Version 2.2 · Last updated: 24 October 2026
This Privacy Policy explains how NOVANOS PARA PHARMACEUTICAL PRODUCTS TRADING L.L.C. (“Novanos”, “we”, “us”), Business Bay, Dubai, United Arab Emirates, collects, uses, shares and protects personal data in the Novanos Loyalty Program mobile app and its administration console (together, the “Programme”). The Novanos Loyalty Program is a loyalty programme for dermatology and aesthetic doctors who use products distributed by Novanos. You verify genuine products by scanning their QR codes, earn points, and redeem them for marketing support, scientific support or product samples. Points do not expire. We ask you to accept this policy when you register. We record which version you accepted and when.1. Who is responsible for your data
Novanos is responsible for the personal data processed in the Programme. We process it in line with the data protection laws that apply to us and to you, including the UAE Personal Data Protection Law (Federal Decree-Law No. 45 of 2021) where it applies. Our contact details are in section 12.2. Information we collect
Information you give us
- Registration: full name, email address, mobile number, clinic name and a password. Your password is stored only as a one-way encrypted hash; we cannot read it.
- Profile (optional): professional title, emirate and a profile picture, if you add them.
- Referral code: if another doctor referred you and you enter their code.
- Your consent: the version of this policy (and of the Programme Terms, when they apply) that you accepted, with the date and time.
Information created when you use the Programme
- Mobile verification: the one-time code we send you by SMS (stored only in hashed form and valid for 5 minutes) and whether the SMS was delivered.
- Product verification: each QR code you scan or enter, the product and production batch it belongs to, the result (genuine, already used, invalid), the time, and the points awarded.
- Points: a record of every points movement (earned, reserved, returned, used, or corrected by Novanos staff with a reason), your lifetime and available balances, and your membership tier.
- Requests: your marketing support, scientific support and sample requests, including hours or quantities, points cost, status, proposed appointment times and fulfilment notes.
- Account status: approval, requests for more information, suspension or closure, with the date and the reason.
- Support messages: the questions you send from Help & support in the app, and our replies.
Information collected automatically
- Server and security logs: IP address, device or browser type, and the time of each request to our servers.
- Sign-in and verification activity: successful and failed sign-ins and verification-code requests, used to protect accounts and limit abuse.
- Camera: the app uses your camera only to read QR codes. Images are processed on your device and are not stored or sent to us; only the code itself is sent.
- Scans made offline: if you scan without a connection, the codes are kept on your phone only until they are sent to us automatically.
- Sign-in session: the app and console keep your sign-in on your device so you stay signed in.
3. How we use your information
We do not sell your personal data, and we do not use it for advertising.| Purpose | Information used | Legal basis |
|---|---|---|
| Create your account, verify your mobile number and review your eligibility | Registration details, verification code | Your request to join; your consent |
| Verify products and award points | Scans, product and batch data, points record | Providing the Programme to you |
| Process redemption requests and arrange support or samples | Requests, contact details, clinic | Providing the Programme to you |
| Send service messages (verification codes, account and request updates) | Mobile number, email address | Providing the Programme to you |
| Prevent fraud and misuse, such as repeated invalid scans or codes used by several accounts | Scans, sign-in activity, logs | Our legitimate interest in protecting the Programme and genuine products |
| Keep security and audit records, and account for the points we owe | Logs, points record, audit trail | Our legitimate interests; legal obligations |
| Comply with the law and respond to lawful requests | Any relevant information | Legal obligation |
No automated decisions. We make no decision with legal or similarly significant effects about you by automated means alone. A new account becomes active once your mobile number is verified, and Novanos staff can review any account. When our systems flag unusual scanning activity, a member of staff reviews it; the system never suspends an account or removes points by itself.
4. Who can see your information
- Novanos staff, by role. Administrators can see doctor accounts, scans, points and requests. Members of our fulfilment team see only the requests assigned to them or their team, and the contact details needed to fulfil them. Every access to an admin function requires a staff account, and every change to your account or points is recorded with the name of the staff member.
- Not other doctors. Other participants cannot see your profile, scans, points or requests.
- Referrals. If you entered a referral code, Novanos staff can see who referred you. The referring doctor is not shown your details in the app.
- Service providers who process data on our behalf and under our instructions:
- cloud hosting and database: Railway Corporation, servers located in Amsterdam, Netherlands (EU West);
- SMS delivery of verification codes: Twilio Inc., which receives your mobile number and the text of the message.
- Authorities and legal requirements. When the law requires it, or to protect the rights, property or safety of Novanos, our participants or others.
- Business transfers. If Novanos is involved in a merger, acquisition or sale of assets, under a privacy policy at least as protective as this one.
5. International transfers
Novanos is based in the United Arab Emirates, and participants may be located in other countries. Our hosting provider stores data in Amsterdam, Netherlands (EU West), and our SMS provider may process your mobile number in the United States and other countries where it operates. When your data is transferred outside your country, we rely on data processing agreements with our service providers, which require them to protect your data to a standard comparable to this policy.6. How long we keep your information
| Information | How long |
|---|---|
| Account and profile details | While your account is open. Removed when you delete your account (section 7) |
| Verification codes | Valid for 5 minutes; kept only in hashed form |
| Scans, points record and requests | Kept after account deletion without your name or contact details, because they form part of Novanos’ accounting and product traceability records |
| Security and audit logs, including IP addresses | 12 months, for security, fraud investigation and legal obligations |
| Backups | Deleted data may remain in encrypted backups for up to 35 days until they are overwritten |
7. Deleting your account
You can delete your account at any time:- In the app: Profile → Delete account, then enter your password and type DELETE to confirm. It takes effect immediately.
- By email: write to info@novanos-ae.com from the email address registered to your account. Full instructions are on our account deletion page: https://novanos-ae.com/delete-account/.
8. Your rights
Depending on the law that applies to you, you can ask us to:- give you a copy of the personal data we hold about you;
- correct inaccurate data. You can edit your name, title, clinic and country in your Profile; contact us to change your email address or mobile number;
- delete your data (section 7);
- restrict or object to certain uses of your data;
- withdraw your consent. This does not affect earlier processing, but you will no longer be able to take part in the Programme.
9. Security
We protect your data with encrypted connections (HTTPS/TLS), one-way hashing of passwords and verification codes, role-based staff access that is checked on every request, limits on repeated sign-in and verification attempts, and an audit trail of account and points changes. Each doctor can access only their own data. No system is completely secure, so we cannot guarantee absolute security.10. Age
The Programme is for healthcare professionals aged 18 or over. We do not knowingly collect data from anyone under 18.11. Changes to this policy
Each version of this policy has a number and a date. We record which version you accepted. If we make important changes, we will tell you in the app or by email before they take effect.12. Contact us
- NOVANOS PARA PHARMACEUTICAL PRODUCTS TRADING L.L.C., Business Bay, Dubai, United Arab Emirates
- Email: info@novanos-ae.com
- Data protection contact (app developer, novaNOS): app@novanos-ae.com