NovaCore Governance Privacy Policy
NovaCore Governance is committed to protecting privacy and handling personal information with care, transparency, and respect. This page explains how personal information may be collected, used, stored, shared, and protected when you use NovaCore’s website, submit an enquiry, access resources, or engage with our services.
Effective Date: January 10th, 2026
Last Updated: March 26th, 2026
Introduction
NovaCore International Governance Ltd (“NovaCore,” “we,” “us,” or “our”) is committed to protecting your
privacy and handling your personal information with care and respect.
This Privacy Policy explains how we collect, use, disclose, store, and protect your personal information when
you:
Our Commitment: We process personal information in accordance with applicable data protection laws,
including the Abu Dhabi Global Market (ADGM) Data Protection Regulations 2021, the EU General Data
Protection Regulation (GDPR) where applicable, and other relevant privacy laws.
By using our website or services, you acknowledge that you have read and understood this Privacy Policy.
1. Information We Collect
We collect personal information in several ways:
1.1 Information You Provide Directly
When you interact with NovaCore, you may voluntarily provide:
Contact Information:
Inquiry and Communication Information:
Engagement Information (for clients):
Event and Meeting Information:
1.2 Information Collected Automatically
When you visit our website, we automatically collect certain technical information:
Device and Browser Information:
Usage Information:
Cookies and Tracking Technologies:
For more information, see Section 8: Cookies and Tracking Technologies
1.3 Information from Third-Party Sources
We may receive information about you from:
2. How We Use Your Information
We use your personal information for the following purposes:
2.1 To Provide Services and Respond to Inquiries
2.2 To Improve Our Website and Services
2.3 To Communicate with You
2.4 To Comply with Legal Obligations
2.5 For Business Operations
2.6 For Marketing and Business Development (with consent)
You can opt out of marketing communications at any time (see Section 10: Your Privacy Rights).
3. Legal Basis for Processing Personal Information
Under applicable data protection laws (including GDPR and ADGM Data Protection Regulations), we process
your personal information based on the following legal grounds:
3.1 Consent
You have given explicit, informed consent for us to process your personal information for specific purposes,
such as:
You can withdraw consent at any time without affecting the lawfulness of processing based on consent
before withdrawal.
3.2 Contractual Necessity
Processing is necessary to:
3.3 Legitimate Interests
We process personal information based on our legitimate business interests, such as:
We balance our legitimate interests against your privacy rights and will not process your information if your
rights override our interests.
3.4 Legal Obligation
Processing is necessary to comply with:
4. How We Share Your Information
We do not sell, rent, or trade your personal information to third parties for their marketing purposes.
We may share your personal information in the following circumstances:
4.1 Service Providers and Business Partners
We engage trusted third-party service providers to support our operations, including:
Technology and Infrastructure:
Professional Services:
Marketing and Communications:
All service providers are contractually bound to:
4.2 Legal and Regulatory Authorities
We may disclose personal information to:
When required by law or when necessary to:
4.3 Business Transfers
If NovaCore is involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy:
4.4 With Your Consent
We may share your information with third parties when you have given explicit consent, such as:
4.5 Aggregated or Anonymized Data
We may share aggregated, anonymized, or de-identified data that cannot reasonably identify you:
5. International Data Transfers
NovaCore operates from the Abu Dhabi Global Market (ADGM) and may transfer personal information to
countries outside the UAE, including:
Data Protection Safeguards:
When transferring personal information internationally, we ensure appropriate safeguards are in place:
For transfers to countries with adequate data protection:
For transfers to other countries:
Your Rights: You may request information about international transfers and obtain copies of relevant
safeguards by contacting us (see Section 13: Contact Information).
6. Data Retention
We retain personal information only for as long as necessary to fulfill the purposes outlined in this Privacy
Policy, unless a longer retention period is required or permitted by law.
6.1 Retention Periods
Inquiry and Contact Information:
Client Information:
Website Usage Data:
Legal and Compliance Records:
6.2 Deletion and Anonymization
When retention periods expire:
7. Data Security
We implement appropriate technical and organizational measures to protect your personal information
against unauthorized access, loss, destruction, alteration, or disclosure.
7.1 Security Measures
Technical Safeguards:
Organizational Safeguards:
Physical Safeguards:
7.2 Your Responsibility
You are responsible for:
7.3 Limitation
No system is 100% secure. While we implement robust security measures, we cannot guarantee absolute
security. You provide information at your own risk.
If we become aware of a data breach that affects your personal information, we will notify you and relevant
authorities as required by applicable law.
8. Cookies and Tracking Technologies
Our website uses cookies and similar tracking technologies to enhance your experience, analyze usage, and
improve our services.
