PRIVACY POLICY

NOVA

Conversations That Matter

Last updated: 30 July 2026

This Privacy Policy ("Policy") explains how Nova ("Nova", "we", "us", or "our") collects, uses, discloses, and protects personal data when you access or use the Nova website, mobile applications, and any associated podcast, audio, or digital content services (collectively, the "Platform"), available at nova.co.rw. This Policy should be read together with our Terms and Conditions. By using the Platform, you acknowledge the practices described in this Policy.

1. Who We Are and Scope of This Policy

Nova operates a podcast and digital media platform under the brand "Conversations That Matter." For the purposes of Rwanda's Law N°058/2021 of 13/10/2021 relating to the protection of personal data and privacy, Nova acts as the data controller for personal data collected through the Platform. This Policy applies to all Users, whether accessing free Content or paying for Premium Content or Subscriptions.

2. Personal Data We Collect

2.1 Information you provide directly:

• Account details: name, email address, phone number, username, and password.
• Payment-related information: billing name, mobile money number, or masked card details, processed through our Payment Processors (Nova does not store full card numbers or mobile money PINs).
• Communications: messages, feedback, comments, or reviews you submit through the Platform, email, or social media.
• Optional profile information: profile picture, bio, or listening preferences you choose to provide.

2.2 Information collected automatically:

• Device and log data: IP address, browser type, device identifiers, operating system, and access times.
• Usage data: episodes played, listening duration, playback position, search queries, and interaction with Premium Content.
• Cookies and similar technologies: used to remember your preferences, keep you logged in, and analyze Platform performance (see Section 8).

2.3 Information from third parties:

• Confirmation of successful or failed transactions from Payment Processors (e.g., mobile money operators, card processors).
• Information from social media platforms if you choose to log in or share Content using a third-party account.

3. How We Use Your Personal Data

• To create and manage your Account and authenticate your identity.
• To process payments, manage Subscriptions, and send payment confirmations or receipts.
• To deliver, personalize, and improve Content recommendations and Platform features.
• To communicate with you about your Account, transactions, new episodes, or changes to our Terms or this Policy.
• To detect, investigate, and prevent fraud, unauthorized access, or abuse of the Platform.
• To comply with legal, tax, and regulatory obligations in Rwanda and, where applicable, other jurisdictions.
• To send marketing communications, where you have opted in, which you may withdraw consent for at any time.

4. Legal Basis for Processing

We process your personal data on one or more of the following legal bases: (a) your consent, such as when you register an Account or opt in to marketing; (b) performance of a contract, such as processing payment for Premium Content or a Subscription; (c) compliance with a legal obligation, such as tax or financial record-keeping requirements; and (d) our legitimate interests, such as securing the Platform against fraud and improving our services, provided such interests are not overridden by your rights under Rwandan data protection law.

5. Payment Data and Third-Party Payment Processors

All payments made on the Platform are processed by licensed, PCI-compliant third-party Payment Processors, including mobile money operators and card payment gateways. Nova receives only transaction confirmation, amount, timestamp, and limited billing details necessary to grant you access to Premium Content and to maintain financial records; Nova does not access or store your full card number, CVV, or mobile money PIN. Your payment information is also subject to the privacy policy of the relevant Payment Processor, which we encourage you to review.

6. Sharing and Disclosure of Personal Data

Nova does not sell your personal data. We may share personal data with:

• Payment Processors, solely to complete and verify transactions.
• Service providers who support hosting, analytics, customer support, or email delivery, under contractual confidentiality obligations.
• Regulatory or governmental authorities, where required by Rwandan law or a valid legal request.
• A successor entity, in the event of a merger, acquisition, or sale of Nova's assets, subject to equivalent privacy protections.

Any third party receiving personal data on our behalf is contractually required to protect it in a manner consistent with this Policy and applicable law.

7. International Data Transfers

Where personal data is processed or stored on servers located outside Rwanda (for example, through cloud hosting or payment infrastructure providers), Nova will take reasonable steps to ensure such transfers comply with Rwanda's Law N°058/2021 and that recipients provide an adequate level of data protection, including through contractual safeguards where required.

8. Cookies and Tracking Technologies

The Platform uses cookies and similar technologies to keep you logged in, remember your preferences, measure Platform performance, and, where you consent, deliver relevant content or advertising. You can control or disable cookies through your browser settings; however, disabling essential cookies may affect your ability to log in or access Premium Content.

9. Data Retention

We retain personal data for as long as necessary to provide the Platform, comply with legal and tax obligations, resolve disputes, and enforce our agreements. Account information is generally retained for the duration of your Account plus a reasonable period thereafter for record-keeping; transaction records are retained in accordance with applicable financial regulations in Rwanda. When personal data is no longer needed, we will securely delete or anonymize it.

10. Data Security

We implement reasonable technical and organizational measures, including encryption in transit, access controls, and secure hosting, to protect personal data against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.

11. Your Rights

Subject to Rwanda's Law N°058/2021 and other applicable law, you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request deletion of your personal data, subject to our legal and legitimate retention needs.
• Withdraw consent to processing based on consent, such as marketing communications, at any time.
• Object to or request restriction of certain processing activities.

To exercise these rights, please contact us using the details in Section 15. We may need to verify your identity before responding to your request.

12. Children's Privacy

The Platform is not directed at children under 10., we limit data collection from such Users to what is necessary to provide that access, and we do not knowingly collect payment information from minors. If we learn that we have collected personal data from a child in violation of this Policy, we will take steps to delete it.

13. Third-Party Links and Embedded Content

The Platform may contain links to third-party websites, social media pages, or embedded players. Nova is not responsible for the privacy practices of such third parties, and we encourage you to review their privacy policies before providing any personal data.

14. Changes to This Policy

Nova may update this Policy from time to time to reflect changes in our data practices, technology, or legal requirements. Material changes will be notified via email or a prominent notice on the Platform at least 14 days before taking effect. Continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

15. Contact Us

If you have questions about this Policy, wish to exercise your data protection rights, or have concerns about how your personal data is handled, please contact:

Nova — Conversations That Matter

• Website: nova.co.rw
• Email: novapodcast2019@gmail.com