Privacy Policy

Last Revised and Effective: August 25, 2026

Welcome to NovaBridge’s website.

This Privacy Policy describes our practices regarding the collection, use and disclosure of personal data that we may collect about you, including through our websites at: https://www.novabridge.com/Home, mobile sites, and mobile applications and any subdomains thereof (collectively, the “Sites”) and, to the extent our processing of your personal data is regulated by the European Data Protection Laws (as defined below) or our processing of your consumer information is regulated by the CCPA (as defined in Section 13), in connection with our other offerings.  Except to the extent our processing of your personal data is regulated by the European Data Protection Laws or our processing of your consumer information is regulated by the CCPA, this Privacy Policy does not apply to any other information collected by NovaBridge by or through any means other than the Sites, such as information collected offline. When we refer to ourselves as “we”, “us”, “our”, “NovaBridge Biosciences,” or “NovaBridge”, we mean NovaBridge Biosciences and all of its Affiliates set out in the most recent SEC Annual Report available at: https://www.novabridge.com/investor-relations. To the extent our Sites or other offerings contain links to third party websites/content/services that are not owned or controlled by NovaBridge Biosciences, NovaBridge Biosciences is not responsible for how these properties operate or treat your personal data so we recommend that you read the privacy policies and terms associated with these third-party properties carefully.

For individuals in the EU/EEA/UK, please see the applicable provisions below.

For California Residents, please see Section 13 below.

If you have questions about this notice, please contact NovaBridge Biosciences at Legal@novabridge.com.

As used herein: (a) “personal data” means information that can be used to identify you or can be tied to you in an identifiable manner; (b) “you” and “your” mean a user of the Sites and, to the extent our processing of an individual’s personal data is regulated by the European Data Protection Laws or our processing of an individual’s consumer information is regulated by the CCPA, an individual who engages with our other offerings; (c) “GDPR” means the General Data Protection Regulation (EU) 2016/679; (d) “UK Data Protection Laws” means the UK GDPR and the UK’s Data Protection Act 2018 (“UK DPA 2018”); (e) “UK GDPR” means the UK equivalent of the GDPR, as defined in section 3(10) (and as supplemented by section 205(4)) of the UK DPA 2018; (f) “European Data Protection Laws” means the GDPR and/or UK Data Protection Laws, in each case to the extent applicable; (g) the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within NovaBridge Biosciences or among our Affiliates within the United States or internationally; and (h) “Affiliate” means any person or entity which directly or indirectly controls, is controlled by or is under common control with NovaBridge Biosciences, whether by ownership or otherwise; and “control” means possessing, directly or indirectly, the power to direct or cause the direction of the management, policies or operations of an entity, whether through ownership of fifty percent (50%) or more of the voting securities, by contract or otherwise.

If an organization with which you are associated (an “Organization”) signs up to use our services, we may receive information about you in connection with our provision of such services to your Organization. To the extent we process that information solely in order to provide such services to your Organization, we will act as a processor on behalf of your Organization in respect of that information, which means: we will handle that information solely at the direction of your Organization; your Organization’s privacy policy (and not this Privacy Policy) will apply to the processing of that information; and your Organization (and not us) is responsible for obtaining all necessary consents and providing you with all requisite information as required by applicable law. To the extent we process your personal data for any other lawful business purpose of ours, this Privacy Policy will apply to the processing of such personal data.

1. PERSONAL DATA NOVABRIDGE BIOSCIENCES MAY COLLECT

We generally collect personal data that you provide to us, including online through the Sites and/or our other offerings. Below are several methods through which NovaBridge Biosciences may collect your personal data:

• Information that you provide: We collect personal data and other data that you provide to us, including personal data you may enter into forms or data fields on our Sites. Such information may include, but is not limited to, contact information (such as your name, postal address, e-mail address, telephone number).
• Information from public or third-party information sources: In some cases, we may augment our existing user databases with information from third parties. We may also collect personal data about you from other sources, including data companies, publicly accessible databases, joint marketing partners, social media platforms and other third parties.
• Information collected from your computer or other electronic device: We may collect information about your computer or other electronic device when you visit our Sites that in some cases may be identifiable. This information may include your Internet Protocol (IP) address, Internet Service Provider (ISP), domain name, browser type, date and time of your request and information provided by tracking technologies, such as cookies, single-pixel tags, local share objects (Flash), local storage, Etags and scripts. If you use a mobile device to access our Sites and other online resources, we also may collect information about your device, such as your device ID and device type, as well as usage information about your device and your use of our mobile web sites and other mobile resources.

