Privacy Notice

This privacy notice for ALTNOVEL Capital Ltd ("AltNovel Service," "We," "Us," or "Our"), which consists of the website altnovel.co and various AltNovel-branded Android and iOS applications, describes how and why we might collect, store, use and/or share ("Process") your information when you use our services ("Services"). The AltNovel Service is operated and maintained by ALTNOVEL, a company duly organised and existing under the laws of ADGM, with company registration number 143278-1, and authorised and regulated by the FSRA (ADGM), FSP 220164.

Reading this privacy policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at admin@altnovel.co.

This Privacy Policy (the "Policy"), together with our terms of use and any other documents referred to in it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. The Policy covers the following areas:

• What personal data we collect about you
• How we collect your personal data
• Use of information
• Disclosure of information
• Where your personal data may be transferred
• Security of personal data
• How long we keep personal data
• Your information and rights
• How you can exercise your rights
• Our use of cookies

Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it. By visiting the AltNovel Service, you are accepting and consenting to the practices described in this Policy.

Personal data is any information relating to natural persons who can be identified, directly or indirectly. We may collect, use, store and transfer the following types of personal data:

• Identity Data: first and last names, date of birth, gender.
• Contact Details: email address, telephone number, screen names and correspondence details.
• Other User Data: registration, username, password, password reminder, search queries, information about interests, submissions, voting and polling activities and other information relating to User Accounts (as defined in the Terms of Use).
• Technology used to access the AltNovel Service: device information, browser information, internet service provider or mobile carrier, referring and exit pages, date and time stamps, clickstream data (including page clicks and scrolls), location, bandwidth speed, software and registry keys, and IP address and device ID.
• Payment details: first six digits of Credit card, expiry date of Credit card. When payment is processed via a 3rd party (e.g. Visa, MasterCard, PayPal), all details are passed directly to the 3rd party.
• Consent records: records of any consents you have given, together with the date and time, means of consent and any related information.
• Marketing and Communication Data: user's preferences in relation to receiving information about our websites.
• Views and opinions: any views and opinions that you choose to send to us, or publicly post about us on social media platforms.
• Digital Data: user's social media accounts, metadata, online identifiers (e.g., internet protocol addresses, cookie identifiers) and other information collected when you visit our websites or Apps.

In addition to collecting personal data directly from users of the AltNovel Service, we also collect personal data from third-party service providers we work with ("Service Providers"), which include:

• Payment processors
• Fraud and credit risk service screening providers
• Advertising partners (including advertising technology)
• Analytics and data service providers
• IT providers
• Accountants, lawyers and other professional service providers

We receive information from Service Providers as necessary to enable them to provide their services to us. The personal data we receive from Service Providers includes information processed for the following purposes:

• to secure our systems;
• to determine location based on your IP address in order to customize our service and prevent fraud;
• to determine payment or balance information, or updates to that information, based on the Service Provider's relationship with you;
• to obtain aggregated demographic, interest-based and online activity data for advertising and analysis purposes; and
• for Service activation purposes.

We collect data in a variety of ways, including:

• Registration details: when you use, or register to use, the AltNovel Service.
• Data you have provided to us: through the AltNovel Service or where you contact us via email, telephone, chat or any other means.
• Relationship data: in the ordinary course of our relationship with you.
• App data: when you download the AltNovel Apps and when launched or used.
• Site data: when you visit the AltNovel website or use any features or resources available on or through the website.
• Data you make public: data that you manifestly choose to make public, including via social media.
• Third-party information: from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities).

We use information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to process your registration, your commitments and your payments, and to communicate with you on these and other topics. For example, we use such information to:

• tailor the AltNovel Service to your needs and interests;
• determine your general geographic location (such as city, state/province, and postal code);
• determine your ISP to support network troubleshooting (we also use aggregated ISP information for operational and business purposes);
• help us quickly and efficiently respond to inquiries and requests;
• coordinate with partners and other third parties on making the AltNovel Service available to users;
• secure our systems, prevent fraud and help us protect the security of AltNovel Service accounts;
• prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and enforce our terms;
• analyze and understand our users and improve our service (including user-interface experiences and service performance);
• communicate with you concerning our service, including news about AltNovel, details about new features, by email, push notification, text message, online messaging channels, and matched identifier communications;
• perform a task in the public interest that has a clear basis in law.

