Privacy Policy

Last Updated: November 7, 2026
Effective Date: November 7, 2026

1. Who We Are

This Privacy Policy describes how Cyber CommerceX LLC, a Wyoming limited liability company doing business as NovaMane Ventures ("NovaMane," "we," "us," or "our"), collects, uses, discloses, and protects personal information when you visit novamane.com and its subdomains (including our Help Center and Auto-Ship member portal), purchase or use our products, contact our support team, receive our emails or text messages, take part in our loyalty or referral programs, or otherwise interact with us, including on social media (together, the "Services").

Cyber CommerceX LLC is the business (or "controller") responsible for your personal information.

Contact: Cyber CommerceX LLC (d/b/a NovaMane Ventures), 312 W 2nd St, Unit A2299, Casper, WY 82601, United States. Email: support@novamane.com. Phone: (855) 746-7270.

This Privacy Policy is incorporated into our Terms of Service. If you do not agree with it, please do not use the Services.

2. Summary

• We collect the information you give us (such as your name, contact details, orders, and messages), information collected automatically when you use our website (such as device data, browsing activity, and cookies), and information from our partners (such as payment processors and advertising platforms).
• We use it to process orders and Auto-Ship deliveries, provide support, honor our guarantee, prevent fraud, improve our website and products, and market to you.
• We do not sell your information for money. We do use advertising and analytics partners, which some U.S. state laws treat as a "sale" or "sharing" of personal information. You can opt out at any time at Your Privacy Choices, and we honor Global Privacy Control signals.
• Information about your hair, scalp, or hair loss, and any before-and-after photos you send us, are treated as health-related information with extra protections (see Section 8).
• Depending on where you live, you have rights to access, correct, delete, and port your information, and to opt out of certain uses (see Sections 10 to 13).

3. Information We Collect

3.1 Information you provide to us

3.2 Information collected automatically

When you use our website, we and our partners automatically collect:

• Device and connection information: IP address, browser type, operating system, device identifiers, language, and general location (city, region, or country) derived from your IP address.
• Browsing and interaction information: pages viewed, products viewed, links clicked, referring URL, search terms, time on page, cart activity, and email or SMS open and click activity.
• Session replay information: we use tools such as Microsoft Clarity to understand how visitors use our website, including page views, scrolling, mouse movements, and clicks. We configure these tools to mask information you type into form fields and do not permit them to be used for advertising.
• Cookies, pixels, and similar technologies as described in Section 7.

3.3 Information from other sources

We receive information from: payment processors and fraud-prevention services (for example, transaction approval and fraud risk signals); shipping carriers and fulfillment partners (for example, delivery status); our subscription, loyalty, and referral platforms; advertising and social media platforms (for example, aggregated campaign performance and, where you interact with our ads, identifiers and interaction data); marketplaces and retail partners; and publicly available sources.

3.4 Inferences

We may create inferences from the information above, such as your likely product interests, purchase timing, or Auto-Ship status, to personalize our marketing and website. We do not use health-related information to create inferences for advertising.

4. How We Use Personal Information

We use personal information to:

1. Provide the Services: process and ship orders, operate Auto-Ship (including recurring billing, renewal reminders, and cancellation), process returns, refunds, replacements, and guarantee requests, and manage your account.
2. Communicate with you: send order confirmations, shipping updates, Auto-Ship acknowledgments and reminders, notices of price or policy changes, and respond to your questions.
3. Marketing: send marketing emails and text messages where you have consented or where permitted by law, show you advertising on other websites and platforms, measure ad performance, and run loyalty, rewards, and referral programs.
4. Improve and personalize: analyze how the Services are used, fix problems, develop products, and personalize content.
5. Safety, security, and fraud prevention: detect and prevent fraud, payment abuse, promotion abuse, and chargeback abuse, and protect the Services, our customers, and our rights.
6. Legal and compliance: comply with laws, tax and accounting obligations, and lawful requests; respond to payment disputes; and enforce our Terms of Service.
7. Business transfers: evaluate or complete a merger, acquisition, financing, reorganization, or sale of assets.

We will not use your personal information for purposes materially different from those described here without notifying you and, where required, obtaining your consent.

5. How We Disclose Personal Information

We disclose personal information to the following categories of recipients:

• Service providers and processors that act on our behalf under contract, including e-commerce platform and hosting, payment processing, subscription billing and member portal, order fulfillment and shipping, shipment protection, customer support and help desk, email and SMS delivery, reviews, loyalty and referral programs, analytics and session replay, privacy request management, data warehousing and reporting, fraud prevention, and professional advisors (such as accountants, bookkeepers, and lawyers).
• Advertising and analytics partners (for example, Meta, Google, and TikTok) that receive identifiers and browsing and interaction information through cookies, pixels, and server-side integrations to measure and deliver advertising. Some of these partners use the information for their own purposes as well. This is the disclosure that some U.S. state laws call a "sale," "sharing," or "targeted advertising." See Section 11 to opt out.
• Payment card networks and issuers, when you dispute a charge (see our Terms of Service, Section 14).
• Marketplaces and partners, where you purchase through them or interact with a co-branded offer.
• Government authorities and others, when required by law, subpoena, or court order, or when we believe disclosure is necessary to protect rights, property, or safety, or to prevent fraud.
• Successors, in connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business.
• Others with your consent or at your direction.

