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Privacy Policy

Effective as of January 10, 2026

Introduction

This Privacy Policy explains how Novel Group (“Company,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information of users of our website novelgroup.us (the “Website”). We are a luxury real estate firm operating in the USA, and we are committed to protecting your privacy. This policy applies to all visitors, clients, and any other individuals (“you” or “your”) who use our Website or services. It is designed to comply with applicable privacy laws, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), as amended. By using our Website, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please refrain from using the Website.

Information We Collect

We collect personal information that you provide to us directly, information collected automatically through technology, and information from third parties as needed. The types of personal data we may collect now or in the future include:

  • Contact and Identity Information: Name, email address, telephone number, postal address, and other identifiers you provide (for example, when filling out our contact forms, registering for an account, signing up for newsletters, or scheduling an online consultation).
  • Property and Preference Information: Details you provide related to your real estate needs or preferences, such as property type, budget, location interests, and any information you submit when requesting information about buying, selling, or building a home.
  • Contact and Identity Information: Name, email address, telephone number, postal address, and other identifiers you provide (for example, when filling out our contact forms, registering for an account, signing up for newsletters, or scheduling an online consultation).
  • Transactional Information: Records of communications and transactions with us, including inquiries, consultation appointments, contracts or agreements if you engage our services, and any payment information if relevant (note: we typically handle financial transactions offline, but if any online payment processing is enabled in future, appropriate data will be collected securely).
  • Device and Technical Data: When you visit the Website, we automatically collect certain information from your device or browser. This includes your IP address, browser type and version, device identifiers, operating system, referral source, and other technical information. We may also log information about your interaction with the Website (e.g., timestamps, errors, and performance data).
  • Cookies and Tracking Data: We use cookies and similar tracking technologies (such as web beacons, pixels, and local storage) to collect information about your browsing activities and preferences. For example, we utilize Google Analytics  and Microsoft Clarity to gather statistical information on site usage, and may use the Facebook Pixel for advertising and retargeting purposes.  These tools may collect data such as your IP address, approximate location, and interactions with our ads or content. Please see our Cookie Policy section for detailed information on our use of cookies and how you can control them.
  • CRM and Communications Data: If you correspond with us (via email, phone, or through the Website), we will collect and retain those communications. We use a custom Customer Relationship Management (CRM) system to securely store contact details, inquiry history, and notes about our interactions with you. This helps us manage our relationships with current and prospective clients.
  • Third-Party Sources: On occasion, we might receive personal information about you from third-party sources. For example, if you engage with our social media pages or advertising campaigns, or if a third-party real estate marketplace or referral partner provides us your details with your consent. We treat any such information in accordance with this Privacy Policy.

We do not intentionally collect any sensitive personal information (such as Social Security Numbers, financial account numbers, or precise geolocation) through our Website at this time. We ask that you refrain from submitting any sensitive data via our online forms. If in the future we decide to collect any sensitive personal data, we will do so in compliance with applicable laws and with appropriate notices and consent mechanisms.

How We Use Your Information

We use the collected personal information for the following business and commercial purposes:

  • Providing and Improving Services: To respond to your inquiries, provide information you request about our luxury homes or services, facilitate real estate transactions (such as initiating the process of buying, selling, or building a home), and to generally operate and maintain our services. For example, if you ask about a property, we will use your contact information to provide details or schedule a consultation.
  • Customer Relationship Management: To manage our relationship with you as a current or prospective client. Your information is entered into our CRM system so we can keep track of communications, tailor our services to your needs, and follow up appropriately.
  • Contact and Identity Information: Name, email address, telephone number, postal address, and other identifiers you provide (for example, when filling out our contact forms, registering for an account, signing up for newsletters, or scheduling an online consultation).
  • Marketing and Newsletters: To send you promotional communications. If you sign up for our newsletter or provide your email to receive updates, we will use your contact information to send you newsletters, market reports, information about new listings, open houses, or other updates about our services. You can opt out of marketing emails at any time (see “Your Rights and Choices” below). We will only send you marketing communications in accordance with applicable law (for example, with your consent where required).
  • Analytics and Improvement: To analyze usage of our Website and services. We use data (including via cookies and Google Analytics) to understand how users interact with the site, which pages or properties are most interesting, and to identify areas for improvement. This helps us enhance the Website’s design, content, and functionality. We may also use aggregated and de-identified data for statistical analysis.
  • Advertising and Retargeting: To serve and measure online advertisements. We may use third-party advertising networks (like Facebook or Google Ads) that employ cookies or pixels to deliver ads about our services on other websites you visit. For example, if you visit our site and view a particular property, the Facebook Pixel may later enable us to show you an advertisement for that property (or similar ones) on Facebook. These advertising activities, where they involve the use of your personal data, will be done in compliance with privacy laws, and you have choices as described in our Cookie Policy (e.g., you can opt out of targeted ads as outlined).
  • Online Consultations and Appointments: If our Website offers the ability to book consultations, appointments, or property viewings online, we will use the provided information (such as your name and preferred schedule) to arrange those services and communicate with you about them. This may include sending reminders or follow-ups about your appointments.
  • Legal and Security Purposes: To protect the rights, property, or safety of Novel Group, our clients, our Website, or the public. This includes using personal information to detect, prevent, or address fraud, security breaches, or other technical issues. We may also use data as necessary to comply with our legal obligations, such as maintaining records for compliance with real estate regulations, responding to lawful requests by public authorities, or to meet record-keeping and reporting requirements.
  • Enforcing Terms and Policies: To enforce our Terms and Conditions of Use (see Terms & Conditions) and other agreements, including investigation of potential violations.
  • Business Transfers: In the event of a potential or actual merger, acquisition, sale of assets, or other business transaction involving our company, personal information held by us may be among the transferred assets but will remain subject to the protections outlined in this Privacy Policy.

We will only use your personal information for the purposes described above or as otherwise disclosed to you at the time of collection. If we need to process your information for an unrelated new purpose, we will update our Privacy Policy and, if required by law, seek your consent.

Legal Bases for Processing (GDPR Compliance)

If you are located in the European Economic Area (EEA), United Kingdom, or another region with data protection laws requiring a legal basis for processing personal data, we process your personal information under the following legal bases:

  • Consent: We will rely on your consent where we are required to do so, for example for sending marketing emails or placing non-essential cookies on your device. Where consent is required, you have the right to withdraw it at any time (e.g., by unsubscribing from our emails or adjusting cookie preferences).
  • Performance of a Contract: When processing is necessary to perform a contract with you or to take steps at your request before entering into a contract. For instance, if you request real estate services, the processing of your personal data for communication and transaction purposes is based on contractual necessity.
  • Legitimate Interests: We may process your data for our legitimate business interests, provided such processing is not overridden by your data protection rights. For example, it is in our legitimate interest to understand how our customers use our Website (analytics), to secure our Website, to improve our services, to market to our existing clients, and to communicate with you regarding your inquiries. We will only rely on legitimate interests after assessing that our interests do not unfairly intrude on your privacy rights.
  • Legal Obligation: Where processing is necessary for us to comply with a legal obligation, such as maintaining transaction records for tax purposes or responding to official legal requests.

Disclosure of Your Information (How We Share Data)

We respect your privacy and will not sell your personal information to third parties. We only share your personal data in the following circumstances:

  • Within Our Organization: Personal information will be accessible to employees and personnel of Novel Group who need it to perform their job duties (for example, our sales team, customer service, or IT administrators), and who are bound by confidentiality obligations.
  • Service Providers and Processors: We share information with trusted third-party service providers who perform services on our behalf, under contract and according to this Privacy Policy. This includes:
    • IT and Hosting Providers: Companies that host our Website or database (ensuring your data is stored securely), cloud storage services, or providers of site functionality (such as a platform that powers our contact forms or scheduling system).
    • Analytics Providers: For example, we share certain site usage data with Google Analytics. Google acts as a service provider in analyzing our web traffic and is restricted from using the data for other purposes.
    • Advertising Partners: If we use third-party advertising networks (like Facebook Ads, Google Ads), we may share limited data (such as a hashed email address or pixel data) with these partners to better target and measure our campaigns. This sharing is typically done via cookies or pixels as described in our Cookie Policy.
    • Email Marketing and CRM Tools: We may use third-party platforms to send out newsletters or manage client relationships (for instance, a marketing email service or a cloud-based CRM software). These providers will process your contact information on our behalf for the purpose of sending communications or organizing our data.
    • Professional Advisors: We might disclose information to our accountants, auditors, lawyers, or insurers as necessary in the course of the professional services they render to us, and under a duty of confidentiality.
  • Business Partners (with Consent): If we collaborate with other companies or referral partners in the real estate industry (for example, a mortgage broker, an interior design firm, or a co-listing brokerage) and you explicitly request services that involve those partners or consent to us connecting you with them, we will share your information as needed to fulfill your request. We will only do this with your knowledge and/or consent (as appropriate under law).
  • Legal Obligation: Where processing is necessary for us to comply with a legal obligation, such as maintaining transaction records for tax purposes or responding to official legal requests.
  • Legal Requirements and Protection: We may disclose personal information when required to do so by law or in a good-faith belief that such action is necessary to (i) comply with a legal obligation, court order, or subpoena, (ii) respond to requests from government or law enforcement authorities, (iii) enforce our Terms and Conditions or other agreements, (iv) protect our rights, property, or safety, or that of our users, clients, or others, or (v) investigate and defend ourselves against any third-party claims or allegations.
  • Corporate Transactions: If we undergo a business transition, such as a merger, acquisition by another company, or sale of all or part of our assets, personal information held by Novel Group may be among the assets transferred to the buyer or successor entity. We will ensure that any such transfer is subject to appropriate privacy and security commitments. If such a change in ownership occurs, we will notify you via the Website or email of any significant changes to how your personal information is handled.

