NovaLife Nutriments LLC

A NovaLife Ventures Company

Privacy Policy

Last Updated: June 2025

NovaLife Nutriments LLC ("NovaLife Nutriments," "we," "us," or "our"), a NovaLife Ventures company, operates this website and all associated platforms, portals, content, features, tools, products, and services (collectively, the "Services") to facilitate commercial transactions, support client and partner relationships, and deliver institutional-grade ingredient supply solutions to businesses across the consumer packaged goods industry. Our Services are powered by Shopify.

This Privacy Policy describes how we collect, use, process, and disclose personal information when you visit, access, or interact with the Services, engage in any commercial transaction, or otherwise communicate with us in the course of our business operations. If there is a conflict between our Terms of Service and this Privacy Policy, this Privacy Policy shall govern with respect to the collection, processing, and disclosure of personal information.

By accessing or using any of the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you are accessing the Services on behalf of an organization, you represent and warrant that you have the authority to bind that organization to this Privacy Policy.

Personal Information We Collect

When we use the term "personal information," we mean information that identifies, relates to, describes, or can reasonably be linked to an identifiable individual or business representative. Personal information does not include information that has been collected anonymously, aggregated, or de-identified such that it cannot reasonably be linked to an individual.

Depending on how you interact with the Services, we may collect or process the following categories of personal information, as permitted by applicable law:

• Contact and Business Information, including name, title, role, company or organization name, billing address, shipping address, email address, and phone number

• Transaction and Order Information, including products or ingredients viewed, quoted, sampled, purchased, returned, or canceled, as well as order history, invoicing records, and account activity

• Account and Credentialing Information, including login credentials, account preferences, communication preferences, and portal settings

• Payment and Financial Information, including payment confirmation, transaction details, and billing records (payment card data is processed exclusively by our third-party payment processors and is not stored on our systems)

• Communications and Correspondence, including information provided through customer support inquiries, sales communications, vendor coordination, or any other business correspondence

• Device and Network Information, including IP address, browser type and version, operating system, device identifiers, referring URLs, and approximate geographic location derived from IP address

• Usage and Behavioral Information, including pages viewed, interactions with the Services, navigation patterns, session duration, click activity, and other browsing or engagement data

• Regulatory and Compliance Records, including documentation submitted or exchanged in connection with quality assurance, food safety compliance, Good Manufacturing Practice (GMP) verification, Certificate of Analysis (COA) requests, or FDA-related correspondence

Sources of Personal Information

We may collect personal information from the following sources:

• Directly from you when you access the Services, submit an inquiry, place an order, create an account, request a quote, or otherwise communicate with us

• Automatically through the Services, including through cookies, pixels, web beacons, and similar tracking technologies deployed on or in connection with the Services

• From service providers who collect, process, or store information on our behalf in connection with the operation of the Services

• From business partners, distributors, and commercial counterparties in connection with ongoing supply, distribution, or procurement relationships

• From advertising, analytics, and marketing platforms or other third parties, as permitted by applicable law

Cookies and Tracking Technologies

We and our service providers use cookies, pixels, web beacons, clear gifs, and similar tracking technologies (collectively, "Cookies") in connection with the Services. Cookies enable us to collect information such as browser type, session duration, pages visited, language preferences, unique identifiers, and other usage and traffic data.

We use Cookies for purposes including: operating and improving the Services; personalizing your experience; understanding usage patterns, trends, and engagement; measuring the effectiveness of our marketing and advertising activities; serving relevant advertisements; maintaining security; and facilitating analytics.

The Services may incorporate tracking technologies provided by third parties, including but not limited to Google Analytics, Meta Pixel (Facebook), TikTok Pixel, Klaviyo, and similar platforms. These third parties may collect information about your online activity over time and across different websites, platforms, and services. The information collected by these technologies is subject to the privacy policies of the respective third-party providers.

When you first visit the Services, you may be presented with a cookie consent mechanism that allows you to accept or manage your cookie preferences. You may update your preferences at any time through the cookie settings available on our website. Most browsers also allow you to decline cookies or manage preferences through browser settings. You may also visit http://optout.aboutads.info/ and http://optout.networkadvertising.org/ to learn more about opt-out options. If you disable or decline non-essential cookies, certain features of the Services may not function as intended. It is your responsibility to manage your cookie preferences through the mechanisms described above.

How We Use Your Personal Information

We may use personal information for the following purposes:

Provide, Operate, and Improve the Services

To process orders and transactions; fulfill and coordinate shipments; manage client and partner accounts; facilitate returns, credits, and adjustments; communicate regarding orders, accounts, or service updates; and continuously improve the functionality, performance, and reliability of the Services.

Client and Partner Relationship Management

To manage ongoing commercial relationships with clients, distributors, co-packers, and supply chain partners; coordinate sampling, quoting, and procurement activities; and support onboarding and account management processes.

Marketing and Business Development

To send marketing, promotional, and business development communications and to display advertisements for our products and services, including on third-party platforms, based on interactions with the Services, where permitted by applicable law.

