Privacy policy
California consumer privacy statement
January 22, 2025
This California Consumer Privacy Statement supplements our Privacy Policy set forth below, which describes the personal information that we collect, the sources from which we collect it, the purposes for which we use it, the circumstances under which we share personal information, and with whom we share it. This Statement applies solely to California consumers and addresses personal information we collect online and offline. This Statement does not apply to NOVODX personnel or job applicants.
This California Consumer Privacy Statement uses certain terms that have the meanings given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).
1. Notice of Collection and Use of Personal Information
We may collect the following categories of personal information about you:
Identifiers: identifiers such as a real name, postal address, unique personal identifier (such as a device identifier; cookies, pixel tags, and similar technology; customer number, unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), internet protocol address, email address, account name, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: signature, bank account number, and other financial information and medical information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, sexual orientation, marital and family status, medical condition, pregnancy or childbirth and related medical conditions
Commercial Information: commercial information, including products or services purchased, obtained, or considered, and other purchasing histories
Online Activity: Internet and other electronic network activity information such as information regarding your interaction with websites, applications or advertisements
Sensory Information: audio, electronic, visual, and similar information
We may use the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:
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Purposes |
Categories of Personal Information |
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Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services |
• Identifiers |
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Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance |
• Identifiers |
|
Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction |
• Identifiers |
|
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity |
• Identifiers |
|
Debugging to identify and repair errors that impair existing intended functionality |
• Identifiers |
|
Undertaking internal research for technological development and demonstration |
• Identifiers |
|
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us |
• Identifiers |
2. Our Prior Collection, Use and Disclosure of Personal Information
We may have collected and used your personal information, as described in Section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement. For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.
Sources of Personal Information
We may have obtained personal information about you from various sources, as described below.
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Categories of Sources of Data Collection |
Categories of Personal Information |
|
Directly from you: |
• Identifiers |
Sharing of Personal Information
We may have shared your personal information with certain categories of third parties, as described below.
|
Categories of Third Parties |
Categories of Personal Information |
|
Partners who perform functions on NOVODX’s behalf |
• Identifiers |
|
Governmental agencies such as law enforcement agencies |
• Identifiers |
We do not sell personal information and have not sold personal information during the 12-month period prior to the effective date of this Privacy Policy.
c. Disclosure of Personal Information for a Business Purpose
We may have disclosed to third parties for a business purpose the following categories of personal information: Identifiers; Additional Data Subject to Cal. Civ. Code § 1798.80; Protected Classifications; Commercial Information; Online Activity; and Sensory Information.
3. California Consumer Privacy Rights
You have certain choices regarding your personal information, as described below.
Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Deletion: You have the right to request that we delete certain personal information we have collected from you.
Suggestions: If in the future NOVODX discloses personal information to third parties for direct marketing purposes, you will have the right to request that we provide you with (a) a list of certain categories of personal information we have disclosed to third parties for their direct marketing purposes during the immediately preceding calendar year and (b) the identity of those third parties.
How to Submit a Request. To submit an access, deletion request email us at info@novo-dx.com. NOVODX will attend to all privacy requests promptly in line with its policy. For CCPA application, you are kindly requested to provide evidence of residence.
Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to complete a request form providing any or all of the following information:
First and last names;
Email address;
Telephone number;
Full residential address;
A copy of certain identification documents; and/or
signature.
In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. We will require you to execute the above referenced declaration and submit it back to us. If, in our sole determination in accordance with the CCPA, we are unable to verify your identity, NOVODX may deny the request in whole or in part.
If you designate an authorized agent to make an access or deletion request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
Please understand that we cannot delete personal information in those situations where our retention is required for our own internal business purposes or otherwise permitted by the CCPA (such as fraud prevention and legal compliance) or other applicable law. In these situations, we will retain your information in accordance with our records retention program and securely delete it at the end of the retention period.