When we share your information with service providers or third parties, we require them to use your data only for the specific purposes we have contracted them for and to protect it in accordance with this Privacy Policy and applicable law. We do not allow our third-party processors to use your personal data for their own marketing or other purposes not authorized by us.

Cookies and Tracking Technologies

For information about how we use cookies and similar tracking technologies on our Website (such as for analytics and advertising), please see our detailed Cookie Policy. In summary, we and our third-party partners use cookies to make our Website function, to understand how you use it, and to serve personalized content or advertisements. Where required by law (e.g., in the EU), we will obtain your consent before using non-essential cookies. You have the ability to manage your cookie preferences at any time. Refer to the Cookie Policy section for more details on types of cookies and how to opt out.
 

Data Retention

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, unless a longer retention period is required or permitted by law. The exact duration will depend on the type of information and the reasons for processing it. For example:

  • Contact information and inquiries may be kept for a reasonable period in our CRM to track our communications and potential business relationship with you.
  • If you become a client (for instance, engage in a transaction with us), we will retain your information for the duration of our business relationship and thereafter as needed for record-keeping (e.g., real estate transaction records may be kept for several years to comply with legal and contractual obligations).
  • Marketing data (like your email for newsletters) will be retained until you unsubscribe or withdraw your consent, or the data becomes outdated. We will periodically clean our mailing lists to remove inactive contacts.
  • Analytics and cookie data is typically retained for a shorter period (for example, Google Analytics data may be kept for 14 months or as configured) or is stored in aggregate form.
  • Records related to consent (e.g., records of opt-ins or opt-outs) are retained as long as necessary to demonstrate our compliance with legal obligations.
  • When personal data is no longer needed for the purposes for which it was collected, we will delete, anonymize, or securely destroy it. If deletion is not immediately feasible (for example, because the data is stored in backup archives), we will ensure that the data is isolated and protected from further processing until deletion is possible.

Data Security

We take the security of your personal information seriously and implement reasonable security measures to protect it from unauthorized access, alteration, disclosure, or destruction. These measures include physical, technical, and organizational safeguards such as encrypted connections (our Website is served via HTTPS/TLS), firewalls and intrusion detection systems, access controls to limit access to personal data on a need-to-know basis, and regular monitoring of our systems for vulnerabilities. Our custom CRM system and any third-party services we use are also selected with security in mind and are required to uphold strong data protection standards.

However, please note that no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You share information with us at your own risk. It is also important for you to protect against unauthorized access to your account credentials and to your devices. If you believe that the security of your personal data has been compromised, please contact us immediately (see Contact Us).

International Data Transfers

Novel Group is based in the United States, and our Website is operated from the USA. If you are accessing our services from outside the United States (such as from the EEA or other regions), be aware that any information you provide will be transferred to and processed in the United States and possibly other jurisdictions where our service providers are located. These countries may have data protection laws that are different from (and potentially less protective than) the laws of your region.
For personal data collected from individuals in the EEA, UK, or Switzerland, we will ensure that appropriate safeguards are in place when transferring data internationally, as required by GDPR. This may include using European Commission-approved Standard Contractual Clauses (SCCs) or transferring data only to entities that have committed to compliance frameworks that ensure adequate protection (for example, companies certified under the EU-U.S. Data Privacy Framework, if applicable). In the absence of an adequacy decision or other safeguard, we may ask for your explicit consent to the cross-border transfer of your personal data.
By using our Website or providing us with information, you acknowledge that your information may be transferred to the United States and processed and stored there. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Your Rights and Choices

Your privacy rights will depend on your jurisdiction and applicable law. Novel Group is committed to respecting all applicable rights you have regarding your personal information. Below, we outline the rights of individuals under GDPR (for EU/EEA and UK users) and under the CCPA (for California residents). If you are a resident of another state or country, you may have similar rights under your local laws, and we will endeavor to honor those as required.