We do not sell or share health-related information, including before-and-after photos, for advertising or for monetary consideration. We do not sell personal information for money.

6. Text Messages (SMS)

If you opt in to text messages, we will send recurring automated marketing and order-related messages to the mobile number you provide. Consent is not a condition of purchase. Message frequency varies. Message and data rates may apply. Reply STOP to opt out or HELP for help. We do not share your mobile number or SMS opt-in consent with third parties or affiliates for their own marketing purposes. SMS terms are also set out in Section 24 of our Terms of Service.

7. Cookies, Pixels, and Similar Technologies

We and our partners use cookies, pixels, tags, software development kits, and server-side integrations to:

• Operate the website (strictly necessary): keep your cart, process checkout, and maintain security;
• Analytics and performance: understand how the website is used (for example, Google Analytics and Microsoft Clarity);
• Advertising: measure ad performance and show you relevant ads on other websites and platforms.

You can manage cookies in your browser settings; blocking some cookies may affect site functionality. You can also opt out of targeted advertising and "sale" or "sharing" of personal information at Your Privacy Choices. Where required by law (for example, for visitors in the United Kingdom), we will ask for your consent before setting non-essential cookies, and you can change your choice at any time through the cookie preferences link on our website.

Global Privacy Control (GPC). We treat a valid GPC signal from your browser as a request to opt out of the sale and sharing of personal information and targeted advertising for that browser or device, and for any account linked to it where we can identify you. Do Not Track. Because there is no common standard for "Do Not Track" signals, we do not respond to them separately from GPC.

8. Health-Related Information and Consumer Health Data

Some information we collect can reveal information about your health, such as your hair loss concerns, scalp condition, sensitivities, product usage history, and before-and-after photos. Certain laws, including Washington's My Health My Data Act and Nevada's consumer health data law, call this "consumer health data," and other laws treat it as "sensitive" personal information.

• What we collect: information you choose to provide about your hair, scalp, and hair loss concerns (for example, in support conversations, reviews, surveys, or quizzes); before-and-after photos submitted for a guarantee request or review; and records that you purchased hair care products.
• How we use it: only to provide the products and services you request, respond to your support or guarantee request, prevent fraud and respond to payment disputes, and comply with law.
• How we disclose it: only to service providers acting on our behalf for those purposes, as required by law, or with your consent. We do not sell it, and we do not use it or share it for targeted advertising.
• Before-and-after photos submitted for a guarantee request are used only to evaluate that request, prevent fraud, and respond to payment disputes. We will not use them in advertising or publish them without your separate written consent.
• Your rights: you may confirm whether we collect your consumer health data, access it, request a list of third parties and affiliates with whom we have shared it, request deletion, and withdraw consent, by contacting us as described in Section 13. Where the law requires your consent to collect or share consumer health data, we will ask for it before doing so.

9. Data Retention

We keep personal information only as long as reasonably necessary for the purposes in this Privacy Policy, including:

We may keep information longer where required by law or to establish, exercise, or defend legal claims. We may retain de-identified or aggregated information that cannot reasonably identify you.

10. Your Privacy Rights

Depending on where you live, you may have the right to:

• Know and access the personal information we hold about you and how we use and disclose it, and obtain a copy in a portable format;
• Correct inaccurate personal information;
• Delete personal information, subject to legal exceptions (for example, records we must keep for tax purposes or to complete an order);
• Opt out of the sale or sharing of personal information, targeted advertising, and profiling that produces legal or similarly significant effects (we do not engage in that type of profiling);
• Limit the use of sensitive personal information (we use sensitive personal information only for the purposes permitted by law and listed in Section 8);
• Withdraw consent where processing is based on consent;
• Object to or restrict certain processing (for residents of the United Kingdom);
• Appeal a decision we make about your request; and
• Not be discriminated against for exercising your rights. We will not deny you goods, charge you a different price, or provide a different level of quality because you exercised a privacy right, except as permitted by law in connection with the financial incentives described in Section 14.

11. U.S. State Privacy Rights

This Section applies to residents of California and other U.S. states with comprehensive consumer privacy laws.

Categories collected in the past 12 months. We have collected the following categories of personal information described in the California Consumer Privacy Act: identifiers; customer records (name, address, phone, payment card details); commercial information; internet or other electronic network activity information; general geolocation data; audio, electronic, or visual information (such as photos, voicemails, and support recordings); inferences; and sensitive personal information (health-related information and account login credentials). The sources, purposes, and recipients of each category are described in Sections 3, 4, and 5.

Sale and sharing. In the past 12 months, we have "sold" or "shared" (as those terms are defined under California law) identifiers, internet or other electronic network activity information, commercial information, and inferences to advertising and analytics partners for targeted advertising and analytics. We have not sold or shared sensitive personal information. We do not knowingly sell or share the personal information of consumers under sixteen (16) years of age.