8.1 What Are Cookies?
Cookies are small text files stored on your device when you visit a website. They help websites remember your
preferences, recognize you on return visits, and analyze how you use the site.
8.2 Types of Cookies We Use
Essential Cookies (Strictly Necessary):
Performance and Analytics Cookies:
Functional Cookies:
Marketing and Advertising Cookies (with consent):
8.3 Third-Party Cookies
We may use third-party services that set cookies on our website:
Third-party cookies are governed by the respective third parties’ privacy policies.
8.4 Cookie Duration
Session Cookies:
Persistent Cookies:
8.5 Managing Cookies
You have control over cookies:
Browser Settings:
Cookie Consent Tool:
Opt-Out Tools:
Note: Disabling certain cookies may affect website functionality and your user experience.
9. Third-Party Websites and Links
Our website may contain links to third-party websites, resources, or services that are not operated by
NovaCore.
We are not responsible for:
Your responsibility:
Links do not imply endorsement: The presence of links on our website does not constitute endorsement,
approval, or recommendation of third-party sites or services.
10. Your Privacy Rights
Depending on your location and applicable laws, you may have the following rights regarding your personal
information:
10.1 Right of Access
You have the right to:
How to exercise: Submit a request to [privacy.manage@novacoregovernance.com] with “Data Access
Request” in the subject line.
10.2 Right to Rectification
You have the right to:
How to exercise: Contact us at privacy.manage@novacoregovernance.com with “Data Correction Request” in the subject line and specify the information requiring correction
10.3 Right to Erasure (Right to be Forgotten)
You have the right to request deletion of your personal information when:
Limitations: We may retain information when necessary to:
How to exercise: Submit a request to privacy.manage@novacoregovernance.com with “Data Deletion Request” in the subject line.
10.4 Right to Restriction of Processing
You have the right to request that we limit how we use your personal information when:
Effect of restriction: We will store the information but not use it further (except with your consent, for legal
claims, or to protect others’ rights).
How to exercise: Contact us at privacy.manage@novacoregovernance.com with “Restriction Request” in the subject line.
10.5 Right to Data Portability
You have the right to:
Applies when:
How to exercise: Submit a request to privacy.manage@novacoregovernance.com with “Data Portability Request” in the subject line.
10.6 Right to Object
You have the right to object to processing of your personal information when:
Direct Marketing: You can object to marketing communications at any time by:
Other Processing: We will stop processing unless we demonstrate compelling legitimate grounds that
override your interests, rights, and freedoms, or the processing is necessary for legal claims.
How to exercise: Contact us at privacy.manage@novacoregovernance.com with “Objection to Processing” in the subject line.
10.7 Right to Withdraw Consent
When processing is based on your consent, you have the right to:
Effect of withdrawal:
How to exercise:
10.8 Right to Lodge a Complaint
You have the right to lodge a complaint with a supervisory authority if you believe we have violated your privacy
rights.
ADGM (Abu Dhabi Global Market): Office of Data Protection Abu Dhabi Global Market
Email:
dataprotection@adgm.com
Website: www.adgm.com
European Union (if GDPR applies): Contact your local data protection authority:
https://edpb.europa.eu/about-edpb/board/members_en
United Kingdom (if UK GDPR applies): Information Commissioner’s Office (ICO)
Website: www.ico.org.uk
Helpline: 0303 123 1113
10.9 Exercising Your Rights
To exercise any of these rights:
1. Submit a written request to privacy.manage@novacoregovernance.com
2. Include the following information:
Our Response:
Verification: To protect your privacy, we may ask for additional information to verify your identity before
responding to requests.
11. Children's Privacy
NovaCore’s services are intended for businesses and professionals. Our website and services are not
directed at children under the age of 18 (or the age of majority in your jurisdiction).
We do not knowingly collect personal information from children.
If you are a parent or guardian and believe we have collected information from a child:
Age Verification: By using our website or services, you represent that you are at least 18 years old or the age
of majority in your jurisdiction.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect:
How We Notify You:
Material Changes:
Non-Material Changes:
Your Responsibility:
Previous Versions: We maintain archived versions of previous privacy policies. Contact us at
privacy.manage@novacoregovernance.com to request a copy.
13. Additional Information for Specific Jurisdictions
Depending on your location, additional privacy rights or disclosures may apply:
Data Protection Officer : legal.manage@novacoreintlgovern.com
13.1 European Union and European Economic Area (EEA)
Legal Basis for Processing: See Section 3 for detailed legal bases.
Data Controller: NovaCore International Governance Ltd is the data controller responsible for your personal
information.