2. HOW WE MAY USE YOUR PERSONAL DATA

Pursuant to the European Data Protection Laws, legal bases for our processing of your personal data may include (without limitation):

(a) where you have given consent to the processing, which consent may be withdrawn at any time without affecting the lawfulness of processing based on consent prior to withdrawal;
(b) where it is necessary to perform the contract we have entered into or are about to enter into with you (whether in relation to the provision of the Sites, our other offerings, or otherwise);
(c) where it is necessary for us to comply with a legal obligation to which we are subject; and/or
(d) where it is necessary for the purposes of our legitimate interests (or those of a third party) in providing, improving, or marketing the Sites and/or our other offerings and your interests or fundamental rights and freedoms do not override those legitimate interests.

Generally, NovaBridge Biosciences collects personal data from you as necessary to enable individuals to register for, customize and personalize certain of our resources and communications. We use personal data to provide products, services and features and other resources that individuals have requested; for example, educational literature and related information about our business, e-mail programs, tools, questionnaires, and surveys. We analyze personal data collected online to identify and offer additional services and promotions that we believe you might find interesting. We may aggregate and/or de-identify your personal data and use it for our lawful business purposes, including product and service development and improvement activities. We use reasonable safeguards designed to minimize the risks associated with the process of anonymizing your personal data.

The personal data that we collect, including through the Sites and/or our other offerings, may also be used for the following purposes:

• To respond to your requests for information, products, or services;
• To provide you with general health information (such as information on certain health conditions as they relate to our offerings) as well as information about our products and services;
• Unless you opt out (to the extent permitted by applicable law), to send you marketing communications, including about a particular NovaBridge Biosciences product or concerning general disease information;
• To determine if you are eligible for certain products, services, or programs;
• To manage or develop our business relationship with you (e.g., to respond to questions, invite you to events, comply with regulatory obligations, or determine eligibility for NovaBridge Biosciences programs);
• For our research, development, and collaboration efforts;
• When we believe it is necessary or appropriate to enforce our legal rights and to comply with applicable laws, lawful requests, and legal process (including to meet national security or law enforcement requirements), such as to respond to subpoenas or requests from government authorities;
• For regulatory reporting, such as adverse event or pharmaceutical transparency reporting; and
• For other everyday business purposes, such as payment processing and financial account management, product development, contract management, administration, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance.

The information we collect from your device is used to better design our Sites. We analyze this information to enhance Sites security and to track the popularity of certain pages of the Sites, the success of our email notifications, traffic levels on the Sites, and other usage data, all of which helps us to provide content tailored to your interests and improve the Sites and related services.

3. COOKIES AND SIMILAR TECHNOLOGIES 

We may collect information passively using “cookies” and “action tags.”

“Cookies” are small text files that can be placed on your computer or mobile device in order to identify your web browser and the activities of your computer on the Sites and other websites. Cookies can be used to personalize your experience on the Sites (such as dynamically generating content on webpages specifically designed for you), to assist you in using the Sites (such as saving time by not having to reenter your name each time you use the Sites), to allow us to statistically monitor how you are using the Sites to help us improve our offerings, and to determine the popularity of certain content.

In addition to cookies that we may place on your computer or mobile device, cookies might also be placed on your computer or mobile device by third parties that we use to provide analytics-related services. In the course of providing such analytics-related services, such third-party analytics service providers could place or recognize unique cookies on your browser.

You do not have to accept cookies to use the Sites. Although most browsers are initially set to accept cookies, you may reset your browser to notify you when you receive a cookie or to reject cookies generally. Most browsers offer instructions on how to do so in the “Help” section of the toolbar. However, if you reject cookies, certain features or resources of the Sites may not work properly or at all and you may experience some loss of convenience.

For the avoidance of doubt, the Sites may use third-party service platforms (such as Adobe Analytics, including to help analyze how users use the Sites). These third-party service platforms may place cookies on your computer or mobile device. If you would like to disable “third party” cookies, you may be able to turn them off by going to the third party’s website.

“Action tags,” also known as web beacons or gif tags, are a web technology used to help track website usage information, such as how many times a specific page has been viewed. Action tags are invisible to you, and any portion of the Sites, including e-mail sent on our behalf, may contain action tags.

