- Who we are and what this policy covers
- Limitations on use by minors
- Health information and HIPAA
- Information we collect
- Cookies and similar technologies
- How we use your information
- How we share your information
- Choice and control
- Data retention
- Where this policy applies
- California privacy rights
- Consumer health data rights
- Data security
- Changes to this policy
- Contact us
Who we are and what this policy covers
Nuvara ([TBD: legal entity name — e.g., Nuvara LLC]) operates nuvara.com (the "Site") as an educational and informational platform that connects interested users with licensed healthcare providers and a US compounding pharmacy through an affiliated partner network. Nuvara does not itself provide medical care, dispense medications, or fulfill prescriptions.
This Privacy Policy ("Policy") describes how Nuvara collects, uses, and shares personal information when you visit the Site, submit information through our waitlist or contact forms, or otherwise interact with us.
By visiting the Site or submitting information to us, you acknowledge this Policy. We will update this Policy when necessary to reflect material changes in how we handle information or as required by applicable law. If we make material changes, we will update the "Last updated" date at the top of this page and, where required, provide additional notice or obtain consent.
Limitations on use by minors
The Site is intended for users who are at least eighteen (18) years of age, or the age of majority in their jurisdiction of residence if higher than eighteen (18). The Site is not designed or directed to children under eighteen (18).
If we learn that we have collected personal information through the Site from a person under eighteen (18), we will use reasonable efforts to delete that information or stop using it in a retrievable form. A parent or legal guardian who believes that a minor has submitted information through the Site may request removal by contacting us using the details in the "Contact us" section below.
Health information and HIPAA
Nuvara is not a "covered entity" under the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations ("HIPAA"). HIPAA generally does not apply to health-related information simply because it is collected online.
When you join the Nuvara waitlist or otherwise interact with the Site, the information you provide to Nuvara — including your name, email address, ZIP code, and the health goals or concerns you select from our intake form — is not "protected health information" (PHI) under HIPAA. This information is governed by this Privacy Policy and applicable state law.
If and when you are later connected through Nuvara with a licensed healthcare provider or a compounding pharmacy, the information you share with those providers and pharmacies in the course of receiving care or having prescriptions filled may be PHI and will be governed by the privacy notices and practices of those providers and pharmacies — not by this Policy. See our Notice of Privacy Practices for more detail on how Nuvara handles information that crosses into that clinical context.
Information we collect
The personal information we collect depends on how you interact with the Site and the choices you make. We collect information from several sources: directly from you, automatically when you use the Site, and occasionally from third-party data sources.
Information you provide directly
- Contact information — your first name, email address, and optional ZIP code, which you provide when you join the waitlist or submit a form on the Site.
- Health goals and demographic data — the goals or concerns you select on our intake form (for example, "more energy day-to-day" or "sharpen focus and mental clarity"), together with your age range, gender identity, and self-reported experience with wellness protocols.
- Communications — the content of any emails, messages, or other communications you send to us.
Information we collect automatically
- Device and usage data — your Internet Protocol (IP) address, browser type and version, device type, operating system, referring URL, pages viewed, links clicked, time spent on the Site, access times, and other details about your use of the Site.
- Approximate location — we may infer your general geographic location (such as city or state) from your IP address.
- Cookies and similar technologies — described in more detail in the section below.
Information from third-party sources
- Service providers — third parties that collect or provide data in connection with work they do on our behalf (for example, analytics providers that help us understand how the Site is used).
- Marketing partners — partners with which we engage in co-marketing or promotional activities.
- Publicly available sources — such as open government databases or public online content.
You may decline to provide personal information to us. If you decline to provide information that is necessary to use a feature of the Site, that feature may not be available to you.
How we use your information
Subject to the limitations described in the "Health information and HIPAA" section above, we use personal information for purposes including:
- Service delivery — to operate the Site, maintain your waitlist registration, and connect you with affiliated providers and partner pharmacies when early access opens in your area.
- Business operations — to administer our records, secure our systems, detect fraudulent or illegal activity, verify your identity, meet our legal obligations, and protect our rights and property.