EU Representative: legal.manage@novacoreintlgovern.com
Your Rights: See Section 10 for comprehensive rights under GDPR.
Data Transfers: See Section 5 for information about transfers outside the EU/EEA.
Supervisory Authority: You have the right to lodge a complaint with your local data protection authority.
13.2 United Kingdom
If you are located in the UK, the UK GDPR and Data Protection Act 2018 apply.
Data Controller: NovaCore International Governance Ltd
UK Representative: legal.manage@novacoreintlgovern.com
Your Rights: See Section 10 for comprehensive rights under UK GDPR.
Supervisory Authority: Information Commissioner’s Office (ICO)
Website: www.ico.org.uk
13.3 United States (California)
If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act
(CPRA) provide additional rights:
Right to Know: You have the right to request disclosure of:
Right to Delete: You have the right to request deletion of personal information (subject to exceptions).
Right to Opt-Out of Sale: We do not sell personal information as defined by CCPA.
Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.
Authorized Agent: You may designate an authorized agent to submit requests on your behalf. We will verify
the agent’s authority.
How to Exercise Rights: Contact us at privacy.manage@novacoregovernance.com with “CCPA Request” in the subject line.
Verification: We will verify your identity using information you previously provided to us.
Response Time: We will respond within 45 days (extendable by an additional 45 days for complex requests)
13.4 United Arab Emirates and ADGM
NovaCore operates from the Abu Dhabi Global Market (ADGM), which has its own data protection framework.
Applicable Law: ADGM Data Protection Regulations 2021 (based on GDPR principles)
Supervisory Authority: ADGM Office of Data Protection
Email: dataprotection@adgm.com
Website: www.adgm.com
Your Rights: See Section 10 for rights under ADGM Data Protection Regulations.
Cross-Border Transfers: ADGM recognizes certain jurisdictions as providing adequate data protection,
including the EU/EEA.
13.5 Other Jurisdictions
If you are located in other jurisdictions with specific data protection laws (Australia, Canada, Singapore, etc.),
we will comply with applicable local requirements.
Contact us at privacy.manage@novacoregovernance.com for jurisdiction-specific information.
14. Automated Decision-Making and Profiling
NovaCore does not engage in automated decision-making or profiling that produces legal effects or
similarly significantly affects you.
What This Means:
Analytics and Website Usage: We use analytics tools to understand website usage patterns, but this does
not constitute profiling that affects your rights.
If our practices change, we will update this Privacy Policy and notify you as required by law.
15. Do Not Track Signals
Some browsers offer a “Do Not Track” (DNT) signal that requests websites not to track your browsing activity
Current Position: There is no industry consensus on how to respond to DNT signals. Our website does not
currently respond to DNT signals.
Your Options:
16. Business Transfers and Corporate Changes
In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or part of our assets:
Your Information May Be Transferred:
We Will Notify You:
Your Rights:
17. Data Minimization and Purpose Limitation
We are committed to data protection principles:
Data Minimization:
Purpose Limitation:
Storage Limitation:
Accuracy:
18. Security Incident Response
In the unlikely event of a data breach or security incident:
Our Response:
Notification:
To You:
To Authorities:
Your Actions:
19. Consent Management
When we process your personal information based on consent:
How We Obtain Consent:
What You Consent To:
Records of Consent:
Withdrawing Consent:
Renewal of Consent:
20. Your California Privacy Rights (Shine the Light Law)
If you are a California resident, California Civil Code Section 1798.83 permits you to request information about disclosure of personal information to third parties for direct marketing purposes.
We do not share personal information with third parties for their direct marketing purposes without your
consent.
If you have questions, contact us at privacy.manage@novacoregovernance.com with “California Shine the
Light Request” in the subject line.
21. Accessibility
We are committed to making this Privacy Policy accessible to all individuals, including those with disabilities.
Accessibility Features:
If You Need Assistance:
If you have difficulty accessing or understanding this Privacy Policy due to a disability:
Commitment: We continuously work to improve accessibility and welcome feedback on how we can better
serve individuals with disabilities.
22. Privacy by Design
NovaCore incorporates privacy protection into all aspects of our operations:
Privacy by Design Principles:
Proactive, Not Reactive:
Privacy as Default:
Privacy Embedded into Design:
Full Functionality:
End-to-End Security:
Visibility and Transparency:
User-Centric:
23. Data Protection Impact Assessments
For high-risk processing activities, we conduct Data Protection Impact Assessments (DPIAs) to:
Identify Risks:
Implement Safeguards:
Document and Review:
Consult When Required:
24. Employee and Contractor Privacy
This Privacy Policy primarily addresses information about clients, website visitors, and business contacts.