Rights of Individuals in the EEA/UK (GDPR)

If you are in the European Union, European Economic Area, or United Kingdom, you have the following rights under the GDPR (subject to certain exceptions and limitations):

  • Right to Be Informed: You have the right to be provided with clear, transparent information about how we use your personal data (this Privacy Policy aims to do that).
  • Right of Access: You can request confirmation of whether we are processing your personal data and, if so, request access to that data (commonly known as a “Data Subject Access Request”). We will provide a copy of the personal data we have about you, along with details on how it’s used, subject to some exceptions (for example, if providing the data would adversely affect the rights of others).
  • Right to Rectification: If any of your personal information we hold is incorrect or incomplete, you have the right to request that we correct or update it without undue delay. This includes updating your contact information or correcting any inaccuracies.
  • Right to Erasure: Also known as the “right to be forgotten,” you may ask us to delete or remove your personal data in certain circumstances – for example, if the data is no longer necessary for the purposes it was collected, or if you withdraw consent and no other legal basis for processing applies, or if you object to processing and we have no overriding legitimate grounds to continue. Please note that this right is not absolute; sometimes we may retain certain information as required by law or for legitimate business purposes (we will inform you if such an exception applies).
  • Right to Restrict Processing: You have the right to request that we suspend or limit the processing of your personal data in certain situations – for instance, if you contest the accuracy of the data, or if you want us to preserve data while you establish, exercise, or defend a legal claim.Right to Restrict Processing: You have the right to request that we suspend or limit the processing of your personal data in certain situations – for instance, if you contest the accuracy of the data, or if you want us to preserve data while you establish, exercise, or defend a legal claim.
  • Right to Object: You may object to our processing of your personal information when such processing is based on our legitimate interests, including profiling based on those interests. If you lodge an objection, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms, or unless needed for legal claims. You also have the absolute right to object to any processing of your data for direct marketing purposes – if you object, we will stop using your data for marketing immediately.
  • Right Not to Be Subject to Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects or similarly significant effects for you, unless it is necessary for entering into or performing a contract, based on your explicit consent, or otherwise authorized by law (and subject to certain safeguards). In practice, Novel Group does not engage in fully automated decision-making without human involvement in a way that has legal or significant effects on individuals.
  • Right to Withdraw Consent: If we rely on your consent as the legal basis for processing your personal data, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, and it will not affect processing of your personal data conducted in reliance on lawful processing grounds other than consent. For example, you can opt out of marketing emails by clicking the “unsubscribe” link in the email or by contacting us, and you can adjust your cookie preferences via our cookie management tool or your browser settings.
  • Right to Lodge a Complaint: If you believe we have infringed your privacy rights or violated data protection laws, you have the right to lodge a complaint with a supervisory data protection authority. If you are in the EEA, you can find your local authority’s contact details here: https://edpb.europa.eu/about-edpb/board/members_en. If you are in the UK, you can contact the Information Commissioner’s Office (ICO).

To exercise any of your GDPR rights, please contact us using the contact information provided at the end of this Privacy Policy. We may need to verify your identity before fulfilling your request (to ensure that we don’t disclose data to the wrong person). We will respond to your request within one month, or inform you if we need additional time or are permitted to decline your request due to an exemption.