- Product improvement and research — to develop, test, and improve the Site and our offerings, and to analyze traffic and user behavior.
- Personalization — to understand your interests so we can tailor the content and communications we share with you.
- Customer support — to respond to your questions, fulfill your requests, and communicate with you about your waitlist registration.
- Communications — to send you updates, confirmations, technical notices, and administrative messages. Where permitted by law or with your opt-in, these communications may include marketing messages by email or SMS about Nuvara's offerings and those of our selected partners.
- Advertising — to promote Nuvara and our offerings, including through advertising on third-party websites and platforms. This may include the use of information about your browsing activity on the Site, including your interaction with health-related content.
We combine data collected from different sources for these purposes. Where applicable law requires your consent for specific uses of sensitive personal information, we will obtain that consent.
We may de-identify or aggregate personal information and use it for any lawful purpose. Where a process is designed to permanently de-identify data, we will not attempt to re-identify it except as permitted by law (for example, to validate the de-identification process).
How we share your information
We share personal information with your consent, as necessary to provide the services you request, or as otherwise permitted or required by law. Subject to the limitations in the "Health information and HIPAA" section above, we may share information with the following categories of recipients:
- Service providers. Vendors or agents working on our behalf — for example, companies that provide analytics, email delivery, fraud prevention, or customer support services.
- Affiliated providers and partner pharmacies. When you choose to engage with a licensed healthcare provider or a compounding pharmacy through Nuvara's affiliated partner network, we share relevant information with those providers and pharmacies so they can evaluate, consult, and provide services to you. Your interactions with those providers and pharmacies are governed by their own privacy practices and, where applicable, their Notice of Privacy Practices.
- Marketing and advertising partners. We may share identifiers and activity data with marketing or advertising partners to deliver personalized advertising — for example, to show you advertisements on other websites or platforms based on your interaction with the Site.
- Affiliates. We may share information across our corporate affiliates where access helps us to operate the Site and provide services.
- Corporate transactions. We may share personal information as part of a corporate transaction, such as a merger, financing, acquisition, bankruptcy, dissolution, or sale of all or a portion of our business or assets.
- Legal and law enforcement. We will access, share, and preserve information when we believe doing so is necessary to comply with applicable law or legal process, to protect our customers or the public, to prevent or respond to fraud or security incidents, or to protect our rights and property.
Third-party analytics and advertising
Third-party analytics and advertising companies also collect information through the Site, including identifiers and device information, approximate location, and usage data. These partners may combine data across multiple sites to improve their analytics and advertising for their own purposes and those of other clients.
NOTICE: Some of the data disclosures described above may be considered a "sale" or "sharing" of personal information as those terms are defined under California and other U.S. state privacy laws. Please see the "California privacy rights" section below for the rights you have with respect to such sharing.
We may also share aggregated or de-identified information in accordance with applicable law.
Choice and control
We provide several ways for you to control how we use the personal information we hold about you. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law.
Access, correction, and deletion
You may request access to, a copy of, correction of, or deletion of personal information we hold about you. See the "Contact us" section below for how to submit a request.
Communications preferences
You can choose whether to receive promotional communications from us by email or SMS. If you receive promotional messages and would like to stop, follow the unsubscribe directions in the message or contact us at the details below. These choices do not apply to service-related communications (such as confirmations or important notices about your registration).
Targeted advertising
You can opt out of certain targeted advertising using industry tools such as the Network Advertising Initiative (optout.networkadvertising.org) and the Digital Advertising Alliance (optout.aboutads.info). These choices are specific to the device and browser you are using.
Browser and platform controls
- Cookie controls. Most web browsers accept cookies by default. You can adjust your browser settings to delete or reject cookies, though doing so may affect certain features of the Site.
- Do Not Track. Some browsers include a "Do Not Track" (DNT) setting. There is no common standard for interpreting DNT signals, and we do not currently respond to DNT signals. You can use the cookie and advertising controls above to manage data collection and use.
- Mobile advertising ID controls. iOS and Android provide settings to limit tracking or reset advertising IDs.
- Email web beacons. Most email clients have settings that allow you to prevent the automatic downloading of images, which can prevent web beacons from connecting to their hosts.
