NOVOFABRIC — Privacy PolicyThis Privacy Policy (the “Policy”) governs the processing of personal data carried out in connection with access to, navigation of and use of the NOVOFABRIC digital platform (the “Platform”), which operates in a strictly business-to-business (B2B) environment and is intended exclusively for professional users. By accessing or using the Platform, the user confirms that they have read and understood this Policy.

 

Personal data will be processed only where a valid legal basis exists under applicable data protection laws (e.g., contract, legal obligation, legitimate interest or consent where required).

 

NOVOFABRIC attaches the utmost importance to the protection of privacy and personal data relating to users of the Platform, as well as to individuals acting as representatives, contacts or professional interlocutors of clients, suppliers and business partners, and undertakes to process such data in compliance with applicable personal data protection regulations.

 

1. Data controller

 

The data controller for the purposes of applicable data protection laws is:[FULL LEGAL NAME / COMPANY NAME], [NIF/CIF], with registered address at [ADDRESS]. Email (data protection): [privacy@…]

 

If the Platform is operated pending incorporation of a new legal entity, the above identified person/entity acts as data controller until updated details are published.Users may contact NOVOFABRIC regarding data protection matters at [privacy@…], indicating “Data protection” in the subject line.

 

2. Scope of application

 

This Policy applies to the personal data of natural persons who access the Platform, register on it, complete contact forms, request information or otherwise interact with NOVOFABRIC within the context of a strictly professional or business relationship.

 

NOVOFABRIC does not provide services to consumers and does not process personal data within the scope of consumer relationships.

 

3. Categories of personal data processed

 

Depending on the manner in which the Platform is used, NOVOFABRIC may process professional identification and contact data, such as name and surname, job title, company, professional email address and telephone number, as well as data associated with the registration and management of user accounts, where applicable.

 

Data arising from communications maintained with NOVOFABRIC, including enquiries, information requests or incidents, may also be processed.In addition, technical and navigation data strictly necessary for the operation, maintenance and security of the Platform may be processed, including IP address, device type, operating system, browser used and technical logs associated with access.

 

In the future, when payment functionalities are enabled, data necessary for the management of transactions may be processed, which will, where applicable, be handled by duly authorised third-party payment service providers. Where payment functionalities are enabled, payment data may be processed by authorised payment service providers acting as independent controllers under their own privacy policies, or as processors on NOVOFABRIC’s behalf, depending on the specific provider and integration model.NOVOFABRIC does not process special categories of personal data. Users are requested not to provide special categories of data through the Platform.

 

4. Source of the data

 

Personal data is primarily collected directly from the user when they complete forms, register on the Platform or communicate with NOVOFABRIC. Certain data is collected automatically as a result of the use of the Platform, through technical mechanisms necessary for its proper functioning and security. Additionally, in the future, certain data may be obtained through third-party service providers strictly necessary for the operation of the Platform.5. Purposes of processing and legal basisPersonal data is processed only where a valid legal basis exists.

 

In particular, data is processed in order to manage information requests and communications from users, to enable registration and the maintenance of professional relationships with Platform users, to ensure the operation, security and maintenance of the Platform, to comply with legal obligations applicable to NOVOFABRIC and, where applicable, for the future management of transactions and related services.

 

Purposes and legal bases:

 

(a) Account creation and Platform access — performance of a contract / pre-contractual steps.

 

(b) Responding to enquiries and support requests — pre-contractual steps and/or legitimate interest.

 

(c) B2B relationship management and communications — contract and legitimate interest.

 

(d) Security, fraud prevention and Platform integrity — legitimate interest and, where applicable, legal obligations.

 

(e) Compliance with legal obligations (tax, accounting, regulatory) — legal obligation.

 

(f) Transaction management (when enabled) — performance of a contract; payment processing by authorised providers under their terms.

 

The legal bases for processing include the performance of contractual or pre-contractual relationships, NOVOFABRIC’s legitimate interest in the development of its professional activity and compliance with legal obligations. NOVOFABRIC does not use personal data for mass marketing purposes or for sending unsolicited commercial communications.

 

6. Data retention

 

Personal data will be retained only for the period strictly necessary to fulfil the purposes for which it was collected and thereafter for the periods required under applicable law.

 

As a general rule, data relating to professional relationships will be retained for the duration of such relationship and, once terminated, for the applicable statutory limitation periods. Technical data will be retained solely for the time required to ensure the security and proper functioning of the Platform. Upon expiry of these periods, the data will be securely deleted or anonymised.

 

Indicative retention periods:

 

• Enquiry/contact data: up to [12–24] months from last interaction.

 

• Account and contract-related data: for the duration of the relationship and thereafter for the periods required by applicable commercial and tax laws.

 

• Security logs: up to [6–12] months unless a longer retention is required to investigate incidents or comply with legal obligations.

 

7. Data recipients

 

Personal data may be disclosed only to technology or professional service providers acting as data processors and whose involvement is necessary for the operation of the Platform, as well as to public authorities, courts or tribunals where disclosure is required by law. In the future, data may be disclosed to payment or logistics service providers where necessary for the execution of specific operations, subject in all cases to the appropriate legal safeguards. NOVOFABRIC does not sell or commercially disclose personal data to third parties.

 

Recipients may include IT hosting providers, cloud infrastructure providers, customer support tools, email/communication services, payment service providers (when enabled), logistics partners (where applicable) and professional advisors (legal/accounting), strictly as necessary.

 

8. International data transfers

 

As a general principle, personal data is processed within the territory of the European Union. Where, exceptionally, a service provider is located outside the European Economic Area, NOVOFABRIC will ensure that international data transfers are carried out in accordance with the safeguards required by applicable law, including the use of standard contractual clauses or other legally recognised mechanisms.

 

9. User rights

 

The user may exercise at any time the rights of access, rectification, erasure, restriction of processing, objection and data portability, in accordance with applicable legislation. To exercise these rights, the user may contact NOVOFABRIC through the designated contact channels, providing proof of identity where required. The user also has the right to lodge a complaint with the Spanish Data Protection Authority or with any other competent supervisory authority.

 

10. Data security

 

NOVOFABRIC implements appropriate technical and organisational measures to ensure a level of security appropriate to the risks associated with the processing of personal data, with a view to protecting such data against unauthorised access, loss, alteration or unlawful disclosure. Nevertheless, the user acknowledges that the use of the Internet involves inherent risks that cannot be entirely eliminated.

 

11. Data relating to minors

 

The Platform is not intended for use by minors, and NOVOFABRIC does not knowingly collect personal data relating to minors. Should the processing of personal data relating to a minor be detected, such data will be promptly deleted.

 

12. Third-party links

 

The Platform may contain links to third-party websites or services. NOVOFABRIC is not responsible for the processing of personal data carried out by such third parties or for their privacy policies, and the user is responsible for reviewing the relevant information.

 

13. Amendments to the Policy

 

NOVOFABRIC reserves the right to amend this Policy where required by legal, technical or operational changes. The version in force shall at all times be the version published on the Platform.

 

14. Contact

 

For any questions or requests relating to this Policy, please contact NOVOFABRIC at [privacy@…].