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Nova Privacy Policy

Last updated: December 4, 2025

Your privacy matters. This Privacy Policy explains what information Nova ("we", "our", "us") collects, how we use it, and the choices you have. This version is written in clear, accessible language suitable for App Store submission and will be refined with legal counsel as needed.


Scope

This Policy applies to our mobile apps, web services, websites, coaching features, customer support, and related services (collectively, the "Service").

It does not apply to third-party websites or services that we do not control.


Information We Collect

Account Information

Name, email address, authentication identifiers.

App Usage Data

Analytics, diagnostics, crash logs, feature usage, interaction patterns, session duration, and performance metrics.

Content You Create

Messages you send to Nova, voice notes, reflections, goals, and other coaching-related content.

Subscription & Payment Metadata

Subscription status, purchase history, and related metadata (handled securely by our payment providers).

We do not receive or store full credit card numbers.

Automatically Collected Data

Device identifiers, IP address, browser type, operating system, app version, cookie data, and similar technologies used for analytics, functionality, and security.


How We Use Information

We use your information to:

  • Provide, maintain, and improve the Nova coaching experience
  • Personalize coaching, prompts, reminders, and insights
  • Develop new features and improve model accuracy
  • Communicate updates, support responses, and security alerts
  • Detect, prevent, and address fraud, misuse, or technical issues
  • Comply with legal obligations and enforce our Terms

Legal Bases (EEA / UK)

Where required by law, we rely on the following legal bases:

  • Performance of a contract – to deliver the Service you request
  • Legitimate interests – to operate, secure, and improve the Service
  • Consent – for notifications, analytics, and optional features
  • Compliance with legal obligations

Sources of Information

We collect information:

  • Directly from you when you create an account or interact with Nova
  • Automatically from your device through analytics and diagnostics
  • From third-party partners such as app stores and payment processors

Data Storage and Security

We use trusted cloud providers and industry-standard security measures to protect your data.

Access to personal data is restricted to authorized personnel and systems needed to operate the Service.

No method of transmission or storage is 100% secure, but we take appropriate steps to safeguard your information.


Data Sharing and Third-Party Processors

We do not sell your personal data.

We may share limited data with third-party service providers under contracts that protect your privacy. Examples include:

  • Hosting & Infrastructure: Google Cloud Platform, Vercel
  • Analytics & Diagnostics: PostHog, Firebase
  • Payments & Subscriptions: Stripe, RevenueCat
  • Email & Notifications: Resend, Gmail

These third parties may only use your data as necessary to provide services to us and consistent with this Policy.


AI and Your Data

Nova uses AI models to power coaching experiences. Unless explicitly stated and consented to:

  • Your personal data is not used to train generalized AI models
  • Data may be processed to deliver responses and improve the quality of your individual experience
  • Internal evaluations and safety reviews may use anonymized or restricted-access data under strict controls

Your Choices and Rights

You may:

  • Access, update, or delete your data where features are available
  • Request deletion or export of your account data by contacting support
  • Change notification preferences in your device or app settings

Depending on your region, you may also have rights to object to or restrict processing, or request portability.

We verify all requests and respond within applicable timeframes.


Children's Privacy

Nova is not intended for children under 13.

If we learn that we collected personal information from a child under 13, we will delete it promptly.


International Transfers

Your data may be processed in countries outside your own.

When transferring data internationally, we use lawful safeguards such as Standard Contractual Clauses.


Retention

We retain personal data only as long as necessary to:

  • Provide the Service
  • Comply with legal obligations
  • Resolve disputes
  • Enforce our agreements

Retention periods vary depending on the data category and context.


Tracking Technologies

We may use cookies, device identifiers, and similar technologies to operate the Service, remember preferences, and measure usage.

You may control certain tracking settings through your device or browser.


Analytics and Diagnostics

We use privacy-conscious analytics to understand aggregate behavior and stability.

Consent or opt-out options are provided where required.


Push Notifications

With your permission, Nova may send notifications such as reminders, coaching prompts, and session updates.

You can disable notifications at any time via your device settings.


Health and Sensitive Data

Nova is not a medical device and does not diagnose, treat, or cure medical conditions.

Do not submit medical or protected health information unless you are comfortable with our processing as described in this Policy.


Changes to This Policy

We may update this Privacy Policy periodically.

The most current version will always be available at: https://nova.reflecta.so/privacy

Material updates will be communicated in-app or by email where appropriate.


Questions or Complaints

If you have concerns about our data practices, please contact us so we can help.

You may also have the right to lodge a complaint with your local supervisory authority.


Contact Information

Acta Ventures UG (haftungsbeschränkt)

Huferhof 36

51515 Kürten

Germany

Managing Director: Louis Morgner

Email: reflecta@acta.so