Privacy Policy

NOVA ViA, LLC ("we", "us", or "our") respects your privacy. This Privacy Policy describes how we collect, use, disclose, and protect information when you use the NOVA LiFE mobile application, website, and related services (collectively, the "Service"). By using the Service, you agree to the collection and use of information in accordance with this Policy.

1. Who This Policy Applies To

NOVA LiFE is offered to two primary categories of users:

Direct Consumer Users. Individuals who download and subscribe to NOVA LiFE directly. For these users, we act as the "business" or "controller" responsible for information collected through the Service.

Provider-Sponsored Users. Individuals whose access is sponsored by a treatment provider, clinician, health plan, employer, or other organization ("Sponsoring Organization"). Where the Sponsoring Organization is a HIPAA Covered Entity and we are performing services on its behalf, we act as a "Business Associate" under HIPAA and handle your Protected Health Information in accordance with our Business Associate Agreement with that organization.

2. Information We Collect

2.1 Information You Provide

We collect information you voluntarily provide when you register, use features, or contact us, including:

• Account information: name, email address, password, date of birth, phone number, and, if applicable, the Sponsoring Organization you are associated with.
• Recovery and wellness information: self-reported mood, cravings, sobriety dates, triggers, goals, milestones, reflections, journal entries, and related tracking data.
• AI chat inputs: messages, prompts, and conversations you submit through AI coaching features.
• Telehealth information: information collected in connection with telehealth sessions, which may include intake forms, insurance or payer information, clinical notes, and communications with a licensed provider.
• Payment information: billing details for consumer subscriptions. Card information is handled by our third-party payment processor and is not stored on our servers.
• Support and feedback: information you submit when contacting customer support, responding to surveys, or providing feedback.

2.2 Information Collected Automatically

When you use the Service, we automatically collect limited technical information, including device information, usage information, approximate location (derived from IP address,we do not collect precise GPS location unless you expressly enable a feature that requires it), and log data. We use cookies, SDKs, and similar technologies strictly for authentication, security, and service operation,not for advertising.

2.3 Information from Third Parties

If you access the Service through a Sponsoring Organization, we may receive enrollment or eligibility information from that organization. We do not receive data about you from advertising networks, data brokers, or social media platforms.

2.4 Sensitive Information

Certain information we collect,including information related to substance use, mental health, mood, cravings, and medications,is "sensitive personal information" under California law and "consumer health data" under Washington's My Health My Data Act. We apply heightened protections to this information.

3. How We Use Information

We use the information we collect only for the following purposes:

• Provide the Service: create and maintain your account, deliver features, process payments, and enable AI coaching, tracking, and telehealth.
• Communicate with you: send service-related messages and respond to inquiries. We do not send marketing emails without your consent.
• Safety and crisis response: identify and respond to potential safety concerns, including situations indicating risk of imminent harm.
• Maintain and improve the Service: troubleshoot, diagnose errors, secure the Service, and improve features using aggregated or de-identified data wherever practical.
• Legal and compliance: comply with applicable laws, enforce our Terms, and protect the rights, property, or safety of our users or others.

We do not use your personal information for third-party advertising, cross-context behavioral advertising, or to train third-party AI models.

4. How We Handle AI Chat and Coaching Data

When you interact with AI features in the Service, your inputs and the AI's responses are processed by our AI service provider(s) under a written agreement that prohibits use of your data to train their general-purpose models. Conversations are stored in your account history so you can review them and so we can provide continuity of support. We apply automated safety screening to detect content suggesting crisis or imminent risk.

Please remember: AI coaching is not therapy and is not reviewed in real time by a licensed clinician.

5. Safety and Crisis Situations

Because NOVA LiFE serves individuals in recovery, there may be situations where content you submit indicates risk of imminent harm to yourself or others. In such situations, we may display crisis resources such as 988 (Suicide & Crisis Lifeline), contact emergency services if we reasonably believe you or another person is at imminent risk of serious harm, or notify your Telehealth Provider if you are currently under their care through the Service.

We do not monitor your entries in real time and cannot guarantee detection of every crisis. If you are in immediate danger, call 911.

6. How We Share Information

We share information only as described below. We do not sell your personal information and do not share it with advertisers or marketing partners.

• Service Providers: vendors who help us operate the Service,cloud hosting, secure data storage, customer support, payment processing, and AI infrastructure providers,bound by written agreements and HIPAA Business Associate Agreements where required.
• Telehealth Providers: if you use telehealth features, we share information necessary for the provider to deliver care.
• Sponsoring Organizations: for Provider-Sponsored Users, we may share information with the Sponsoring Organization to the extent permitted by applicable law.
• Legal Requirements: if required by law, subpoena, or court order, or to protect rights, property, or safety.
• Business Transfers: if NOVA ViA, LLC is involved in a merger or sale of assets, with notice and in compliance with this Policy and HIPAA.
• With Your Consent: we may share information for other purposes with your consent or at your direction.

7. Data Retention

We retain information only as long as necessary to provide the Service, comply with legal obligations, resolve disputes, and enforce our agreements. Active account data is retained for the duration of your account. After account closure, we retain most personal information for up to three (3) years unless a longer period is required by law. De-identified or aggregated data may be retained indefinitely.

8. Security

We implement administrative, technical, and physical safeguards designed to protect your information, including encryption in transit and at rest, access controls, secure software development practices, workforce training, logging and monitoring, and incident response procedures. Our safeguards are designed to meet HIPAA Security Rule requirements where applicable.

No system is completely secure. We encourage you to use a strong, unique password and to promptly report any suspected compromise to admin@novalifeapp.com.

9. Your Choices and Controls

• Access and update: you can review and update your account information through the Service settings.
• Delete your account: you can request deletion of your account by contacting admin@novalifeapp.com.
• Communications: you can opt out of non-essential communications at any time.
• Device permissions: you can manage notifications, microphone, camera, and location permissions through your device settings.

10. Children

The Service is intended for individuals 18 years of age or older. We do not knowingly collect personal information from anyone under 18. If you believe a minor has provided us with information, please contact admin@novalifeapp.com.

11. State-Specific Privacy Rights

11.1 California Residents (CCPA/CPRA and CMIA)

If you are a California resident, you have the right to know, correct, delete, and limit use of sensitive personal information. We will not discriminate against you for exercising these rights. We do not sell or share your personal information for cross-context behavioral advertising. To exercise your rights, contact admin@novalifeapp.com.

11.2 Washington, Nevada, and Connecticut Residents

Additional rights may apply to "consumer health data" under state law, including the Washington My Health My Data Act. Contact admin@novalifeapp.com to submit a request.

11.3 Other States

Other U.S. states (including Colorado, Virginia, Utah, Texas, Oregon, Delaware, and Montana) provide comparable privacy rights. We honor applicable rights for residents of those states.

12. HIPAA Notice (Provider-Sponsored Users)

If you are a Provider-Sponsored User, the Sponsoring Organization is responsible for providing you with its Notice of Privacy Practices. You also have the right to file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights without retaliation.

13. Users Outside the United States

The Service is intended for users in the United States. If you access the Service from outside the U.S., your information will be processed in the U.S.

14. Do Not Track

We do not respond to "Do Not Track" browser signals because no uniform standard exists. However, as noted, we do not engage in cross-context behavioral advertising.

15. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will provide notice through the Service or by email before the changes take effect.

16. Contact Us