Privacy Policy

NovaJenta  |  Last updated: May 2026

1. Who We Are

This website is operated by Paul Bale, trading as NovaJenta (“we”, “us”, “our”). NovaJenta provides fractional CMO and senior marketing advisory services.

For privacy matters, please contact us at:
Email: hello@paulbalecmo.com
Website: www.novajenta.com

2. Scope of This Policy

This Privacy Policy explains how we collect, use, store, and protect personal data when you visit www.novajenta.com (“the Site”). It applies to all visitors and any individuals who contact us through the Site.

We are committed to full compliance with:

• The EU General Data Protection Regulation (GDPR) (Regulation 2016/679)
• The Irish Data Protection Acts 1988–2018
• The ePrivacy Regulations (SI 336 of 2011, as amended)
• The EU AI Act (Regulation 2024/1689) — see Section 9

3. What Data We Collect

We collect only the minimum personal data necessary for the purposes described below. Depending on how you use the Site, this may include:

Automatically collected data:

• IP address and approximate location (country/region)
• Browser type and version
• Pages visited and time spent on the Site
• Referring URL
• Device type and operating system

Data you provide voluntarily:

• Name and email address (if you contact us via any contact form or email link)
• Any other information you choose to include in a message to us

We do not collect sensitive personal data (as defined under Article 9 GDPR), and we do not collect data from children under the age of 16.

4. How We Use Your Data

We process your personal data on the following legal bases under GDPR Article 6:

We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.

5. Cookies

The Site uses cookies. You can manage your cookie preferences at any time using the Cookie Settings option available on the Site.

We use the following categories of cookies:

• Strictly Necessary — Essential for the Site to function. These cannot be disabled.
• Analytics — Help us understand how visitors use the Site (e.g. pages visited, time on site). These are only placed with your consent.
• Preferences — Remember your settings and choices across visits. These are only placed with your consent.

We do not use advertising or tracking cookies, and we do not sell or share your data with advertising networks. For full details of the cookies used, please refer to our Cookie Settings panel.

6. Third-Party Services and Data Processors

We work with the following third-party services that may process personal data on our behalf. Each is bound by appropriate data processing agreements and/or standard contractual clauses:

Cloudflare — Provides domain infrastructure and content delivery network (CDN) services. Cloudflare may process IP addresses and technical traffic data as part of providing these services. Their privacy policy is available at www.cloudflare.com/privacypolicy.

Web3Forms — Processes form submissions made through the Site (including our waiting list and contact forms) on our behalf. When you submit a form, your name and email address are transmitted to Web3Forms solely for the purpose of relaying that submission to us. Web3Forms states that they do not store form submissions — data is relayed and deleted. NovaJenta has verified this against their current Privacy Policy and holds a Data Processing Agreement with Web3Forms in accordance with GDPR Article 28. Their privacy policy is available at web3forms.com/privacy.

We will update this list if additional processors are engaged. We do not sell your personal data to any third party.

7. Data Retention

We retain personal data only for as long as necessary for the purposes described in this policy:

• Contact enquiry data — retained for up to 24 months from last contact, then securely deleted
• Cookie consent records — retained for 12 months
• Analytics data — retained in accordance with the third-party provider’s settings, typically 14–26 months

8. Your Rights Under GDPR

As a data subject, you have the following rights:

• Right of access — to obtain a copy of the personal data we hold about you
• Right to rectification — to have inaccurate data corrected
• Right to erasure — to request deletion of your data (“right to be forgotten”)
• Right to restriction — to restrict how we process your data in certain circumstances
• Right to data portability — to receive your data in a structured, machine-readable format
• Right to object — to processing based on legitimate interests
• Right to withdraw consent — at any time, where processing is based on consent (including cookie consent)

To exercise any of these rights, please contact us at hello@paulbalecmo.com. We will respond within 30 days.

If you are unhappy with how we handle your data, you have the right to lodge a complaint with the Data Protection Commission (DPC), Ireland’s supervisory authority:

Data Protection Commission
21 Fitzwilliam Square South, Dublin 2, D02 RD28
www.dataprotection.ie  |  info@dataprotection.ie  |  +353 1 765 0100

9. AI Act Compliance

The EU AI Act came into force in August 2024 and applies progressively from 2025–2026. NovaJenta’s website does not currently deploy AI systems that interact with users or make decisions about individuals. Where AI tools are used in the production of content or services, they are used under human oversight and do not constitute high-risk AI systems as defined under the Act.

NovaJenta anticipates offering training services in AI and business automation. A specific privacy notice covering those services will be published prior to their launch.

We will update this section as our use of AI tools evolves and as further provisions of the AI Act come into effect.

10. International Data Transfers

Where any of our third-party processors transfer personal data outside the European Economic Area (EEA), we ensure that appropriate safeguards are in place in accordance with GDPR Chapter V, including Standard Contractual Clauses (SCCs) or adequacy decisions by the European Commission.

11. Security

We take reasonable technical and organisational measures to protect your personal data against unauthorised access, loss, or disclosure. However, no method of transmission over the internet is completely secure, and we cannot guarantee absolute security.

12. Links to Other Websites

The Site may contain links to third-party websites. We are not responsible for the privacy practices or content of those sites and encourage you to review their privacy policies.

13. Changes to This Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top of this page will reflect any changes. Where changes are significant, we will take reasonable steps to notify you.

14. Contact Us

For any questions about this Privacy Policy or how we handle your personal data:

Paul Bale
NovaJenta
Email: hello@paulbalecmo.com
Website: www.novajenta.com