSPs) and/or banking institutions in relation to issues raised regarding purchasing/withdrawals to/from investing account(s) held with the Company; 
4. business parties, credit providers, courts, tribunals, and regulatory authorities as agreed or authorized by law; 
5. business introducers with whom we have a mutual business relationship; 
6. anyone authorized by you.

6. Third-party links

The App may contain links to third-party websites or services. We are not responsible for the privacy practices or content of such websites. We encourage you to review the privacy policies of those third parties before providing any personal information.

7. Use of cookies

7.1. We use cookies to ensure that our website works effectively and to support your investment activities. Cookies are small text files sent from our web server to your computer. Our cookies do not contain any personal data, account data, or passwords.
7.2. We may enlist outside organizations to help us manage the website and collect and analyze statistical data. These outside organizations may install and use their own cookies on our behalf.

8. Changes to this Privacy Policy

We may update our Privacy Policy from time to time by posting a new version of the policy on our website or within the app. We recommend that you periodically read this Privacy Policy to always have the latest information regarding how your personal data is processed. Your continued use of the app signifies your acceptance of the updated Privacy Policy.

9. Contact us

If you have any questions or concerns regarding this Privacy Policy, please contact us at [email protected]