Privacy Policy

LAST REVISED: February, 2025

At Nova Network, Inc. (“Nova”, “us”, “we” or “our”), maintaining the trust of our online users is of the utmost importance to us. We have developed this Privacy Policy (the “Policy”) to show our commitment to fair information practices and the protection of our users’ privacy, and to explain how we collect, process, use and share information about our users. This Policy applies to our company website available at https://www.itsnova.com, mobile application, and to all other sites that are owned or operated by Nova or that have this Policy posted (collectively, the “Site” or “Sites”).

Please review this Policy carefully, and use the information herein to make informed choices. Feel free to contact us at privacy@itsnova.com if you have any concerns or questions about our privacy practices. By accessing the Sites, registering for an account, or making a purchase from us, you are agreeing to all of the terms set forth in this Policy.

If you do not agree to this Policy, do not use the Sites, purchase our services, interact with us, or give us any information. Your continued use of the Sites or our services means that you agree to this Policy.

1. What personal information we collect
   The types of personal information we obtain about you depends on how you interact with us and our products and services. When we use the term “personal information,” we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or de-identified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual.

   When we collect any information that does not identify you as a specific natural person, such information may not be deemed personal information under applicable law; such information, unless otherwise prohibited by law, may be used and disclosed for any purpose. Similarly, if applicable law requires that we treat non-personal information as personal information, we will use and disclose this information as personal information in accordance with this Policy.

   The following are the categories and specific types of personal information that we collect:

   • Basic Identifying Information. This may include your full name, postal and billing address, e-mail address, phone number, date of birth, account name, signature, username, social media handle, employer, or other similar identifiers.
   • Device Information and Other Unique Identifiers. This may include device identifier, internet protocol (IP) address, device type, carrier, cookies, beacons, pixel tags, mobile ad identifier, or similar unique identifiers.
   • Internet or Other Network Activity. This may include information regarding your interactions with our website, mobile application, emails, or advertisements.
   • Geolocation Data. This may include information that permits us to determine your location, such as if you manually provide location information or enable your mobile device to send us precise location information.
   • Order Information. This may include products or services you have purchased or considered, and your product preferences.
   • Demographic Data. This includes age and gender, some of which may include characteristics of protected classifications under state or federal law.
   • User Content. This may include your communications with us, communications with other users, and any other content you provide (such as social media profiles, photographs, images, videos, work experience, portfolio, survey responses, comments, job listings, reviews, testimonials, and other content).
   • Phone Contacts. This includes contacts saved on your mobile device to enable you to connect with your contacts on our Sites.
   • Inferences. Inferences drawn from or created based on any of the information identified above.
   • Job Applicant Information. Including professional or employment-related information (such as education and employment history) and any other information you provide in connection with applying and interviewing for employment with us. If we retain you as an employee, this may include, among other things, your Social Security number or taxpayer ID.
   • Sensitive Personal Information. We only collect sensitive personal information, as defined in the applicable U.S. state privacy laws, with your consent. We do not use sensitive personal information for inferring characteristics about you.
2. How we collect your personal information
   We collection information about you in a range of ways, including the following:

   Directly from You. We collect personal information you provide, such as when you submit an application, register for an account or create a profile, contact us, respond to a survey, participate in a sweepstakes, contest, or other similar campaign or promotion, apply for a job, or sign up to receive emails or text messages.

   Using Online Tracking Technologies and Other Automatic Data Collection Technologies. When you visit our Sites, open or click on emails we send you, or interact with our advertisements, we or third parties we work with automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies. For more information, please see “Cookies and Similar Online Tracking Technologies” section below.

   From Our Business Partners. We may obtain information from businesses that we have partnered with, collaborate with, or work with.
   From Social Media Platforms and Networks. If you interact with us on social media or use features, such as plugins, widgets, integrations, or other tools made available by social media platforms or networks (including Instagram, Vimeo, and Dribbble) in connection with our Sites, we collect information that you disclose to us, or that the social media platforms disclose to us. For more information about the privacy practices of those social media platforms, please review the privacy policies and settings of the social media platforms and networks that you use.

   From Other Sources. For example, we may obtain information about you from other sources, such as data analytics providers, marketing or advertising service providers, fraud prevention service providers, vendors that provide services on our behalf, or publicly available sources. We may also create information based on our analysis of the information we have collected from you.

   Do Not Track. Nova understands that some users may have enabled a “do not track” feature or other mechanism intended to provide consumers with a choice regarding the collection of their personally identifiable information; however, consistent with our rights under applicable law, our Sites may not support or respond to do-not-track requests or other signals sent from a web browser.