Quality Assurance and Regulatory Compliance

To maintain records related to product quality, ingredient traceability, batch documentation, Certificate of Analysis (COA) records, Good Manufacturing Practice (GMP) compliance, and applicable FDA regulatory requirements; and to respond to quality inquiries, audits, or regulatory requests in the ordinary course of business.

Security, Fraud Prevention, and Risk Management

To detect, investigate, and prevent fraudulent, illegal, unauthorized, or otherwise harmful activity; to protect the integrity and availability of the Services; and to secure commercial transactions and proprietary business information.

Communications and Support

To respond to inquiries, provide support, and maintain effective communication with clients, partners, and other stakeholders.

Legal and Compliance Obligations

To comply with applicable federal, state, and local laws, regulations, and legal processes; to enforce or defend our rights, terms, and policies; and to respond to lawful requests from governmental authorities.

Analytics, Insights, and Business Operations

We may collect, use, process, disclose, and otherwise leverage personal information for our legitimate business and commercial purposes, including but not limited to operating, maintaining, evaluating, improving, developing, and monetizing our products and Services; conducting analytics, research, and data analysis; developing new products, formulations, and service offerings; supporting marketing and advertising activities; advancing business operations, partnerships, growth, and strategy; and for other purposes reasonably related to the operation and expansion of our business, to the extent permitted by applicable law.

Where required by law, individuals may have the right to limit or opt out of certain uses or disclosures of their personal information through available privacy controls, including platform-provided opt-out mechanisms.

How We Disclose Personal Information

We may disclose personal information in the following circumstances:

• With Shopify and other service providers that perform services on our behalf, including but not limited to payment processing, analytics, order fulfillment, logistics, customer support, cloud storage, and IT infrastructure

• With advertising networks, social media platforms, and marketing partners to provide advertising and promotional services, including targeted advertising based on your interactions with the Services

• When you direct or consent to the disclosure, for example through integrations, shared portals, or collaborative business tools

• With NovaLife Ventures and affiliated entities within our corporate group for internal business purposes, operational coordination, and shared services, consistent with this Privacy Policy

• In connection with a business transaction such as a merger, acquisition, restructuring, joint venture, financing, or sale of assets, in which personal information may be among the assets transferred or disclosed

• With third-party data partners for analytics, data enrichment, or other commercial purposes, to the extent permitted by applicable law

• To comply with legal obligations or to protect the rights, safety, property, and security of NovaLife Nutriments, NovaLife Ventures, our clients, partners, or others

Third-Party Advertising

We may use third-party advertising companies to serve advertisements regarding products and services that may be relevant to you when you access the Services and other websites or online platforms. These companies may place or recognize cookies on your browser and use information about your visits to the Services and other websites to serve targeted advertisements. They may also use these technologies, along with information they collect about your online activity, to recognize you across the devices you use.

To learn more about targeted advertising and your opt-out options, you may visit http://optout.aboutads.info/ and http://optout.networkadvertising.org/.

Third-Party Payment Services

The Services may provide functionality allowing you to make payments using third-party payment services. When you use such a service, your personal information will be collected by that third party and will be subject to the third party's privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, any third party's collection, use, or disclosure of your personal information in connection with such payment services.

Relationship with Shopify

The Services are hosted by Shopify. Shopify collects and processes personal information related to your access to and use of the Services in order to provide and improve Shopify's platform and services. Information submitted through the Services may be shared with Shopify and other third parties located in different jurisdictions.

Certain Shopify features may involve Shopify processing personal information independently. In such cases, Shopify is responsible for responding to requests regarding those processing activities. To learn more, visit the Shopify Consumer Privacy Policy.

Third-Party Websites and Links

The Services may contain links to third-party websites, platforms, or resources. We are not responsible for the privacy practices, content, or security of any third-party websites or platforms. Any information you provide to third-party platforms is governed by their respective privacy policies, and we encourage you to review those policies before submitting personal information.

Sensitive Information

Unless we specifically request it, we ask that you not send us, and you not disclose, any sensitive personal information (such as health or medical information, social security numbers, information related to racial or ethnic origin, political opinions, religion, or criminal background) on or through the Services or otherwise to us. Where you choose to provide such information voluntarily (for example, through support communications or regulatory documentation), you consent to our processing of that information in accordance with this Privacy Policy and applicable law.

Children's Data

The Services are intended for business use and are not directed at individuals under the age of 13. We do not knowingly collect personal information from children under 13. If you believe a child has provided us with personal information, please contact us at compliance@novalifeventures.com to request deletion.

Security and Retention

We implement reasonable organizational, technical, and administrative safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, or destruction. However, no method of electronic transmission or data storage is completely secure, and we cannot guarantee absolute security.