Rights of California Residents (CCPA/CPRA)

If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

  • Right to Know: You have the right to request that we disclose to you the personal information we have collected about you in the 12-month period preceding your request. You can ask for the categories of personal information and specific pieces of personal information we have collected, as well as details about our information practices, including: the categories of sources of that information, the business or commercial purposes for collecting or selling/sharing that information, and the categories of third parties to whom we disclose personal information.
  • Right to Delete: You have the right to request that we delete any personal information about you that we have collected from you, subject to certain exceptions. Once we receive and confirm a verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. CCPA allows us to retain information needed, for example, to complete transactions you requested, to detect security incidents, to comply with legal obligations, or other such exceptions. If we must deny a deletion request due to an exception, we will inform you of the reason.
  • Right to Opt-Out of Sale or Sharing: California law gives you the right to opt out of the “sale” of your personal information, or the sharing of your personal information for cross-context behavioral advertising. Novel Group does not sell your personal information for money. However, we may share certain information with third parties in a manner that could be considered a “sale” or “sharing” under the CCPA’s broad definitions (for example, allowing third-party advertising cookies on our site could be considered a sale/share of data like device identifiers or browsing activity). You have the right to direct us not to sell or share your personal information. You can exercise this right by clicking on the “Do Not Sell My Personal Information” link on our Website (if available) or by contacting us as described below. We also recognize Global Privacy Control (GPC) signals – if you have GPC enabled in your browser, we will treat it as an opt-out of sale/sharing request as required by law.
  • Right to Correct: Effective January 1, 2023 (with CPRA), California consumers have the right to request correction of inaccurate personal information that we maintain about you. If you become aware that any personal information we have is incorrect, you may request that we correct it, and upon a verifiable request, we will do so where required by law.
  • Right to Limit Use of Sensitive Personal Information: The CPRA also gives you the right to limit our use or disclosure of Sensitive Personal Information if we collect such information for purposes beyond those allowed by law. Examples of sensitive data include precise geolocation, racial or ethnic origin, etc. At this time, Novel Group does not collect or process sensitive personal information for purposes that would trigger this right. If that changes, we will update our practices and honor opt-out preferences for the use of sensitive information as required.
  • Right to Non-Discrimination: You have the right not to receive discriminatory treatment from us for exercising any of your CCPA rights. This means we will not deny you services, charge you a different price, or provide a different level of quality of services just because you exercised your rights under the CCPA. However, please note that if you request deletion of your data, or opt out of certain uses, it may affect our ability to provide certain services (for example, if you ask us to delete all your information, we may not be able to keep you on our mailing list or recognize you for special offers). In such cases, that outcome is a function of your request, not a form of retaliation or discrimination.

Exercising Your California Privacy Rights: If you are a California resident and wish to exercise your Right to Know, Right to Delete, Right to Opt-Out, or Right to Correct, you (or an authorized agent acting on your behalf) can submit a verifiable consumer request to us by contacting us (see Contact Us information below). Please include “CCPA Request” in the subject line and specify which right you seek to exercise. We will need to verify your identity to process your request — this may involve matching information you provide with our records or asking you for additional information. For authorized agents, we may require proof of authority. We aim to respond to consumer requests within 45 days as required by CCPA (or inform you in writing if we need more time, up to an additional 45 days). Requests to opt out of sale/sharing will be honored within the timelines required by law (generally as soon as feasibly possible).
If you have any difficulty exercising your rights or need assistance, please contact us and we will be happy to guide you.

Other Jurisdictions

Our company strives to comply with privacy laws in all jurisdictions where we do business. If you reside in a state or country not explicitly listed above (for example, Virginia, Colorado, or other U.S. states with privacy laws, or countries like Canada, etc.), you may have similar rights (such as the right to access or delete your data, or to opt out of certain data processing). We will honor valid requests in accordance with applicable law. Please contact us to inquire about your specific privacy rights, and we will respond in accordance with the law.

Children’s Privacy

Our Website and services are not intended for children. We do not knowingly collect personal information from individuals under the age of 13. If you are under 13 years old, please do not provide any personal information on this Website or use our services. If we learn that we have inadvertently collected personal data from a child under 13, we will take steps to delete such information as soon as possible.
Additionally, because our services (luxury real estate) are typically relevant to adults, we request that anyone under 18 use our Website only with the involvement of a parent or guardian. We do not target or market to minors. If you are a parent or guardian and you believe we have collected information about a child under 13 (or under 18 without proper consent), please contact us so that we can investigate and delete the data as necessary.

Changes to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. If we make material changes to this Policy, we will notify users by posting the updated Policy on this page with a new effective date, and we may provide additional notice (such as via email or a pop-up notice on the Website) if required by law. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information. Your continued use of the Website after any changes to this Privacy Policy constitutes your acceptance of the updated terms.

Contact Information (Terms of Use)

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your personal information, please contact us at:

Novel Group
Email: info@novelgroup.us
Phone: +1(606)-707-5050

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