By using cookies and action tags together, we can gain valuable information to improve the Sites and measure the effectiveness of our marketing campaigns. We may also combine information collected from cookies with information that you may provide, such as information provided in a form that you complete.

Finally, you should be aware that third parties may use their own cookies or action tags when you click on a link to their websites or services on or from the Sites. This Privacy Policy does not govern the use of cookies or action tags or the use of your personal data by such third-party websites or services.

We also collect information through our Internet log files, which record data such as user IP addresses, browser types, domain names, and other anonymous statistical data involving use of the Sites. This information may be used to analyze trends, to administer the Sites, to monitor the use of the Sites, and to gather general demographic information. We may link this information to other information about you for these and other purposes such as personalizing your experience on the Sites and evaluating the Sites in general.

4. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data amongst and between our family of companies and Affiliates as well as our business partners for the purposes set forth in this Policy. We take commercially reasonable steps designed to ensure that such recipients use your personal data only for appropriate purposes and take appropriate measures to protect your personal data. NovaBridge Biosciences may disclose aggregate or de-identified data to third parties for our lawful business purposes.

We may employ independent contractors, vendors and suppliers (collectively, “Outside Contractors”) to provide specific services and products related to the Sites and our other offerings, including hosting and maintaining the Sites and developing applications for the Sites. In the course of providing products or services to us, these Outside Contractors may have access to information collected through the Sites and/or our other offerings, including your personal data. We use reasonable efforts to ensure that these Outside Contractors are capable of protecting the security of your personal data.

If we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a corporate sale, merger, reorganization, dissolution or similar event, we may transfer personal data that we have collected to such third party.

We reserve the right to disclose your personal data as required by law, when we believe disclosure is necessary or appropriate to comply with a regulatory requirement, judicial proceeding, court order, government request, lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process served on us, or to protect the safety, rights, or property of our customers, the public, NovaBridge Biosciences or others. We may disclose information in special circumstances when we have reason to believe that disclosing this information is necessary to identify, contact or bring legal action against someone who may be violating a contract with us, to detect fraud, for assistance with a delinquent account, or to protect the safety and/or security of our users, the Sites and/or our other offerings, our business, or the general public.

We may provide information to third parties, including where such information is combined with similar information of other users of the Sites. For example, we might inform third parties regarding the number of unique users of the Sites, the demographic breakdown of our users of the Sites, or the products and/or services purchased using the Sites and the vendors of such products and services. In addition to the above, when users use our Sites, third parties (including without limitation third-party analytics service providers and commercial partners) may directly collect information about our users’ online activities over time and across different websites. The third parties to which we may provide or who may independently directly collect information may include analytics service providers, website tracking services, and other similar parties.

We may provide your personal data to professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

5. THIRD-PARTY SITES

Our Sites may provide you with access to other websites and services. Please be aware that we are not responsible for the privacy practices of any websites or services other than the Sites. A link to a third-party website does not constitute or imply endorsement by us. Additionally, we cannot guarantee the quality or accuracy of information presented on those websites. We encourage you to read the privacy policies or statements of each and every such website and service. This Privacy Policy applies solely to personal data collected by us or on our behalf, through the Sites and, to the extent our processing of your personal data is regulated by the European Data Protection Laws or our processing of your consumer information is regulated by the CCPA, our other offerings.

6. DATA SECURITY

NovaBridge Biosciences uses technical, administrative, and procedural measures in an attempt to safeguard your personal data from unauthorized access or use. No such measure is ever 100% effective though, so we do not guarantee that your personal data will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such data. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your personal data might have been compromised), please immediately notify us by contacting us at Legal@novabridge.com.

7. CHILDREN’S PRIVACY

The Sites are not directed to individuals under the age of thirteen (13), and we do not knowingly collect personal data from children under the age of 13.

8. HOW LONG WILL WE RETAIN PERSONAL DATA?

We retain your personal data for as long as needed or permitted in light of the purpose(s) for which it was obtained or as otherwise permitted by applicable law. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you and operate the Sites and/or our other offerings; (ii) whether there is a legal obligation to which we are subject; (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations) (iv) the amount, nature, and sensitivity of your personal data; (v) the potential risk of harm from unauthorized use or disclosure; and/or (vi) the purposes for which we process your personal data and whether we can achieve those purposes through other means.