In certain circumstances, it may be necessary to use your personal information for complying with applicable laws or regulations, in response to lawful requests for information from the government or through legal process; fulfilling any other purpose disclosed to you in connection with our services; or contacting you to resolve disputes and provide assistance with our services.

We disclose your information for certain purposes and to third parties as described below:

• To related companies and affiliates of AltNovel: we share your information among companies that are affiliates of AltNovel, as needed for providing access to our Services, customer support, decisions about service improvements, and for other purposes described in the Use of Information section of this Policy. We share only on a need-to-know basis, under strict contractual confidentiality obligations.
• Suppliers and Service Providers: we use other companies, agents, contractors or suppliers to perform services on our behalf or to assist us with the provision of services to you, including marketing, advertising, communications, security, infrastructure and IT services, payment processing, customer service, analytics, and consumer-survey administration. We do not authorise them to use or disclose your personal information except in connection with providing their services.
• Promotional offers: we may offer joint promotions or programs that require sharing your information with third parties. Please note that those third parties are responsible for their own privacy practices.
• Protection of AltNovel and our affiliates: we may disclose your information where we reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request; (b) enforce applicable terms of use; (c) detect, prevent or address illegal or suspected illegal activities, security or technical issues; or (d) protect against harm to the rights, property or safety of the AltNovel Service, its users or the public.
• Business purposes: in connection with any reorganisation, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided the receiving party agrees to respect your personal information in a manner consistent with this Policy.

Whenever we transfer personal information to other countries, we will ensure the information is transferred in accordance with this Policy and as permitted by applicable laws on data protection.

Because of the international nature of our business, we may transfer personal data to related affiliates of AltNovel and to third parties as noted above, in connection with the purposes set out in this Policy. We therefore transfer personal data to other countries that may have different laws and data-protection compliance requirements to those that apply in the country in which you are located.

Where this is the case, we will take steps to ensure that your personal data receives an adequate level of protection. These procedures include ensuring that all such entities keep your personal information confidential and secure and only use it for the purposes we have specified. We conduct due diligence on our partners and ensure that any data storage centres we use to store your personal data employ best-practice data-protection technologies.

Please note that when you transfer any personal data directly to AltNovel or any of its related affiliates, we are not responsible for that transfer. We will nevertheless process your personal data, from the point at which we receive it, in accordance with the provisions of this Policy.

We have implemented appropriate technical and organisational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of processing. The data you provide is protected using SSL (Secure Socket Layer) technology, the industry standard method of encrypting personal information so that it can be securely transferred over the Internet.

All payment details are transmitted over SSL and processed and stored in compliance with Payment Card Industry Data Security Standards (PCI DSS). We require all third parties we work with to have appropriate technical and operational security measures in place to protect your personal data.

Please note that no data transmission over the Internet or website can be guaranteed to be secure from intrusion. You should also take appropriate measures to safeguard your personal data, particularly by keeping your password secure and confidential. If you know or have reason to believe that your account credentials have been lost, stolen, misappropriated or otherwise compromised, please contact us. If we know or have reason to believe that your personal data has been compromised, we will notify affected users in accordance with applicable laws.

We will only retain your personal data for the period necessary to fulfil the purposes described in this Policy. The criteria for determining the duration for which we will retain your personal data are:

• for as long as we maintain an ongoing relationship with you;
• for as long as your personal data is necessary in connection with the purposes set out in this Policy, for which we have a valid legal basis;
• any applicable limitation period under applicable law;
• if any relevant legal claims are brought, we continue to process personal data for such additional periods as are necessary in connection with that claim.

