Privacy Policy – Novasphere Direct

Privacy Policy for Novasphere Retail LLC

Last Updated: May 03, 2025

1. Introduction

Novasphere Retail LLC (“Novasphere,” “we,” “us,” or “our”), located at 1361 CRIMSON CT, PLOVER, WI 54467, USA, is committed to protecting the privacy and confidentiality of Personal Information entrusted to us. This Privacy Policy (“Policy”) outlines how we collect, use, disclose, secure, and retain Personal Information in connection with:

Our website (https://novasphere.center/) (“Website”);
The provision of our business legal framework and advisory services (“Services”) to our clients (“Clients”); and
Our general business communications and operations.

“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or¹ could reasonably be linked, directly or indirectly, with a particular individual or household.

We handle Personal Information in accordance with applicable U.S. federal and state data privacy laws and our professional obligations of confidentiality.

2. Information We Collect

The types of Personal Information we collect depend on your interaction with us:

Information from Website Visitors:
- Contact Information: If you voluntarily provide it (e.g., via contact forms, newsletter sign-ups), such as your name, email address, phone number, and company affiliation.
- Technical Data: IP address, browser type, operating system, device information, referring URLs, pages viewed, and dates/times of visits, collected through cookies and similar technologies (see Section 7).
Information from and About Our Clients (and Individuals Related to Client Matters):
- Client Contact and Identification Information: Names, titles, company details, addresses, email addresses, phone numbers of individuals within client organizations.
- Business Information: Detailed information about a Client’s business operations, structure, finances, strategies, plans, and challenges, as necessary to provide our Advisory Services.
- Information for Service Provision: Any Personal Information provided by or on behalf of a Client, or generated by us in the course of providing Services. This may include highly sensitive and confidential information related to legal matters, contracts, employees, customers, disputes, intellectual property, compliance issues, etc.
- Billing and Payment Information: Financial account information for invoicing and payment processing.
- Information about Other Individuals: In the course of providing Services to our Clients, we may process Personal Information about other individuals who are not our direct clients (e.g., employees or customers of our Clients, counterparties in transactions or disputes, witnesses, beneficiaries). This information is processed based on instructions from our Clients or as necessary for the provision of Services.

3. How We Collect Information

Directly from You: When you provide it to us by filling out forms on our Website, communicating with us via email, phone, or in person, or when you engage us for Services and provide information necessary for that engagement.
Directly from Our Clients: Clients provide us with substantial information as part of our advisory relationship.
Automatically: Through cookies and other tracking technologies when you visit our Website.
From Third Parties:
- From our Clients about other individuals related to their matters.
- From publicly available sources (e.g., government records, company registers, professional directories) as part of providing our Services.
- From other parties involved in a Client’s matter (e.g., other advisors, opposing counsel, with client consent or as part of a legal process).

4. How We Use Your Information

We use Personal Information for the following purposes:

To Provide Advisory Services: This is our primary purpose. We use information provided by and about Clients to deliver business legal framework advice, draft documents, conduct research, and fulfill our contractual obligations under Engagement Letters/SOWs.
Client Relationship Management: To manage our relationships with Clients, including communications, account administration, and client service.
Billing and Collections: To issue invoices and process payments for our Services.
Website Operation and Improvement: To operate, maintain, and improve our Website, analyze usage, and enhance user experience.
Marketing and Communications (with consent/opt-out): To send newsletters, legal updates (if applicable), information about our services, or event invitations, where permitted by law and professional ethics. You can opt-out of marketing communications at any time.
Compliance with Legal and Ethical Obligations: To comply with applicable laws, regulations, court orders, professional conduct rules (including conflict checks), and record-keeping requirements.
Security and Fraud Prevention: To protect the security and integrity of our systems, data, Website, and to prevent fraud or other illegal activities.
To Establish, Exercise, or Defend Legal Claims: In connection with actual or threatened legal proceedings.

5. How We Share and Disclose Information

We hold Personal Information, particularly confidential client information, in strict confidence. We do not sell Personal Information. We disclose Personal Information only in the following circumstances:

Within Novasphere Retail LLC: To personnel who need access to the information to provide Services or perform their duties, subject to confidentiality obligations.
To Our Service Providers: With trusted third-party vendors who perform services on our behalf (e.g., IT hosting, document management systems, secure communication platforms, payment processors, research tools, accounting services). These providers are contractually obligated to maintain the confidentiality and security of the data and are restricted from using it for any purpose other than providing services to us.
In Connection with Providing Services to Clients:
- With third parties as necessary to provide the Services, with the Client’s instruction or consent (e.g., government agencies for filings, other parties in a transaction, experts).
- Information shared in the course of representing or advising a Client is subject to our professional duties of confidentiality and any applicable attorney-client privilege (where a formal attorney-client relationship is established).
For Legal and Ethical Reasons:
- If required by law, subpoena, court order, or other legal process.
- To comply with our professional and ethical obligations, including responding to inquiries from regulatory bodies.
- To protect the rights, property, or safety of Novasphere, our Clients, or others.
Business Transfers: If Novasphere is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of its assets, Personal Information may be transferred as part of that transaction, subject to standard confidentiality arrangements.
With Your Explicit Consent: For any other purpose disclosed to you at the time we collect your information or pursuant to your consent.