Additional Information. If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. This Statement is available in alternative formats upon request. Please contact info@novo-dx.com (Monday – Friday 8:30 a.m. – 5.00 p.m. Eastern Time, excluding National Holidays for visually and hearing impaired.
Consumer Health Data Privacy Policy
Effective January 22, 2025
NOVODX a Delaware corporation ( hereinafter “NOVODX”, “We”) are committed to respecting your privacy. Our Privacy Policy describes how we handle your personal data generally. This supplemental Consumer Health Data Privacy Policy (“Health Privacy Policy”) explains our practices for “Consumer Health Data” as such term is defined by applicable laws including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. health privacy laws, as each are amended and as and when they become effective including any regulations thereunder (“U.S. Health Privacy Laws”).
“Consumer Health Data” is broadly defined to mean personal information that is linked or can be reasonably linked to a consumer and that identifies past, present or future physical or mental health status. Consumer Health Data includes information about medical conditions as well as non-medical information, such as biometric data, information about use of non-prescription medication or use of health-related products., for example. Consumer Health Data does not include information pertaining to individuals with whom we have an employment relationship.
If we make any material updates to this Health Privacy Policy, we will notify you as required by U.S. Health Privacy Laws, including by either notifying you at the time of collecting Consumer Health Data, or by updating this Health Privacy Policy earlier than required. We reserve the right to amend this Health Privacy Policy at our discretion and at any time.
Categories of Consumer Health Data that We Collect
NOVODX only collects, uses and discloses Consumer Health Data as needed to provide you with the products or services that you request or with your consent.
NOVODX may collect Consumer Health Data related to the following categories of Consumer Health Data:
- Product Interests. Information about your interest in health-related brands or products, such as when you visit some of our websites and mobile applications or buy certain products.
- Individual Health Conditions, Treatments and Diseases. Information about your health history, symptoms and/or treatment, such as pregnancy status.
- Bodily Function, Vital Signs and Measurements. Information about the operations of the systems of your body, such as digestion, metabolism, immune support or height and weight.
- Reproductive and Sexual Health Information. Information about your reproductive system or sexual well-being collected when you voluntarily provide it to certain websites or mobile applications or buy certain products, such as information about your periods or pregnancy status.
- Research Programs. Information you provide when participating in research studies or responding to our surveys including any of the above categories about physical or mental health, medical history or other health-related information.
Purposes for Collecting Consumer Health Data and How We Use It
We may use your Consumer Health Data for the following Processing Purposes:
- Products/Services, including performing services for you and sending you certain products or samples you have requested.
- Consumer Management, such as:
- Identifying and authenticating you to our different marketing programs, websites, and mobile apps.
- Administering and maintaining accounts and preferences, as well as financial incentive, rewards, discounts (e.g., price or service coupons) and loyalty programs.
- Helping you manage your website or app preferences.
- Allowing you to enter our contests or sweepstakes and leaving ratings and reviews for products.
- Consumer Service/Communications, such as:
- Responding to your questions or requests for information
- Sending transactional messages (such as account statements or confirmations).
- Sending marketing communications about our products or services (or the products or services of our partners), surveys, and invitations.
- Payment/Financial, such as processing your financial details for managing refunds.
- Serving Ads, including serving you with relevant ads about our brands and programs.
- Ads Administration, such as measuring and tracking the effectiveness of advertising campaigns and carrying out other administrative and accounting activities with respect to ad campaigns.
- Quality and Safety, including:
- Quality control, training, and analytics.
- Safety maintenance and verification.
- System administration and technology management, including optimizing our websites and applications.
- Security, including detecting threats and protecting against malicious or fraudulent activity.
- Recordkeeping and Auditing, including recordkeeping and auditing interactions with consumers, including logs and records maintained as part of transaction information.
- Legal/Compliance, including risk management, audit, investigations, reporting and other legal and compliance reasons.
- Research & Development (“R&D”), such as
- Internal research,
- Clinical study applications,
- Designing and developing new products, services, and programs.
