Privacy Policy

Effective November 2023

I. Scope of this Privacy Statement

 

This Privacy Statement describes the types of personal information LNHC, Inc. (“Novan,” “us,” “we” or “our”) collects through www.novan.com, (the “Site”), and how we collect, use, and share that information.  This Privacy Statement does not govern our collection of personal information through any website or other means, other than through the Site.

By using the Site, you explicitly accept, without limitation or qualification, our practices surrounding the collection, use, and sharing of personal information provided by you in the manner described in this Privacy Statement. If you do not agree with the terms of this Privacy Statement, please do not access, browse, or use the Site.

 

II. Personal Information We Collect

 

A. Information You Give Us

You do not have to give us any personal information to browse this Site.  However, you may be asked to provide personal information to submit or request information from us, or to use the services offered through this Site.  This information may include information such as your name, e-mail address, postal address, company affiliation, and areas of interest. Once you provide us with personal information about you, you are no longer anonymous to us.

 

B. Automated Information Collection

We may collect certain information about your use of the Site through the use of tracking technologies or by other passive means. This “passively collected” information includes, but is not limited to, the domain name of the website that allowed you to navigate to the Site, search engines used, the internet protocol (IP) address used, the length of time spent on the Site, the pages you looked at on the Site, other websites you visited before and after visiting the Site, the type of internet browser you have, the frequency of your visits to the Site, and other relevant statistics, including the following:

    • Log Information. When you access the Site, our servers automatically record information that your browser sends whenever you visit a website. These server logs may include information such as your web request, IP address, browser type, browser language, the date and time of your request, and one or more cookies (small text files containing a string of characters) that may uniquely identify your browser.
    • Links. The Site may include links in a format that enables us to keep track of whether these links have been followed by IP addresses. We use this information to improve the quality of our products and design.
    • Cookies. When you visit or access the Site, we send one or more cookies (small text files containing a string of characters) to your computer that uniquely identifies your browser. We use cookies to improve the quality of the Site by storing user preferences and tracking user trends. Most web browsers accept cookies automatically but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. Please note that if you disable cookies, you may not be able to use some customized features available through the Site.
    • Web Beacons. Web beacons (also known as “pixel tags” or “clear GIFs”) are 1×1 single-pixel graphics that allow us to count the number of users who have visited or accessed the Site and to recognize users by accessing our cookies. We may employ web beacons to facilitate Site administration and navigation, to track the actions of users of the Site, to compile aggregate statistics about Site usage and response rates, and to provide an enhanced online experience for visitors to the Site.  We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened.

 

III. How We Use Personal Information

 

Personal information collected through the Site may be used by Novan and its affiliates for purposes of:

    • Responding to your questions;
    • Providing the information you request through this Site;
    • Contacting you, whether by email, postal mail, or telephone with information about this Site or our services;
    • For such purposes as you may authorize at the time you submit the information;
    • Auditing, research, and analysis to maintain, protect, and improve this Site and our service;
    • Creating a profile based on the information you have provided;
    • Ensuring the technical functions of our network;
    • Improving and customizing the content and layout of the Site;
    • Developing new products and services; or
    • Compiling personal information and other information collected through the Site on an aggregate basis

 

IV. Personal Information We Share

 

We do not sell, rent, trade, or otherwise share personal information collected through the Site, except as described below:

  • Subsidiaries and Affiliates.  We may share personal information with our subsidiaries and affiliates for the purposes for which you provided the information or as reasonably necessary for our internal administrative and business purposes.
    • Service Providers.  We work with third parties that provide services on our behalf. Such services may include website hosting, marketing, and website usage analytics.  We may share personal information and non-personal information with these third parties for the purpose of enabling them to provide these services.
    • Consent.  We may share personal information in accordance with any consent you provide.
    • Required by Law. We may disclose personal information or any information collected through this Site if we are required to do so by law or pursuant to legal process, in response to a request from government officials or law enforcement authorities, or as necessary or appropriate in connection with an investigation of illegal activity.
    • Certain Transactions. We may disclose or transfer personal information or any information collected through this Site to third parties who acquire all or a portion of Novan’s business, whether such acquisition is by way of merger, consolidation, or purchase of all or a portion of our assets, or in connection with any bankruptcy or reorganization proceeding brought by or against us.

 

V. Aggregate Information 

 

We may compile personal information and other information collected through the Site on an aggregate basis. This information may include, without limitation, the number of users who have registered for the Site, demographic information about users of the Site, and individual purchase preferences.  Such aggregate information does not identify you individually. We may use aggregate information and share aggregate information with third parties for any of the purposes specified in this Privacy Statement, and for any other lawful purpose.

 

VI.  Your Choices

 

A. Information You Provide

You can always choose whether or not to provide information on the Site.  However, if you choose not to disclose certain information, you may not be able to register as a user of the Site, which may limit your access to certain portions of the Site.

 

B. Communications From Us

If at any time you decide that you no longer wish to receive notices from us regarding the Site, you may indicate this preference by contacting us at contact@novan.com.

 

VII. Information Storage and Security

 

We employ reasonable security precautions to protect personal information about you. The Site is operated from a secure environment with integrated security measures to help protect against the loss, misuse, and alteration of personal information provided on or through the Site. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect personal information about you, we cannot guarantee the security of any information you transmit to us through or in connection with the Site. If you have reason to believe that personal information is no longer secure, please notify us immediately by contacting us in accordance with the last section below.