9. CHANGES TO OUR PRIVACY POLICY

From time to time, we may update this Privacy Policy. We will not make changes that result in significant additional uses or disclosures of your personal data without allowing you to “opt in” to such changes. We may also make non-significant changes to this Privacy Policy that generally will not significantly affect our use of your personal data, for which your opt-in is not required. This Privacy Policy was last updated as of the date listed above. We encourage you to periodically review this page for the latest information on our privacy practices. If any non-significant changes to this Privacy Policy are unacceptable to you, you must immediately contact us and, until the issue is resolved, stop using the Sites and/or engaging with our other offerings.

10, DATA TRANSFERS

The Sites and our other offerings are owned and operated by NovaBridge Biosciences in the United States of America. However, your personal data may be accessible or transferred to our Affiliates, vendors, and suppliers who are located in other countries. If you are visiting the Sites and/or engaging with our other offerings from a country other than the United States of America, your communication with us will necessarily result in the transfer of information across international borders. Therefore, by using the Sites and/or engaging with our other offerings, you hereby expressly consent to the transfer of your personal data outside your country or region. For clarification but not limitation, NovaBridge Biosciences is a multi-national company with offices in the United States and China. As such, NovaBridge Biosciences may transfer or provide access to your personal information to Affiliates, service providers or collaborators in these countries and others that do not provide the same level of protection as your own country. To the extent required by applicable law: whenever we transfer your personal data to third parties (as described in this Privacy Policy) located in countries that do not ensure adequate protection for your personal data (as determined by the European Commission or the UK Information Commissioner’s Office, as applicable, each, an “Inadequate Jurisdiction”), we ensure a similar degree of protection is afforded to it; we may use specific contracts approved by the European Commission (accessible at https://eur-lex.europa.eu/eli/dec_impl/2021/914/oj ), the UK Information Commissioner’s Office (accessible at https://ico.org.uk/media2/migrated/4019539/international-data-transfer-addendum.pdf ), as applicable, which give your personal data the same protection it has in the European Economic Area or the United Kingdom, as applicable, under the European Data Protection Laws; and if we rely on another basis to transfer your personal data to an Inadequate Jurisdiction, we will keep you updated or contact you if required. Please contact us if you want further information on the specific mechanisms used by us when transferring your personal data to an Inadequate Jurisdiction.

11. YOUR RIGHTS

We generally use your personal data as described in this Privacy Policy or as authorized by you or as otherwise disclosed at the time we request such personal data from you. You generally must “opt in” and give us permission to use your personal data for any other purpose. You may also change your preference and “opt out” of receiving certain marketing communications from us by following the directions provided in association with the communication or such other directions we may provide or by contacting Legal@novabridge.com.

You may update your personal data and your preferences provided through the Sites and/or in connection with our other offerings. Different programs and services may offer different phone numbers, links or preference managers that allow you to inform us of your updates and choices, including opting out of particular communications. These contact options are typically available on the Sites, but you may always contact us for assistance at Legal@novabridge.com if you have any difficulty finding these tools or otherwise updating your data or preferences.

You may choose not to provide any personal data to us; however, in doing so, you may not be able to use certain Sites and/or engage with our offerings. Please note that we may need to retain certain personal data for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. 
Under certain circumstances and in compliance with the European Data Protection Laws, you may have the right to:

• Request access to your personal data (commonly known as a ‘subject access request’). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate personal data we hold about you corrected;
• Request erasure of your personal data. This enables you to ask us to delete or remove your personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove all of your personal data in certain circumstances;
• Object to the processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground;
• Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data, for example, if you want us to establish its accuracy or the reason for processing it;
• Request the transfer of your personal data to another party; and
• Lodge a complaint with the relevant supervisory authority (as defined in the European Data Protection Laws). If you have any complaints about the way we process your personal data, please do contact us. Alternatively, you may lodge a complaint with the supervisory authority which is established in your country.

If you want to review, verify, correct or request erasure of your personal data, object to the processing of your personal data, or request that we transfer a copy of your personal data to another party, please contact Legal@novabridge.com .

To protect your privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your identity before granting you profile access or making corrections. You are responsible for maintaining the secrecy of your unique password and account information at all times.

You should be aware that it may not be technologically possible to remove each and every record of the personal data you have provided to us from our system. The need to back up our systems to protect information from inadvertent loss means that a copy of your personal data may exist in a non-erasable form that will be difficult or impossible for us to locate. After receiving your request, we will use commercially reasonable efforts to update, correct, change, or delete, as appropriate, your personal data stored in databases we actively use and other readily searchable media as appropriate, as soon as and to the extent reasonably practicable.