Data Storage and Retention
We retain personal data for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, or as required by applicable laws, regulations, or contractual obligations. Specifically:
- Account Information: Retained as long as your account is active and for up to 2 years after account closure to comply with legal obligations or resolve disputes.
- Transaction Data: Retained for a minimum of 5 years as required for tax, accounting, and regulatory purposes.
- Consumer Health Data: Retained for the duration of your use of our health-related products and services and for up to 2 years after to comply with applicable laws or conduct research and development.
- Marketing Data: Retained until you withdraw consent or opt out, after which it will be deleted or anonymized unless retention is required by law.
- Legal and Compliance Records: Retained as long as necessary to meet legal and regulatory requirements, typically 10 years.
After the applicable retention periods, personal data is securely deleted, anonymized, or aggregated to prevent unauthorized access or use.
Sources of Consumer Health Data
We collect Consumer Health Data from the following sources:
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From you, such as when you request certain health-related products and services, join certain brand marketing email lists or loyalty programs, or volunteer the information in connection with surveys or promotions.
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From your interactions with us, such as when you use our health-related apps or browse our websites for brands related to health.
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From our business and marketing partners, who provide us with information about consumers who are viewing our content across websites or apps, purchasing our products, or taking advantage of our promotions.
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From other third-party sources such as data brokers who provide us with information about consumers that may be interested in our products.
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We may also infer or derive Consumer Health Data by analyzing other non-health related data we have about you or other consumers.
Disclosures of Consumer Health Data
We do not sell your Consumer Health Data. We also do not share your Consumer Health Data with any Third Parties or Affiliates.
We may disclose the categories of Consumer Health Data described above in the following circumstances:
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We may disclose Consumer Health Data with our data processors, service providers and contractors who assist us in providing goods and services to you. These processors may only use the data as permitted by our contracts with them.
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We may also disclose Consumer Health Data as permitted by law, such as (i) with your consent, (ii) if needed to protect your vital interests, such as in the event of a medical emergency or natural disaster, (iii) to an acquiring organization if we are involved in a sale or a transfer of our business, (iv) as needed to prevent, detect, protect against, or respond to security incidents, identity theft, fraud, harassment, malicious or deceptive activities, (v) as needed to preserve the integrity or security of our systems or (iv) to investigate, report, or prosecute those responsible for any action that is illegal under applicable state or Federal law.
Your Privacy Rights
You have specific rights with respect to your Consumer Health Data:
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You have the right to know if we are collecting, using or disclosing your Consumer Health Data, to access that consumer health data, including receiving a list of the entities and affiliates with whom we have shared or sold your information, though currently we do not sell or share your Consumer Health Data with Third Parties or Affiliates.
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You have the right to request that we delete your Consumer Health Data.
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If we are processing your Consumer Health Data with your consent, you have the right to withdraw that consent. For cookie-related Consumer Health Data, you can do this by visiting your “Cookie consent” at the bottom of our health-related websites or in the Settings menu of our mobile applications. Withdrawing your consent for collection of non-cookie related Consumer Health Data will effectuate a deletion request.
We will not discriminate against you for exercising any of your rights. However, if you withdraw consent for collection and/or request deletion of your Consumer Health Data, we may remove you from certain marketing programs that rely on your Consumer Health Data to provide you the services. To exercise these rights, please contact us at info@novo-dx.com. We will authenticate your requests and process it as required by law. Please allow up to 45 days for a response. If your appeal is unsuccessful, you can file a complaint with the relevant government body in your state, including:
- Washington State Attorney General at www.atg.wa.gov/file-complaint.
- Nevada State Attorney General at https://ag.nv.gov/Complaints/File_Complaint/.
Please contact us at info@novo-dx.com directly with any questions or concerns you may have about your Consumer Health Data privacy or this Health Privacy Policy. Conform to the “Additional Information: above relating to time and national holidays, etc.
CONTACT US
Phone: (561) 826 4881
Email: support@novo-dx.com
Address: 1061 E Indiantown Road, Suite 110. Jupiter, FL 33477