3. Online Tracking Technology
   We and our third–party partners and service providers (such as advertising and analytics providers) use tags, pixels, web beacons, software developer kits, third–party libraries, cookies, and other similar online tracking technologies (collectively, “online tracking technologies”) to gather information when you interact with our Sites and email communications. Some online tracking technologies help us maintain the security of our Sites and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.
   
   
4. How we use your personal information
   Depending on how you interact with our Sites, the personal information we collect and the way in which it is used may vary. We use the information we collect in order to best provide our services. Where you have provided us with your personal information, we may use that information in the following ways:

   Providing Services. We use your personal information to provide our services, such as to review your application to use the services; to send notifications to you related to your account and subscriptions; to create, maintain, and otherwise manage your account or profile, including offering functionalities such as the ability to save user preferences and history; and to provide a forum for posting photos, videos, job listings, and finding and offering work opportunities.

   Operate and Improve Site and Services. We use your personal information to operate, maintain, and improve our Sites and services, including to identify and repair errors or problems; to respond to comments and questions and provide customer service; to review and respond to flagged messages between users; and to send information including confirmations, technical notices, updates, security alerts, and support and administrative messages.

   Marketing and Promotions. We use your personal information to send marketing, advertising, and promotional communications by email and text message (such as promotions, new product launches, and event invitations) and to administer sweepstakes, contests, and other similar promotions.

   Analytics and Personalization. We use your personal information to develop your user profile (which may include information collected elsewhere) or to update other user information we may have about you; to conduct research and analytics, including to improve our services and product offerings; to understand how you interact with our Sites and communications with you; to improve our Sites and marketing campaigns; to personalize your experience with the services; to better understand our customers’ needs; and to provide personalized recommendations.

   Promote Security and Prevent Fraud. We use your personal information to detect, investigate, prevent, or take action regarding possible malicious, deceptive, fraudulent, or illegal activity, including fraudulent profiles; attempts to manipulate or violate our policies, procedures, and terms and conditions; and security incidents.

   Legal Obligations. We use your personal information to comply with our legal and regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.

   Recruitment and Hiring. We use your personal information to make decisions about recruitment and hiring.

5. Disclosure of Personal Information
   We will not disclose your personal information to third parties except as follows:
   • We may share personal information with third-party service providers that perform services to support our core business functions, internal operations, and marketing. Their use of your information is not governed by this privacy policy.
   • We may share personal information through Site features such as, plugins, widgets, and/or other tools made available by social media platforms and networks that may result in information being collected or disclosed between us and such parties. Their use of your personal information is not governed by this privacy policy.
   • We may share personal information for legal, protection, and safety purposes, such as to comply with laws; respond to lawful requests and legal processes; protect the rights and property of Nova, our agents, customers, and others; and enforce our agreements, policies, and terms of use.
   • We may share personal information with your consent. For example, you may consent to our sharing of personal information with others for their own marketing uses. Those uses will be subject to their privacy policies.
   • If you submit a public review or feedback, we may (at our discretion) store and present your review on our Sites. If you wish to remove your public review, please contact us at privacy@itsnova.com.
   • We may share information in an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
   • Personal information is maintained on our servers or those of our service providers, and is accessible by authorized employees, representatives, and agents as necessary for the purposes described in this Policy.
   • We may share personal information with our affiliates, or when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

   For the avoidance of doubt, Nova may share personal information in additional manners, pursuant to your express approval, if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.

6. Third-party sites
   This Policy applies only to information we collect, process, and use through our Sites. This Policy does not apply to information that we collect through other channels or any third-party websites that you may be able to access from our Sites, which may have data collection and use practices and policies that materially differ from those described in this Policy, or to any services that may be offered by our business partners. We are not responsible for the content or privacy practices of any third-party sites.
   
   
7. Storage and transfer of personal information
   Your personal information may be processed in a foreign country, where privacy laws may be less stringent than the laws in your country. By submitting your personal information to us, you agree to the transfer, storage, and processing of your personal information in a country other than your country of residence including, but not limited to, the United States. BY USING OUR SITES, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.
   
   
8. How long we store your information
   We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as necessary to:
   • Respond to any questions, complaints or claims made by you or on your behalf;
   • Show that we treated you fairly; or
   • Comply with our legal obligations; resolve disputes; enforce our agreements; or protect against fraudulent, deceptive, or illegal activity.{" "}

   We will not retain your personal information for longer than necessary for the purposes set out in this Policy. Different retention periods apply for different types of personal information. When it is no longer necessary to retain your personal information, we will delete or anonymize it.