Personal information is retained for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with applicable legal, regulatory, and contractual obligations, resolve disputes, and enforce agreements. Retention periods are determined based on factors including: the duration of our ongoing business relationship with you; applicable legal and regulatory retention requirements, including but not limited to FDA record-keeping obligations and GMP documentation standards; and whether retention is advisable in light of our legal position, including with respect to applicable statutes of limitations, litigation, regulatory inquiries, or audit requirements.

International Transfers

Your personal information may be transferred to and processed in countries other than the country in which you reside, including the United States. By using the Services, you understand and acknowledge that your information may be transferred to jurisdictions that may have data protection frameworks different from those applicable in your country of residence.

Your Rights and Choices

If you no longer wish to receive marketing-related emails from us, you may opt out by following the unsubscribe instructions included in any such communication.

We will endeavor to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of marketing communications, we may still send you important administrative, transactional, or regulatory communications, from which you cannot opt out.

If you would like to update personal information that you have provided to us, you may do so through your account portal or by contacting us using the information provided below.

If you are a U.S. consumer or business representative, please see the section below titled "Additional Information for U.S. Consumers" for further information on your privacy rights and choices.

Additional Information for U.S. Consumers

Pursuant to applicable U.S. state consumer privacy laws, including but not limited to those enacted in California, Colorado, Connecticut, New Jersey, Virginia, and other states with active consumer privacy statutes, we provide the following additional disclosures.

Sale and Sharing of Personal Information

We may sell or share personal information (as those terms are defined under applicable state laws) with third parties, including advertising networks, social media platforms, data analytics providers, and marketing partners. The categories of personal information that may be sold or shared include: identifiers (such as name, email address, and IP address), commercial information (such as transaction and purchase history), internet or network activity information (such as browsing behavior and interactions with the Services), and geolocation data (such as approximate location derived from IP address).

We do not knowingly sell or share personal information of consumers under 16 years of age.

Your Consumer Privacy Rights

Depending on your state of residence, you may have the following rights with respect to your personal information, subject to applicable law:

• Right to Know. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the sources from which it was collected, the purposes for which it was collected, and the categories of third parties with whom it was shared or to whom it was sold.

• Right to Delete. You may request that we delete your personal information, subject to certain legal and regulatory exceptions.

• Right to Correct. You may request that we correct inaccurate personal information that we maintain about you.

• Right to Portability. You may request a copy of your personal information in a structured, commonly used, and machine-readable format.

• Right to Opt Out of Sale or Sharing. You may request that we stop selling or sharing your personal information for targeted advertising purposes.

• Right to Non-Discrimination. You have the right not to receive discriminatory treatment for exercising any of your privacy rights.

How to Exercise Your Rights

To exercise any of the rights described above, please contact us at:

• Email: compliance@novalifeventures.com
• Phone: (908) 219-7665

We will verify your identity before processing your request, which may require you to provide your name, email address, and your relationship with NovaLife Nutriments. We will respond to your request consistent with applicable law. We may decline to honor a request where a legal or regulatory exception applies.

If you wish to opt out of the sale or sharing of your personal information for targeted advertising, you may do so by: (1) visiting our Data Sharing Opt-Out Page; (2) emailing compliance@novalifeventures.com with the subject line "Do Not Sell or Share My Personal Information"; or (3) enabling an opt-out preference signal, such as the Global Privacy Control (GPC), in your browser. We will process your request consistent with applicable law. Please note that opt-out requests are specific to the browser or device from which the request is made. If you use multiple browsers or devices, you may need to opt out on each one separately.

We honor opt-out preference signals, including the Global Privacy Control (GPC), as a valid request to opt out of the sale or sharing of personal information for targeted advertising, in accordance with applicable state laws. When we detect a GPC signal from your browser, we will treat it as an opt-out request for that browser and device. For information about how to enable the Global Privacy Control, visit https://globalprivacycontrol.org/.

Authorized Agents

If an authorized agent would like to submit a request on your behalf as permitted under applicable law, the agent may contact us at compliance@novalifeventures.com. We may require documentation verifying the agent's authorization and may require you to verify your identity directly with us.

Appeal Process

If we decline to take action on your request, you may appeal our decision by contacting us at compliance@novalifeventures.com within a reasonable period after receiving notice of the refusal. We will respond to your appeal consistent with applicable law.

De-Identified Information

Where we maintain or use de-identified information, we will continue to maintain and use it only in a de-identified fashion and will not attempt to re-identify the information, except as permitted by applicable law.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations. Changes will be posted on the Services with an updated "Last Updated" date. Your continued use of the Services following the posting of any changes constitutes your acceptance of the updated Privacy Policy.

Contact

If you have questions about this Privacy Policy, our privacy practices, or wish to exercise any of your rights, please contact us at:

NovaLife Nutriments LLC, A NovaLife Ventures Company

General Inquiries: Email: support@novalifeventures.com Phone: (908) 219-7665

Privacy, Compliance, and Data Rights: Email: compliance@novalifeventures.com

Mailing Address: 233 Mt. Airy Road, 1st Floor Basking Ridge, NJ 07920