Novi Privacy Policy

Effective date: [not yet in effect]
Last updated: [not yet in effect]

1. Introduction

This Privacy Policy describes how Novi Connections Inc. ("Novi," "we," "us," or "our") collects, uses, retains, and discloses information in connection with the Novi mobile application and the novidate.com website (together, the "Services"). The Services are currently available only in the Atlanta, Georgia metropolitan area.

Biometric information is addressed in the Novi Biometric Information Policy, which supplements this Privacy Policy and is available at novidate.com/biometric-policy.

If you have questions about this Privacy Policy, contact us at support@novidate.com.

2. Information We Collect

2.1 Information you provide

Account information. Your phone number (which serves as your account identifier and is used to send sign-in codes), first name, date of birth, and an optional recovery email address. Your date of birth cannot be changed after account creation.

Profile information. Your gender; the gender or genders you wish to meet; your preferred age range; your faith and its visibility setting; lifestyle responses (drinking, smoking, and family plans); education; career; local favorite places; written responses to profile prompts ("Sparks"); three profile photographs; and your standing weekly availability for scheduled calls.

Certain profile fields offer a visibility setting. Hiding a field removes it from your visible profile; the underlying answer is still used for matching.

Verification information. A brief video selfie and related facial data, processed to confirm that you are a real, live person and that your profile photographs are of you. This processing involves biometric information and is described in the Novi Biometric Information Policy. We request your express consent before this processing occurs, and verification cannot proceed without it.

Location information. We collect approximate location information only. During sign-up you may either enter your city or allow a one-time device location check; if you use the device location check, coordinates are reduced to approximately one-kilometer precision before use. We do not collect precise GPS coordinates and do not track your location on an ongoing basis. Other members see only a distance or neighborhood label, never your location.

Communications. Messages you exchange with matches through the in-app chat; reports you submit; and correspondence you send to us.

Waitlist information. If you sign up for the waitlist outside our service area: your approximate location or city; your email address (required when you sign up on our website, where email is the only way we can reach you; optional in the app, where a device notification token can serve instead); and, if you signed up in the app, that device notification token. This information is used to notify you when the Services open in your area, and occasionally about the launch itself.

2.2 Information generated through your use of the Services

• Verification results and numeric scores (no facial imagery is included in these records);
• Records of matches, scheduled calls, and related activity;
• Calendar free/busy windows, if you choose to connect a calendar (event details are not accessed);
• Device notification tokens and a log of notifications sent to you;
• Usage information, such as the screens you visit in the application, the sign-up steps you complete, taps on application controls, and similar interaction events. These records describe your use of the application's features; they do not include the content of your messages or profiles you view. See Sections 4 and 5.1 for how this information is used;
• Technical logs and crash reports generated when the application encounters an error, used to keep the application working correctly;
• Moderation, safety, and enforcement records, including reports and blocks.

2.3 Information we do not collect

We do not purchase information from data brokers, collect information from social media platforms, use advertising identifiers, access your contact list, or collect precise GPS location. We do not conduct criminal background checks or identity verification beyond the verification described above; see the Terms of Service for related disclaimers.

2.4 Payment information

When paid features launch, purchases will be processed by Apple, Google, or our payment processor. We will receive records of your purchases (the item, date, and status) but will not receive or store full payment card numbers.

3. Biometric Information

The Novi Biometric Information Policy governs our collection, use, retention, and destruction of biometric information. In summary: the video selfie used for liveness verification is never stored; a single still reference image from a passed verification is retained for no more than 30 days; verification records retained beyond that period contain numeric results only, with no facial imagery; and if an account is banned for serious misconduct, a facial template may be retained to prevent the banned individual from creating a new account. That retention exception, and all other biometric practices, are described in full in the Biometric Information Policy.

4. How We Use Information

We use the information described above to:

• Provide and operate the Services, including creating your profile, introducing you to other members, scheduling calls, and enabling chat;
• Verify that members are real, are of age, and match their profile photographs;
• Maintain the safety and integrity of the Services, including reviewing reports, enforcing our terms, and preventing banned individuals from returning;
• Send notifications you have enabled and service communications;
• Comply with legal obligations; and
• Understand and improve how the Services are used, through analysis of usage patterns in our own systems and through the analytics providers listed in Section 5.1.