Your personal data collected through our website and apps will be retained as long as your account is active or otherwise for as long as is necessary for the purpose for which we initially collected it. Personal data that is no longer needed is either permanently deleted or anonymized.

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18, or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at admin@altnovel.co.

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data, or at any time by contacting us at admin@altnovel.co.

Our site may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for those policies. Please check them before submitting any personal data.

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

• request information about whether we hold personal information about you, and, if so, what that information is and why we are holding or using it;
• request access to your personal information (commonly known as a data subject access request);
• request correction of the personal information we hold about you;
• request erasure of your personal information where there is no good reason for us continuing to process it;
• object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) or where we are processing for direct marketing;
• object to automated decision-making, including profiling;
• request the restriction of processing of your personal information;
• request transfer of your personal information in an electronic and structured form to you or another party (data portability);
• withdraw consent for any specific processing for which you previously provided consent.

If you wish to exercise your rights, please contact us using the details provided in "How to contact us" below.

Please note that:

• We may need to verify your identity before we can act on your request. As a security measure, we may also contact you to ask for further information in relation to your request.
• The exercise of these rights is subject to certain legal conditions and limitations. We may have to decline your request if those conditions are not fulfilled or if legal limitations apply.
• Requests that are unreasonably repetitive, require disproportionate technical effort, or create a risk on the privacy of others may be rejected.
• You will not have to pay a fee to exercise any of these rights. We may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.

In any case, we will seek to deal promptly with your request, and in any event within one month (subject to any extensions to which we are lawfully entitled). If we refuse your request, we will tell you the reasons for doing so.

The AltNovel Service uses cookies to distinguish you from other users of the AltNovel Service. This helps us to provide you with a good experience when you browse and allows us to improve our service. This may include cookies of media and advertising partners that are placed on your machine when visiting the AltNovel Service. Please visit our partners' websites for information on their privacy and cookie policy.

Cookies are small text files that are transferred to your computer's hard drive through your web browser to enable us to recognise your browser and help us track visitors to our site. Most web browsers automatically accept cookies, but if you wish, you can change these browser settings by accepting, rejecting and deleting cookies. The "help" portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. If you choose to change these settings, certain functions and features may not work as intended.

For more information about cookies and how to stop cookies being installed, visit allaboutcookies.org.

We may send targeted marketing communications, which could include SMS, push notifications, emails and phone communication (collectively, "Marketing Notifications"), in relation to new product services, features or services we may be launching shortly on AltNovel, or marketing activities such as newsletters.

If you would like to opt out of these Marketing Communications, follow the "unsubscribe" instructions in the communication when received. To stop receiving push notifications, turn off push on your mobile device. Please note that unsubscribing may not remove you from general communications required to administer your account with AltNovel.

Consequently, if you opt out of Marketing Communications, you may miss out on information about new features, promotions, offers and other benefits that may be of interest.

If you visit one of our sites, it may link you to other unaffiliated third-party websites. Please note that AltNovel is not, and cannot, control or be responsible for the content or privacy and confidentiality practices of any third-party websites. We do not endorse or make any representations about third-party websites. This Policy does not cover the personal data you choose to give to unrelated third parties. You must always carefully review the privacy and confidentiality policy of any third-party website that you may visit.

If you have any questions or want to exercise any of these rights, please email us at admin@altnovel.co.

Your use of the AltNovel Service, and any disputes arising from it, is subject to this Policy and all of its dispute-resolution provisions including arbitration, limitation on damages and choice of law. We reserve the right to change our Policy at any time. Non-material changes and clarifications will take effect immediately, and material changes will take effect within thirty (30) days of their posting on this site. If we make changes, we will post them and will indicate at the top of this page the Policy's new effective date. If we make material changes to this Policy, we will notify you here, by email, or through a notice on our home page. We encourage you to refer to this Policy on an ongoing basis. Unless stated otherwise, our current Policy applies to all information that we have about you and your account.