How Novinway handles your information

01Scope

This Privacy Notice applies to information collected through Novinway’s website, inquiries, consultations, intake, family onboarding, Care Services, Navigation Services, separate professional services, recruiting, payment, and other direct contact with Novinway.

A service agreement, authorization, or service-specific notice may provide additional details.

02Information we collect

Depending on your relationship with Novinway, we may collect:

• Contact, identity, household, custody, emergency-contact, approved-pickup, sponsor, and payer information.
• Information families provide about a child’s routines, communication, interests, sensory preferences, health, disability, medication or emergency plans, behavior, mobility, eating, hygiene, sleep, school, activities, and safety.
• Scheduling, location, transportation, travel, service, communication, preference, complaint, incident, and emergency information.
• Records, forms, applications, benefits information, authorizations, meeting information, submissions, and responses used for Navigation Services.
• Information used for a separately contracted professional service, including ABA assessment, treatment, professional communications, and billing records.
• Agreements, permissions, Family Care Plans, signatures, audit records, invoices, payment status, and account information.
• Photos or short videos taken during Care as described below.
• Job-application and employment-related information provided by applicants, employees, and references.

We ask families to provide only information reasonably relevant to the inquiry or service.

03Information collected automatically

Our website and service providers may receive device and browser information, IP address, approximate location, referral source, pages viewed, website interactions, and cookie data.

You may manage nonessential cookies through available site or browser settings. Disabling some technologies may affect website functions.

04How we use information

Novinway may use information to:

• Respond to inquiries and conduct intake.
• Determine whether a requested service fits Novinway’s scope and can be provided safely.
• Prepare Family Care Plans, match and prepare staff, schedule services, and provide consistent support.
• Deliver Care, Navigation, or separately contracted professional services.
• Communicate with families, sponsors, staff, and authorized outside organizations.
• Document services, review incidents or significant behavior, address concerns, and improve child-specific support.
• Process payments, provide receipts or dependent-care documentation, maintain business records, prevent fraud, and enforce agreements.
• Recruit, screen, employ, and manage personnel.
• Protect children and others, respond to emergencies, report suspected abuse or neglect, comply with legal process, and meet other legal duties.
• Maintain security and improve our systems and operations.

05Who can access information

Novinway limits access according to role and need.

Care Specialists and supporting personnel receive the practical information needed to prepare for and provide Care. Navigators receive the information needed for the family-authorized task. A separately engaged professional receives information needed for that professional service.

Novinway does not automatically copy outside clinical, school, insurance, legal, or professional records across service roles.

06How we share information

Novinway may share information with:

• The family and people the family authorizes.
• Novinway personnel and authorized professionals who need the information for their work.
• Technology, scheduling, payment, storage, communication, insurance, accounting, legal, and other providers that help operate the business.
• Emergency responders, health professionals, schools, activities, transportation providers, insurers, agencies, attorneys, auditors, and other recipients when directed by the family or reasonably necessary for the service.
• A sponsor or payer to the extent needed to arrange services, verify charges, or administer payment.
• Government agencies, courts, law enforcement, or other public authorities when disclosure is required or legally permitted.
• A buyer, successor, lender, insurer, or professional adviser involved in a legitimate business transaction or claim.

Novinway limits disclosures to what the stated purpose reasonably requires. We do not sell personal information for money or publicly use private family information without authorization.

07Navigation authorizations

Before a Navigator requests or sends records or contacts another organization for a family, Novinway records the authorized purpose, recipient, information, time period, and permission.

Some organizations may still require the parent or authorized person to speak, sign, or confirm their identity directly.

08Session photos and video

With the authorization provided in the Care Services Agreement, Novinway may take limited photos or short videos on secure, company-managed devices during Care.

Ordinary activity photos or videos may be shared privately with the family. A brief recording of an incident or significant behavior may be reviewed internally to understand what occurred and improve child-specific support.

A family may decline session photos and video in writing at any time. Novinway does not make audio recordings without consent and does not record bodily care, nudity, private areas, suspected abuse or neglect, or any situation in which recording could interfere with supervision, de-escalation, first aid, emergency response, or reporting.

Public use of a child’s or family’s image, story, or quotation requires separate authorization.