Please be aware that the data controllers of your personal data are the NovaBridge Biosciences entities referenced when we collect your personal data. Please contact us at Legal@novabridge.com if you have any questions about the controller or controllers of your personal data.

12. DO NOT TRACK

The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to automated Do Not Track requests. However, if you wish to stop such tracking, please contact us with your request, using our contact details provided below.

13. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

This Section 13 shall apply only to the extent that we are regulated as a business (as defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively with any regulations promulgated thereunder, the "CCPA")) under the CCPA. This Section 13 shall apply to you only if you are a California resident. Upon request, alternative formats of this Privacy Policy are available to individuals with a disability.

As used in this Section 13, “sell” (including any grammatically inflected forms thereof) means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information (as defined below) to a third party for monetary or other valuable consideration.

As used in this Section 13, “share” (including any grammatically inflected forms thereof) means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, consumer information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions with a third party for cross-context behavioral advertising for our benefit in which no money is exchanged.

The terms “selling” and “sharing” do not include (i) disclosing consumer information to a third party at your direction, (ii) where you intentionally interact with one or more third parties, or (iii) transfers of your consumer information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of NovaBridge, provided that the information is used or shared consistently with the CCPA.

13.1 Consumer Information Collected

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with particular California residents or households (“consumer information”). Consumer information does not include deidentified or aggregated information, publicly available information or lawfully obtained, truthful information that is a matter of public concern, or any other information that is excepted from the definition of “personal information” under the CCPA, or any information that is otherwise not regulated by the CCPA. For purposes of this Section 13.1, “publicly available information” means information that is lawfully made available from federal, state, or local government records, or information that we have a reasonable basis to believe is lawfully made available to the general public by you or from widely distributed media, or information made available by a person to whom you have disclosed the information if you have not restricted the information to a specific audience. 

For purposes hereof, "sensitive consumer information" means: (1) consumer information that reveals (A) your social security, driver's license, state identification card, or passport number; (B) your account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; (C) your precise geolocation; (D) your racial or ethnic origin, religious or philosophical beliefs, or union membership; (E) the contents of your mail, email, and text messages, unless we are the intended recipient of the communication; (F) your genetic data; (G) your neural data; and (2)(A) consumer information consisting of biometric information processed for the purpose of uniquely identifying you; (B) consumer information collected and analyzed concerning your health; or (C) consumer information collected and analyzed concerning your sex life or sexual orientation. We do not use or disclose your sensitive consumer information.

To the extent we consider Deidentified Data outside the scope of the CCPA because it is not identifiable, then, to the extent required by the CCPA, NovaBridge hereby publicly commits to process Deidentified Data in its possession only in a de-identified fashion and not attempt to re-identify such Deidentified Data. “Deidentified Data” means data that cannot reasonably be used to infer information about, and that cannot reasonably be linked to, an identified or identifiable California resident.

In particular, with respect to the Sites and, to the extent our processing of your consumer information is regulated by the CCPA, our other offerings, we have collected the following categories of consumer information from California residents or households within the last twelve (12) months and, in connection therewith, we may collect the following categories of consumer information from California residents or households:
 

13.2 Purposes for Collection of Consumer Information; Categories of Sources

We collect consumer information for the business or commercial purposes described in the tables above and in the manner described in Sections 2 and 3 of this Privacy Policy with respect to your personal data. Regarding the categories of sources from which consumer information is collected, we collect consumer information from the categories of sources described in the tables above and in the manner described in Sections 1 and 2 of this Privacy Policy with respect to your personal data.  

13.3 Disclosures of Consumer Information for a Business or Commercial Purpose

NovaBridge may disclose your consumer information described in the tables above to a third party for a business or commercial purpose, as described in the tables above and in Sections 3 and 4 of this Privacy Policy with respect to your personal data.

13.4 Sharing and Sales of Consumer Information

In the preceding twelve (12) months, NovaBridge has not shared or sold, nor does it or will it share or sell consumer information.

13.5 California Residents’ Rights and Choices

The CCPA provides California residents with specific rights regarding their consumer information. This Section describes your CCPA rights (to the extent applicable to you) and explains how to exercise those rights.