Data retention
We retain personal information for as long as necessary to provide the services you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and for other legitimate business purposes. Retention periods vary based on factors including the sensitivity of the information, the purposes for which it was collected, and any legal or contractual obligations.
Where this policy applies
The Site is operated from within the United States and this Policy is governed by U.S. law. The Site is not intended for users located outside the United States. If you access the Site from outside the United States, you do so at your own initiative and are responsible for compliance with applicable local laws.
California privacy rights
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act, as amended ("CCPA"), you have the following rights. For a standalone summary of these rights, see our CCPA disclosure page.
Notice at collection
At or before the time of collection, you have a right to receive notice of the categories of personal information we collect, the purposes for which it is collected or used, whether it is sold or shared, and how long it is retained. That information is contained in this Policy.
Right to know
You have the right to request that we disclose to you the personal information we have collected about you, and additional information about our collection, use, disclosure, sale, or sharing of that information. See "Contact us" below for how to submit a request.
Right to correct or delete
You have the right to request that we correct inaccurate personal information, and to request that we delete personal information we hold about you, subject to exceptions permitted under the CCPA.
Right to opt out of "sale" or "sharing"
You have the right to opt out of the "sale" or "sharing" of personal information, as those terms are defined under the CCPA. The CCPA defines "sell" and "share" broadly, and some of the disclosures we make to advertising and analytics partners may fall within those definitions. In particular, we allow advertising and analytics providers to collect identifiers (IP addresses, cookie IDs, and mobile identifiers), activity data, device information, and approximate location through the Site.
To submit a "Do Not Sell or Share My Personal Information" request, email us at [TBD: privacy@nuvara.com] with "Do Not Sell or Share" in the subject line. If you opt out, we will not share personal information in ways that qualify as a "sale" or "sharing" under the CCPA. We will continue to provide some information to our partners acting as service providers to help us perform advertising-related functions on our behalf.
We do not knowingly sell or share the personal information of consumers under 16 years of age.
Right to limit use of sensitive personal information
You have the right to limit our use of sensitive personal information to purposes necessary to provide the services you request or as otherwise permitted by law.
Right to non-discrimination
You have the right not to be discriminated against for exercising your rights under the CCPA.
Exercising your rights
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf. Before accepting a request from an agent, we will require proof that you have authorized the agent to act on your behalf. To process requests to know, correct, or delete specific pieces of personal information, we will need to verify your identity — typically by requiring you to send the request from the email address associated with your account or by providing information reasonably necessary to verify your identity.
Consumer health data rights
Certain U.S. states — including Washington, Nevada, and Connecticut — have enacted laws providing additional rights with respect to "consumer health data" (as defined by those laws). The information we collect that may constitute consumer health data includes the health goals or concerns you select on our intake form, inferences about your interests based on your activity on the Site, and approximate location information.
If you are a resident of a state with a consumer health data law that applies to us, you may have rights to:
- Withdraw consent to the collection or sharing of your consumer health data.
- Access and confirm whether we have collected, shared, or sold your consumer health data, and request a copy.
- Request correction of inaccurate consumer health data.
- Request deletion of your consumer health data.
- Appeal a denial of any of the above requests.
To exercise these rights, email us at [TBD: privacy@nuvara.com]. We may need to verify your identity before processing your request.
Data security
We use reasonable physical, technical, and administrative measures intended to protect personal information from unauthorized access, use, disclosure, alteration, and destruction. No system is completely secure, and we cannot guarantee the security of information transmitted over the Internet or stored in our systems.
If you have reason to believe that information you shared with us has been compromised, please notify us immediately using the contact details in the "Contact us" section below.
Changes to this policy
We may update this Policy from time to time. When we do, we will post the revised Policy on this page and update the "Last updated" date at the top. If we make material changes, we will provide additional notice or obtain consent as required by law. Your continued use of the Site after we post an updated Policy constitutes your acceptance of the changes.
Contact us
If you have questions about this Policy or wish to exercise any of the rights described above, please contact us:
Nuvara — Privacy Team
Email: [TBD: privacy@nuvara.com]