Privacy Policy

Effective Date: 01/07/2025

NOVARX (“Company” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.novarx.co (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy should be read in conjunction with our California Consumer Privacy Act (CCPA) Opt-out Notice, contained herein, and Collection Notice.

This policy applies to the information we collect:

• On this Website.
• In email, text, and other electronic messages between you and this Website.
• Through mobile and desktop applications you download from this Website, which provides dedicated non-browser-based interaction between you and this Website.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by the Company or any third party[ (including our affiliates and subsidiaries)]; or
• Any third party[ (including our affiliates and subsidiaries)], including through any application or content (including advertising) that may link to or be accessible from or through the Website. 

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Protected Health Information (PHI) and Medical Records

We are committed to protecting your Protected Health Information (PHI) in accordance with the Health Insurance Portability and Accountability Act (HIPAA) and applicable privacy laws. This section explains how we handle PHI, your rights concerning it, and who to contact for more information.

1. How We Collect PHI

We may collect PHI when:

• You provide it to us directly (e.g., during registration, consultations, or use of our services).
• It is shared with us by authorized healthcare providers or partners in compliance with applicable laws.

2. How We Use PHI

We use PHI for purposes such as:

• Providing healthcare-related services.
• Processing payments for medical treatments or services.
• Improving our products and services.
• Complying with legal obligations, such as reporting to public health authorities.
• We will only use PHI as permitted by law and will not use it for marketing purposes without your explicit authorization.

3. Sharing PHI

We may disclose PHI to third parties, including:

• Healthcare providers for treatment purposes.
• Insurance companies for payment purposes.
• Service providers who perform functions on our behalf (e.g., data processing or storage) under a Business Associate Agreement (BAA).
• Regulatory authorities or law enforcement, as required by law.

All third-party partners are required to comply with HIPAA regulations and safeguard your PHI.

4. Safeguarding PHI

We implement administrative, technical, and physical safeguards to protect PHI, including:

• Encryption of PHI in transit and at rest.
• Secure access controls to limit who can view or modify PHI.
• Regular training for employees handling PHI to ensure compliance with HIPAA standards.
• While we strive to protect your information, no system is 100% secure. If a breach involving PHI occurs, we will notify affected individuals as required by law.

Your Rights Regarding PHI

As a patient, you have the following rights under HIPAA concerning your PHI:

1. Access to Your Records:
   You have the right to request and receive a copy of your medical records.
2. Request for Amendments:
   You may request corrections to your medical records if you believe there is an error or incomplete information.
3. Restrictions on Use or Disclosure:
   You can request restrictions on how we use or disclose your PHI, though we are not always required to agree to such restrictions.
4. Confidential Communications:
   You may request that we contact you in a specific way (e.g., at a certain address or phone number) to maintain confidentiality.
5. Accounting of Disclosures:
   You have the right to request a list of instances where your PHI was disclosed for reasons other than treatment, payment, or healthcare operations.
6. File a Complaint:
   You have the right to file a complaint if you believe your privacy rights have been violated. Complaints can be directed to us or to the U.S. Department of Health and Human Services (HHS).
7. To exercise any of these rights, please contact our Privacy Official using the information provided below.

Privacy Official Contact Information

If you have questions about our privacy practices, wish to file a complaint, or need assistance with your PHI rights, please contact our Privacy Official:

Compliance Officer of NovaRX
Nova Vascular LLC
99 Wall St #878
New York, NY, 10005
(315) 631-0894
info@novarx.co

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one underage may provide any information to or on the Website. We do not knowingly collect personal information from children under 18 years old. If you are under 18, do not use or provide any information on this Website or on or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18 please contact us at: info@novarx.co or (929) 578-0823.

Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding the collection and sale of their personal information. Please see Your State Privacy Rights for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

• By which you may be personally identified, such as name, postal address, email address, or telephone number (“personal information”);
• That is about you but individually does not identify you and/or
• About your internet connection, the equipment you use to access our Website, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
• From third parties, for example, our business partners.

Information You Provide to Us.