6. Cookies and Tracking Technologies

Our Website may use cookies and similar tracking technologies to enhance user experience, analyze² site traffic, and for other operational purposes. You can typically control cookies through your browser settings. For more detailed information, please refer to a separate Cookie Notice if available on our Website, or contact us.

7. Data Security

We implement and maintain reasonable administrative, technical, and physical security measures designed to protect the Personal Information³ we process against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures include, but are not limited to:⁴

Access controls and authentication.
Encryption of sensitive data where appropriate.
Secure storage and transmission of information.
Regular security assessments and updates.
Confidentiality agreements with employees and service providers.

Given the nature of our services, we are acutely aware of the need for robust security and confidentiality for Client information. However, no method of transmission over the Internet or method of electronic storage is 100% secure.

8. Data Retention

We retain Personal Information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal,⁵ accounting, ethical, or reporting requirements.

Client Files and Information: Retention periods for client matter files are often lengthy due to legal and professional obligations, statutes of limitation, and the need to address future inquiries or conflicts. Specific retention periods may be governed by our internal policies and applicable law.
Other Personal Information: Other Personal Information is retained for as long as necessary for its collection purpose or as permitted by law. When Personal Information is no longer required, we will securely destroy or anonymize it.

9. Your Privacy Rights

Depending on your jurisdiction and applicable law, you may have certain rights regarding your Personal Information. Novasphere is committed to honoring these rights. These may include:

Right to Access: You may have the right to request access to the Personal Information we hold about you.
Right to Correction: You may have the right to request that we correct inaccurate Personal Information.⁶
Right to Deletion: You may have the right to request that we delete your Personal Information, subject to certain exceptions (e.g., where retention is necessary for us to comply with legal obligations, resolve disputes, maintain client files as required by professional rules, or exercise/defend legal claims).
Right to Opt-Out of Marketing Communications: You can opt-out of receiving marketing emails from us at any time by using the “unsubscribe” link in the emails or by contacting us.
Rights Related to Client Information: If we process your Personal Information on behalf of one of our Clients in our capacity as their advisor, you should generally direct your rights requests to that Client.

Exercising Your Rights: To exercise any applicable rights, please contact us using the details in Section 14. We will need to verify your identity before responding to your request and will process your request in accordance with applicable law. Please note that certain rights may be limited where they conflict with our legal or ethical obligations, including duties of confidentiality or attorney-client privilege (where applicable).

10. Children’s Privacy

Our Website and Services are not directed to individuals under the age of 18, and we do not knowingly collect Personal Information from⁷ children under the age of 13 without verifiable parental consent, in⁸ accordance with the Children’s Online Privacy Protection Act (COPPA). If we become aware that we have collected Personal Information from a child⁹ in violation of applicable law, we will take steps to delete that information.

11. Attorney-Client Relationship and Confidentiality

This Privacy Policy is separate from, and does not override, the duties of confidentiality and any attorney-client privilege that may arise when a formal attorney-client relationship is established between Novasphere Retail LLC and a Client pursuant to a specific Engagement Letter for legal services. The handling of information within such a privileged relationship is governed by applicable professional conduct rules and law.

12. International Data Transfers

Novasphere Retail LLC is based in the United States, and our Services are primarily targeted to clients in the US. If we transfer Personal Information to or from other countries, we will do so in compliance with applicable data protection laws, ensuring appropriate safeguards are in place.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices,¹⁰ legal or regulatory obligations, or service offerings. We will post the updated Policy on our Website and indicate the “Last Updated” date. We encourage you to review this Policy periodically. For material changes, we may provide more prominent notice.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our handling of your Personal Information, please contact¹¹ our Privacy Officer or Joseph Mitch, Sole Member at:

Novasphere Retail LLC

Attn: Privacy Compliance

1361 CRIMSON CT

PLOVER, WI 54467, USA

Email: support@novasphere.center (or a dedicated privacy email like privacy@novasphere.center)

Website: https://novasphere.center/