Employee and Contractor Information:
If you are a NovaCore employee or contractor:
Employee Training:
25. Governance and Oversight
Privacy Governance Structure:
Data Protection Officer (DPO):
Responsibilities:
Privacy Committee:
Regular Audits:
26. Vendor and Third-Party Management
We carefully select and manage service providers who process personal information on our behalf:
Due Diligence:
Contractual Requirements:
Ongoing Monitoring:
Sub-Processors:
27. Research and Analytics
We may use personal information for research, analysis, and statistical purposes:
Purposes:
Safeguards:
Publication:
Your Rights:
28. Marketing Communications Preferences
What We Send:
With your consent, we may send:
How We Obtain Consent:
Frequency:
Managing Preferences:
Unsubscribe:
Update Preferences:
Contact Us:
Note: Unsubscribing from marketing does not affect:
29. Cross-Border Data Flows
NovaCore operates internationally and may transfer personal information across borders:
Transfers from ADGM:
Transfers to ADGM:
Legal Mechanisms:
Your Rights:
30. Record Keeping and Documentation
We maintain comprehensive records of our data processing activities:
Records of Processing Activities:
Consent Records:
Data Subject Requests:
Data Breaches:
Availability:
31. Complaints and Dispute Resolution
If you have concerns about our privacy practices:
Step 1: Contact Us Directly
Step 2: Escalation Within NovaCore
Step 3: Supervisory Authority
Step 4: Legal Remedies
Alternative Dispute Resolution:
32. Language and Interpretation
Primary Language: This Privacy Policy is written in English. English is the governing language for
interpretation.
Translations: We may provide translations in other languages for convenience. If there is any conflict between
the English version and a translation, the English version prevails.
Legal Effect: This Privacy Policy, together with our Terms of Use, constitutes the complete agreement
regarding privacy practices.
Severability: If any provision is found invalid or unenforceable, the remaining provisions continue in full effect.
33. Definitions
To help you understand this Privacy Policy, here are definitions of key terms:
Personal Information/Personal Data: Information that identifies or can be used to identify an individual,
including name, email, phone number, IP address, and other identifiers.
Processing: Any operation performed on personal information, including collection, storage, use, disclosure,
transfer, and deletion.
Data Controller: The entity that determines the purposes and means of processing personal information.
NovaCore is the data controller for information we collect.
Data Processor: An entity that processes personal information on behalf of a data controller (e.g., our service
providers)
Data Subject: The individual to whom personal information relates (you).
Consent: Freely given, specific, informed, and unambiguous indication of agreement to processing of
personal information.
Supervisory Authority: A government body responsible for enforcing data protection laws (e.g., ADGM Office of Data Protection, ICO, data protection authorities).
ADGM: Abu Dhabi Global Market, a financial free zone in Abu Dhabi, UAE, with its own regulatory framework.
GDPR: General Data Protection Regulation (EU) 2016/679, the European Union’s data protection law.
CCPA: California Consumer Privacy Act, California’s data protection law.
Cookies: Small text files stored on your device by websites you visit.
Anonymization: Process of removing or altering information so that individuals cannot be identified.
Pseudonymization: Process of replacing identifiers with pseudonyms, allowing data to be linked back to
individuals with additional information.
34. Effective Date and Version Control
Current Version: 1.0 Effective
Date: January 10th, 2026
Last Updated: March 26th, 2026
Next Scheduled Review: March 26th, 2027
Version History:
Review Schedule: We review this Privacy Policy at least annually and update as necessary to reflect:
Archived Versions: Previous versions are maintained for record-keeping. Contact privacy.manage@novacoreintlgovern.com to request archived versions.
35. Acknowledgment and Acceptance
By using our website, submitting inquiries, or engaging our services, you acknowledge that:
If you do not agree with this Privacy Policy, please do not use our website or provide us with personal
information.
36. Additional Resources
Related Documents:
External Resources:
Privacy Tools:
37. Contact Us
For any questions, concerns, or requests regarding this Privacy Policy or our privacy practices:
NovaCore International Governance Ltd
Privacy Inquiries:
Email: privacy.manage@novacoregovernance.com
Subject Line: Privacy Inquiry
General Contact:
Email: enquiries.manage@novacoreintlgovern.com
Phone: +971 (0)4 879 0700
Postal Address: NovaCore International Governance Ltd, Abu Dhabi Global Market (ADGM), Al Maryah Island Abu Dhabi, United Arab Emirates
Office Hours: Sunday to Thursday, 9:00 AM to 5:00 PM GST
Response Time: We will respond to privacy inquiries within 2 business days and substantive requests within
30 days (or as required by applicable law).
This Privacy Policy was last updated on March 26th, 2026.