9. Protection of your personal data
   We have put in place reasonable measures and appropriate procedures for implementing these policies and for safeguarding the personal data we collect. However, we cannot guarantee that personal information we collect will never be disclosed in a manner inconsistent with this Policy. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.

   For your convenience, our Site may include functionality that allows you to remain logged in so that you do not have to re-enter your password each time you want to access your account. If you choose to remain logged in, you should be aware that anyone with access to your device will be able to access and make changes to your account and may be able to make purchases through your account. For that reason, if you choose to remain logged in, we strongly recommend that you take appropriate steps (such as enabling the “Passcode Lock” security feature on your mobile device) to protect against unauthorized access to, and use, of your account. Please also notify us as soon as possible if you suspect any unauthorized use of your account or password.

10. Your legal rights over your personal information
    Consistent with applicable law, you may exercise the rights described in this section. Please note that some of the rights may vary depending on your country, province, or state of residence.

    The Right to Access, Correct or Delete Personal Information Where allowed under applicable law, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. However, we may not delete your data in the following situations:

    • If you have any open or ongoing matter with our customer service or technical support personnel or
    • When retention is required to comply with our legal obligations; resolve disputes; enforce our agreements; or protect against fraudulent, deceptive, or illegal activity.

    To exercise any such rights applicable to you, please contact us at privacy@itsnova.com. Please note that we may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law. We will respond to your request within a reasonable timeframe in accordance with the applicable law.

    Identity Verification
    For us to process some requests, we will need to verify your identity to confirm that the request came from you. We may contact you by phone or e-mail to verify your request. Depending on your request, we will ask for information such as your name, an e-mail address that you have used with us, a phone number you have used with us, or other information to help us verify your identity.

    Authorized Agent
    Depending on applicable law, you may be able to designate an authorized agent to submit a request on your behalf to access or delete your personal information. To do so, you must: (1) provide that authorized agent written and signed permission to submit such request and, if requested, (2) verify your own identity directly with us. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

11. GDPR and the Data Protection Act 2018 for EU/UK Residents
    We will keep your personal information while you have an account with us or while we are providing services to you. Thereafter, we will keep your personal information for as long as necessary to:

    Lawful Basis

    We will only collect and process your personal information where we have a lawful basis to do so. The legal basis for processing your personal information may vary depending on the purpose for which we are using the data. For example, in some cases we obtain your consent, in others we are legally obligated to process your data for a certain purpose, and in some cases, we rely on our legitimate interests, provided that such processing shall not outweigh your rights and freedoms.

    Please review Sections 5 and 6 above, where we describe the purposes for which we process your personal information. You have the right to object to our use of your personal information or withdraw your consent for any of these purposes by sending an email to privacy@itsnova.com. We may need to verify your identity before we are able to respond to the inquiry.

    Data Subject Rights – EU and UK residents

    As an EU or UK data subject, being a person resident in the EEA or UK, you are entitled to the following rights in regard to your personal data:

    • The right to access – You have the right to request that we provide you with copies of your personal data which we hold on record. In some scenarios, as permitted by law, we may charge you a small fee for this service.
    • The right to rectification – You have the right to request that we correct any information we have on record that you believe is inaccurate. You also have the right to request that we complete any information we have on record that you believe is incomplete.
    • The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
    • The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
    • The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
    • The right to data portability – You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

    If you make a request, we have one month to respond to you. You can verify whether we hold any of your personal data, or make a data subject request please contact us at privacy@itsnova.com. We may need to verify your identity before we are able to respond to the inquiry.

    Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to lodge a complaint with a supervisory authority.

12. Notice concerning children
    The Sites are not specifically directed at or intended for children under the age of 13, and Nova does not knowingly collect personal information via the Sites from anyone under 13. Any user that believes that Nova has in its database the personal information of a child under the age of 13 should contact us at legal@itsnova.com, so that, if necessary, we can remove the applicable information.
    
    
13. Managing communication preferences
    Email. You can stop receiving promotional e-mails at any time by clicking on the “unsubscribe” link at the bottom of any promotional e-mail that you receive from us.

    Text Messages. You can opt-out of receiving text messages from us by replying “STOP” to the text message you receive from us. Please note that this will only opt you out of the specific text messaging program associated with that number.

    In-App Push Notifications. You can stop receiving in-app push notifications by adjusting your notification settings in the Nova mobile application.

14. Contact information
    We welcome your comments or questions about this Policy. You may contact us at contact@itsnova.com.
    
    
15. Changes to this policy
    We reserve the right to revise this Policy from time to time (for example, to keep up with changes in the law or to reflect changes in how we are doing business). We will post the date it was last updated at the top of this Policy and provide additional notice to you via email if we make any changes that materially affect your privacy rights.