Opt out. You can opt out of sale, sharing, and targeted advertising at Your Privacy Choices, by enabling Global Privacy Control, by emailing support@novamane.com, or by calling (855) 746-7270.

Sensitive personal information. We use and disclose sensitive personal information only for purposes that do not give rise to a right to limit under California law, such as providing the products and services you request and preventing fraud.

California "Shine the Light." California residents may request information about our disclosure of personal information to third parties for their own direct marketing purposes by contacting us as described in Section 13.

Nevada. Nevada residents may submit a request directing us not to sell covered information, as defined under Nevada law, by contacting us as described in Section 13.

12. International Customers: Canada, the United Kingdom, Australia, and New Zealand

Where we process information. We are based in the United States, and our service providers may process personal information in the United States and other countries. Those countries may have data protection laws that differ from yours. When we transfer personal information internationally, we take steps required by applicable law to protect it, including contractual safeguards such as the UK International Data Transfer Addendum where required.

Canada. We handle personal information in accordance with applicable Canadian privacy laws, including PIPEDA and, for Quebec residents, the Act respecting the protection of personal information in the private sector. Our privacy contact is reachable at support@novamane.com. You may access and request correction of your personal information and withdraw consent, subject to legal and contractual restrictions. You may also contact the Office of the Privacy Commissioner of Canada or your provincial privacy regulator.

United Kingdom. Under the UK GDPR, our legal bases for processing are: performance of a contract (processing orders, Auto-Ship, returns, and support); legitimate interests (fraud prevention, security, analytics, improving the Services, and marketing to existing customers where permitted, balanced against your rights); consent (non-essential cookies, marketing where consent is required, and health-related information); and legal obligation (tax, accounting, and compliance). Health-related information is processed on the basis of your explicit consent or where necessary to establish, exercise, or defend legal claims. You have the rights listed in Section 10, and you may lodge a complaint with the Information Commissioner's Office (ico.org.uk).

Australia. We handle personal information in accordance with the Australian Privacy Principles where they apply to us. Personal information may be disclosed to recipients located in the United States and other countries where our service providers operate. You may request access to or correction of your personal information, and you may complain to us first and then to the Office of the Australian Information Commissioner (oaic.gov.au) if you are not satisfied with our response.

New Zealand. We handle personal information in accordance with the Privacy Act 2020. You may request access to and correction of your personal information, and you may complain to the Office of the Privacy Commissioner (privacy.org.nz).

13. How to Exercise Your Rights

Submit a request:

• Online at Your Privacy Choices (opt-out requests);
• By email to support@novamane.com with the subject line "Privacy Request"; or
• By phone at (855) 746-7270.

Verification. To protect your information, we will verify your identity before fulfilling requests to access, correct, or delete personal information, usually by matching information you provide (such as your email address and a recent order number) to our records. We do not require verification for opt-out requests, but we may need enough information to locate your records.

Authorized agents. You may designate an authorized agent to make a request for you. We may require proof of the agent's authority and may ask you to verify your identity directly, as permitted by law.

Timing. We respond within the time required by applicable law (for example, within forty-five (45) days for U.S. state law requests, extendable once where permitted, and within one (1) month for UK requests, extendable where permitted).

Appeals. If we decline your request, you may appeal by replying to our decision or emailing support@novamane.com with the subject line "Privacy Appeal." We will respond in writing within the time required by law. If your appeal is denied, you may contact your state attorney general or relevant regulator.

14. Notice of Financial Incentives

We offer programs that may be considered "financial incentives" under California law, including: discounts or offers for signing up for our emails or text messages; Auto-Ship pricing; and loyalty, rewards, streak, and referral programs. To participate, you provide identifiers such as your name, email address, phone number, and purchase information. Participation is optional and you may withdraw at any time by unsubscribing, replying STOP, cancelling Auto-Ship, or contacting us, although you may lose the associated benefits.

We believe the value of the personal information collected through these programs is reasonably related to the value of the benefit offered. We estimate that value using our expenses related to the program, including the cost of the discount or reward, and the expected revenue from customers who participate. Specific program terms are presented when you join.

15. Children's Privacy

The Services are intended for adults and are not directed to children. We do not knowingly collect personal information from anyone under eighteen (18) years of age. If you believe a child has provided us with personal information, please contact us and we will delete it.

16. Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, and relying on PCI-compliant payment processors so that we do not store full payment card numbers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please keep your account credentials confidential.

17. Third-Party Websites and Platforms

The Services may link to or integrate with third-party websites, social media platforms, and payment providers that have their own privacy practices. This Privacy Policy does not apply to them, and we are not responsible for their practices. Please review their privacy policies.

18. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will post the updated version with a new "Last Updated" date and, if we make material changes, provide additional notice as required by law (for example, by email or a notice on our website). Where required, we will obtain your consent before applying material changes to information we have already collected.

19. Contact Us

Cyber CommerceX LLC (d/b/a NovaMane Ventures)
312 W 2nd St, Unit A2299
Casper, WY 82601, United States
Email: support@novamane.com (subject line "Privacy Request")
Phone: (855) 746-7270