13.5.1 Access to Specific Information and Data Portability Rights

You may have the right to request that NovaBridge disclose certain information to you about our collection and use of your consumer information over the past twelve (12) months or such other period required by the CCPA. Once we receive and confirm your verifiable consumer request (in the manner described in Section 13.6 below), to the extent required by the CCPA, we will disclose to you:  

• The categories of consumer information we collected about you.
• The categories of sources for the consumer information we collected about you.
• Our business or commercial purpose for collecting that consumer information.
• The categories of third parties to whom we disclose that consumer information.
• The specific pieces of consumer information we collected about you (also called a data portability request).
• If we disclosed your consumer information for a business or commercial purpose, a list disclosing disclosures for a business or commercial purpose, identifying the categories of recipients to whom such consumer information was disclosed and the consumer information categories that each category of recipient obtained.

 13.5.2 Deletion Request Rights

You have the right to request that NovaBridge delete any of your consumer information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm a verifiable request from you or your authorized agent (in each case if you are a California resident) in the manner described in Section 13.6 below (“verifiable consumer request”), we will delete (and notify our service providers and/or contractors to delete, unless this proves impossible or involves disproportionate effort) your consumer information from our records, unless an exception applies or retention of your consumer information is otherwise permitted by the CCPA. We may deny your deletion request if retaining the information is reasonably necessary for us or our service provider(s) and/or contractor(s) to:  

• Complete the transaction for which we collected the consumer information, provide a product or service that you requested, take actions reasonably anticipated by you within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
• Help to ensure security and integrity to the extent the use of your consumer information is reasonably necessary and proportionate for those purposes.
• Debug to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise that consumer’s free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the ability to complete the research, if you have provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us and compatible with the context in which you provided the information.
• Comply with a legal obligation.

13.5.3 Correction Request Rights

You have the right to request that we correct inaccurate consumer information about you that we maintain, taking into account the nature of the consumer information and the purposes of the processing of the consumer information. If we receive a verifiable consumer request from you to correct inaccurate consumer information, we will use commercially reasonable efforts to correct such inaccurate consumer information as directed by you, pursuant to Section 1798.130 of the CCPA and regulations adopted pursuant to the CCPA.  

13.6 Exercising Access, Data Portability, Correction, and Deletion Rights

To exercise the access, data portability, correction, and deletion rights described in Section 13.5 above, please submit a verifiable consumer request to us by contacting us at Legal@novabridge.com. Only you, or someone legally authorized to act on your behalf (such as an authorized agent), may make a verifiable consumer request related to your consumer information. Someone legally authorized to act on your behalf (such as an authorized agent) may make a verifiable consumer request on your behalf, provided that you have duly authorized that person or entity to make such a verifiable consumer request on your behalf and provided that that person or entity can provide verification of their authority to make such a request on your behalf where required. You may also make a verifiable consumer request on behalf of your minor child. You may make a verifiable consumer request for access or data portability no more than twice within a twelve (12) month period.

The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected consumer information or an authorized agent; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with consumer information if we cannot verify your identity or authority to make the request and confirm the consumer information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use consumer information provided for the purposes of verification of a consumer request to verify the requestor's identity or authority to make the request. We use the following process to verify consumer requests: In the event you make a request under this Section, we may take various approaches to verify your identity depending on the nature of your request. These approaches may include initiating video conferencing or telephone calls with you or reaching out to you by email or otherwise to ask you questions pertaining to the information we have about you.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to ninety (90) days), we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your consumer information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. If your requests are manifestly unfounded or excessive, in particular because of their repetitive character, we may either charge a reasonable fee, taking into account the administrative costs of providing the information or communication or taking the action requested, or refuse to act on the request and notify you of the reason for refusing the request.

13.7 Non-Discrimination

• We will not discriminate against you for exercising any of your CCPA rights, including, unless permitted by the CCPA, by:
• Denying you goods or services;
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
• Providing you a different level or quality of goods or services;
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services; or
• Retaliating against an employee, applicant for employment, or independent contractor, as defined in subparagraph (A) of paragraph (2) of subdivision (m) of Section 1798.145 of the CCPA for exercising their rights under the CCPA.

13.8 Consumer Information Retention

We will only retain your consumer information for as long as necessary to fulfill the purposes for which we collected it or as otherwise permitted by applicable law. To determine the appropriate retention period for consumer information, we consider the amount, nature, and sensitivity of that consumer information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process your consumer information and whether we can achieve those purposes through other means, and the applicable legal requirements.

 13.9 Contact

If you have any questions or concerns relating to this Privacy Policy and/or our consumer information practices, please contact us at Legal@novabridge.com.