 

VIII. A Special Note about Children

Under Age 13

Novan understands the importance of protecting children’s privacy in the interactive online world. The Site is not designed for, or intentionally targeted at, children under 13 years of age. It is not our policy to intentionally collect or maintain information about anyone under the age of 13.  No one under the age of 13 should submit any personal information to Novan or the Site.

Under Age 18

Minors under 18 years of age may have the personal information that they have provide to Novan through the Site deleted by sending an email to contact@novan.com requesting deletion.  Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.

 

IX. External Links

 

The Site may contain links to various websites that Novan does not control.  When you click on one of these links, you will no longer be transacting business through the Site. Third party websites maintain their own privacy policies, and we do not exercise any control over any of the third party websites that may be linked to the Site. If you visit a website that is linked to the Site, you should consult that website’s privacy policy before providing any personal information. Please be aware that we are not responsible for the privacy practices of such other websites, and we are not liable for their misuse of personal information about you.

 

X. State-Specific Privacy Notice

 

If you are a resident of California (including California business contacts), Colorado, Connecticut, Utah, or Virginia, the law in your state (collectively, the “State Privacy Laws”) provides you with the following rights with respect to your personal information:

Your California, Colorado, Connecticut, Utah, and Virginia Privacy Rights

  • The right to know what personal information we have collected, used, disclosed, and sold about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom Novan discloses personal information, and the specific pieces of personal information Novan has collected about you.
  • The right to obtain a copy of personal information we have obtained about you in a portable and, to the extent technically feasible, readily usable format.
  • The right to correct inaccurate personal information about you, taking into account the nature of the personal information and the purposes of the processing.
  • The right to request that we delete any personal information we have about you.
  • If we deny your request, the right to appeal our decision.

In addition, and as set forth below, California law requires us to identify, for the 12-month period prior to the date of this Privacy Policy, what information we may have “sold” or “shared” about you. For the 12-month period prior to the date of this Privacy Policy, we have not sold or shared any personal information about our customers.  We do not use or disclose Sensitive Personal Information, as defined in applicable laws, for any purposes other than those permitted by applicable law.

Submitting Requests

If you are a resident of California, Colorado, Connecticut, Utah, or Virginia, you may submit your requests to opt out, correct, delete, and/or to know/obtain Personal Information we have collected about you by contacting us via email at contact@novan.com or by contacting 833-757-4630

We will respond to your request in compliance with the requirements of your state’s applicable laws.  Please note that we are only required to honor California requests to know twice in a 12-month period.

Verification of Your Identity

When you exercise these rights and submit a request to us, we will verify your identity by asking you to provide us with additional information such as your email address, order numbers of previous orders of our products and services, the last four digits of a credit or debit card used to make a purchase, or the date or your last purchase from us.  We also may use a third-party verification provider to verify your identity.

Appeal

Residents of Colorado, Connecticut, and Virginia may appeal a decision we have made regarding their requests by calling us at 833-757-4630 or by emailing us at contact@novan.com.  We will respond to appeals from Virginia and Connecticut residents within 60 days.  We will respond to appeals from Colorado residents within 45 days.

Non-Discrimination

If you make a request under your state privacy law, we will not discriminate against you in any way.  For example, we will not deny you discounts or other benefits or impose penalties on you or provide you with or suggest that you will receive a different level or quality of benefits or services.

Authorized Agents

You may permit an authorized agent to submit a request to know or to delete your personal information.  If we receive a request on your behalf, we will ask that person to give us proof that you gave that person written permission to make a request for you.  If that person does not provide us with written proof, we will deny their request so that we can protect your personal information.

Automated Decision-Making

We generally do not use automated decision-making technology, as that term is defined by State Privacy Laws. If we make use of automated decision-making technology, you will be informed through a separate privacy notice.

Record Retention

We may retain your personal information for as long as necessary to fulfil the purpose for which it was collected or to comply with legal or regulatory requirements. We strive to retain your personal information no longer than is reasonably necessary to carry out the purposes listed in this Privacy Policy or as required by law.  We retain your personal information following the end of your services or other business relationship in accordance with applicable law and our data retention and destruction policies.

XI. Response to “Do Not Track” Signals


Some Internet browsers include the ability to transmit “Do Not Track” signals.  Since uniform standards for “Do Not Track” signals have not yet been adopted, Novan does not process or respond to “Do Not Track” signals.

XII. Special Admonitions for International Use


The Site is hosted in the United States. All matters relating to the Site are governed exclusively by the laws of the State of North Carolina in the United States of America and not the jurisdiction in which you are located. If you are located outside of the United States of America and you contact us, please be advised that any information you provide to us will be transferred to the United States of America and that by submitting information, you explicitly authorize such transfer.

 

XIII. Updates to this Privacy Statement

 

We may change or update the Site or any of our policies and procedures without prior notice. We will post a notice on this Site to advise you of any significant changes to this Privacy Statement and indicate via the Effective Date legend at the top of this Privacy Statement when it was most recently updated. Your continued use of the Site signifies your continued assent to the terms of this Privacy Statement, as updated or amended at that time.

 

XIV. Questions Regarding this Privacy Statement

 

If you have any questions or comments regarding this Privacy Statement, please send us an email at contact@novan.com