The information we collect on or through our Website may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website. We may also ask you for information when you report a problem with our Website.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
• Your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies.

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website. The technologies we use for this automatic data collection may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate settings on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.

We do not collect personal information automatically, but we may tie non-personal information collected automatically to personal information about you that we collect from other sources or that you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your account, including expiration and renewal notices.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To allow you to participate in interactive features on our Website.
• In any other way, we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about our own and third-party goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the order form) or adjust your preferences in your account profile.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect, or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all NOVARX assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by NOVARX about our Website users is among the assets transferred.
• To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of NOVARX, our customers, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data. You can also always opt-out by logging into the Website and adjusting your user preferences in your account profile, by checking or unchecking the relevant boxes, or by sending us an email stating your request to info@novarx.co

Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@novarx.co. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt-out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.

Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target audience preferences, you can opt-out at any other time by logging into the Website and adjusting your user preferences in your account profile by checking or unchecking the relevant box or by sending an email to info@novarx.co. For this opt-out to function, you must have your browser set to accept all browser cookies.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website and visiting your account profile page.

You may also send us an email at info@novarx.co to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding the use of their personal information.

California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
• Data portability.
• Opt-out of personal data processing for: targeted advertising (excluding Iowa); sales; or profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
• Either limit (opt-out of) or require consent to process sensitive personal data.
• Rights for California Customers under the California Consumer Privacy Act (CCPA)

The California Consumer Privacy Act gives you control over the personal information that we collect. Please review this Policy is full in conjunction with our CCPA Collection Notice and Opt-Out Notice.

1. Right to Know

You have a right as a consumer to request that we disclose to you what personal information is collected, used, shared, or sold about you, and why that information was collected, used, shared, or sold. Specifically, you may request the following: The categories of information collected. Specific pieces of personal information collected. The categories of sources from which the business collected personal information.The purposes for which the business uses the personal information.The categories of third parties with whom the business shares the personal information.The categories of information that we disclose to our third-party partners. Please see our CCPA Collection Notice and Opt-Out Notice for more information.

2. Right to Correct.

You, as a customer, have the right to request that NOVARX correct any inaccurate information that we have about you. Please contact info@novarx.co to exercise this right. We are required to respond to your request within 45 calendar days, which can be extended upon notice. We may also ask you for additional information upon receiving this request and we may deny a request for the following, but not exclusive, reasons: We cannot verify your identity to complete the request. The request is manifestly unfounded or excessive. The information is publicly available, certain medical information, consumer credit reporting information, or other types of information exempt from the CCPA.

3. Right to Delete

Please review this privacy policy in full. You may request that we delete the personal information collected and that we instruct our service providers to do the same. Certain exceptions allow us to keep your personal information, such as publicly available information, verification difficulties, business security practices, or legal obligations, to name a few. Please contact info@novarx.co to exercise this right

4. Right to Limit Use of Personal Information (Right to Limit)

You as the consumer, have the right to direct NOVARX to only use your sensitive personal information for limited purposes, such as providing you with the services you requested. Please contact info@novarx.co to exercise this right.

5. Right to Opt-Out of Sharing

You may request that we stop sharing your personal information (“opt-out”). Please note that sharing refers specifically to sharing for cross-context behavioral advertising, which is the targeting of advertising to a consumer based on the consumer’s personal information obtained from their online activities. Exceptions to the Opt-Out right include: Sale or sharing is necessary for us to comply with legal obligations, exercise legal claims or rights, or defend legal claims. The information is publicly available information, certain medical information, consumer credit reporting information, or other types of information exempt from the CCPA. Please contact info@novarx.co to exercise this right. 

6. Right to Non-Discrimination

We cannot deny you goods or services, charge you a different price, or provide a different level or quality of goods or services should you choose to exercise your rights under the CCPA. However, if you refuse to provide your personal information to NOVARX or ask us to delete or stop sharing your information, and that information is necessary for us to provide you with goods or services, then we may not be able to complete the transaction.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you, by email, to the primary email address specified in your account, or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us info@novarx.co