We do not sell personal information and have never sold it. We do not use personal information for third-party advertising, and we do not serve advertising in the Services.

5. How We Share Information

5.1 Service providers

We share information with service providers that process it on our behalf and only as needed to perform their functions:

If you connect a Google calendar, Novi's use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements. Novi accesses only your calendar's free/busy windows and events Novi itself creates, and uses that information solely to schedule your calls.

5.2 Legal requirements and safety

We may disclose information where required by law, such as in response to a valid subpoena or court order, or where necessary to investigate or address serious safety incidents. Where legally permitted, we will notify you before disclosing your information in response to legal process.

5.3 Corporate transactions

If Novi is involved in a merger, acquisition, financing, or sale of assets, information may be transferred as part of that transaction. This Privacy Policy would continue to apply to your information, and we would notify you of any transaction that changes how your information is handled.

5.4 No other sharing

We do not share personal information with advertisers, data brokers, or unrelated third parties.

5.5 Third-party links

The Services may contain links to third-party websites. For example, the in-app chat may offer a shortcut to OpenTable's website for finding a restaurant. Opening such a link sends no information about you or your conversation to the third party, and Novi does not receive information about what you do on the third-party site. Novi counts how often such links are opened, without recording who opened them. Information you provide to a third-party website is governed by that website's privacy policy, not this one.

6. Data Retention

We retain information no longer than needed for the purposes for which it was collected, subject to the specific periods below.

7. Account Deletion

You may delete your account at any time in Settings. Upon account deletion:

• Your profile, photographs, preferences, matches, and messages are deleted;
• Any verification reference image still within its 30-day retention window is deleted immediately; and
• Your sign-in credentials are deleted.

We retain the following after account deletion: records we are legally required to keep or that are needed for safety purposes (for example, the record that a report was filed and resolved); records of consents you provided; and, only for accounts banned for serious misconduct, the facial template described in the Biometric Information Policy.

8. Data Security

We maintain administrative and technical safeguards designed to protect personal information. All access to member data passes through our servers; the application does not have direct access to other members' data. Verification images are encrypted at rest with a dedicated key. Calendar connection tokens are stored in an encrypted vault and are never stored in plain text. Staff access to member data is restricted, individually authorized, and recorded in an audit log.

No method of transmission or storage is completely secure. If a breach affects your information, we will notify you as required by applicable law.

9. Your Rights and Choices

• Access and correction. Your profile information is visible and editable in the application.
• Deletion. You may delete your account in Settings at any time, as described in Section 7.
• Location. You may enter your city manually instead of using the device location check.
• Calendar. You may disconnect a connected calendar at any time in Settings; disconnection deletes the associated tokens.
• Notifications. You may disable notifications in your device settings and may hide message previews in the application's settings.
• Verification consent. Express consent is requested before biometric verification. If you decline, verification cannot be completed and the Services will not be available, because all member profiles are verified.
• Requests. You may submit access, correction, or deletion requests to support@novidate.com, whether or not such rights are required by the law of your state. We respond within 30 days.

Depending on your state of residence, state law may grant you rights to access, correct, or delete personal information. The choices described in this section are available to all users regardless of state of residence.

10. Cookies and Website Data

The Novi application does not use cookies. The application collects the usage and crash information described in Sections 2.2, 4, and 5.1; it does not use advertising or cross-site tracking technologies. The novidate.com website does not set tracking or advertising cookies and does not use analytics. Because we do not track visitors across websites, browser Do Not Track signals do not change how the Services behave. If these practices change, we will update this Privacy Policy before the change takes effect.

11. Age Requirement

The Services are restricted to individuals 21 years of age or older. Sign-ups by individuals under 21 are refused and the associated data is deleted. If we learn that an account belongs to an individual under 21, the account is removed.

12. Scope

The Services are offered in the United States and are currently available only in the Atlanta, Georgia area. The practices described in this Privacy Policy apply to all users of the Services.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you through the Services before the changes take effect. The current version is available at novidate.com/privacy.

14. Contact Us

Novi Connections Inc.
support@novidate.com