09Health information, ABA, and HIPAA

Care and Navigation are not health-care services. A family’s decision to provide health, disability, medication, or behavioral information does not by itself make Novinway a HIPAA covered entity or business associate, and this document is not a HIPAA Notice of Privacy Practices. Novinway nevertheless treats this information as sensitive.

Any ABA or other professional service is separately contracted and delivered under the responsible professional’s applicable license, scope, and documentation requirements. Professional records are kept separate from ordinary Care and Navigation records and are shared only with family authorization or another lawful basis.

If a professional service becomes subject to HIPAA or another service-specific privacy law, Novinway will provide any additional notice required for that service.

10Payment and benefit information

Payments are processed through an outside payment provider. Novinway may receive transaction information, payment status, and limited account details but does not store complete card or bank credentials.

Novinway may provide receipts, its taxpayer identification information, service dates, and payment amounts for a family’s dependent-care or benefit administrator. The family and administrator remain responsible for deciding whether an expense qualifies. Novinway does not promise insurance, government-program, HSA, FSA, or dependent-care reimbursement.

11Safety and legal disclosures

Novinway may use or disclose information when reasonably necessary to:

• Protect a child or another person from immediate harm.
• Obtain emergency assistance.
• Report suspected abuse or neglect.
• Respond to legal process or a lawful government request.
• Investigate a complaint, security event, or suspected wrongdoing.
• Enforce an agreement or address an insurance claim or dispute.
• Meet another legal or professional obligation.

We follow the reporting agency’s or law enforcement’s directions about notifying a family of suspected abuse or neglect.

12How we protect information

Novinway uses administrative, technical, and physical safeguards appropriate to the information and service. These may include role-based access, account controls, company-managed devices, secure service providers, staff requirements, and incident-response procedures.

No system can guarantee complete security. Novinway will provide notice of a security incident when required by law.

13How long we keep information

Novinway generally follows these retention periods:

• Final agreements, permissions, material Family Care Plans, and incident or safety records: until the later of ten years after services end or the child reaches age 25.
• Billing, tax, and final Navigation project records: seven years.
• ABA or other professional records: according to applicable professional and jurisdictional requirements.
• Routine family-update photos and videos: deleted after delivery when they are no longer needed.
• Internal-review recordings: after review, Novinway may delete a recording or retain it in connection with a reportable incident, complaint, insurance matter, claim, quality improvement, or internal staff training. When practical, recordings retained for quality improvement or training are de-identified. Recordings tied to another matter follow the retention period for the related record; other recordings are kept only as long as they remain useful for the stated purpose.
• Public-media authorizations and withdrawal history: retained while the material remains in use and as reasonably needed for related claims.

Drafts, routine scheduling information, communications, applicant information, and other operational records are deleted or reduced when no longer reasonably needed for service, safety, employment, insurance, professional duties, disputes, or law.

14Your choices

You may contact Novinway to:

• Review or correct your contact information.
• Update permissions or communication preferences.
• Decline session photos and video.
• Withdraw a public-media authorization.
• Change an authorized Navigation recipient.
• Ask how long we keep information, who can access it, or how we share it.
• Make another privacy request available under applicable law.

Novinway may need to verify your identity and authority before acting. We may retain information when reasonably required for safety, payment, insurance, professional duties, disputes, or law.

15Children’s information

The website is intended for parents, guardians, professionals, applicants, and other adults. It is not intended for children acting independently.

Novinway collects information about a child from a parent, guardian, or other authorized adult when reasonably needed for an inquiry, intake, service, or safety purpose.

16Family stories and quotations

Novinway uses family stories, testimonials, images, or quotations publicly only with appropriate authorization.

To protect privacy, Novinway may change or generalize names, initials, locations, ages, and other identifying details. We may lightly edit, shorten, or combine statements made by the same person for grammar, clarity, and length without materially changing what the person communicated. We do not combine statements from different families and present them as one person’s experience.

17Changes and contact

Novinway may update this notice as its services, systems, or legal duties change. Updates apply going forward and do not change a signed agreement, price, service scope, liability term, or permission without any additional agreement or authorization required.

For privacy questions or requests, contact:

Novinway, LLC
hello@novinway.com
www.novinway.com