Privacy Policy

Effective Date: 01/01/2026

This Privacy Policy explains how HAS Consulting LLC (“we,” “us,” or “our”), including its operating brands Novorêx® (www.novorex.org) and Dr. Sater Boutique Clinic, collects, uses, discloses, and safeguards your personal information. NOVOREX website is owned by HAS Consulting LLC, which acts as a data controller of your personal data.

We have adopted this Privacy Policy to describe how we process information collected through our websites, platforms, services, educational tools, assessments, consultations, and related offerings. By using our website or services, you acknowledge that you have read and understood this Privacy Policy.

1. Organizational Identity

All services are operated by HAS Consulting LLC, a medical, research, advisory, and technology-enabled organization.

• Novorêx®: belief science, emotional intelligence, education, analytics, and human-centered frameworks

• Dr. Sater Boutique Clinic: concierge medical, hematology-oncology, advisory, and consultative services

2. Personal Information We Collect

A. Information Collected Automatically (“Device Information”)

When you visit our website, we automatically collect certain information about your device, including your browser type, IP address, time zone, and certain cookies installed on your device. As you browse the site, we may also collect information about the pages you view, referring websites or search terms, and how you interact with the site.

B. Information You Provide Voluntarily

We may collect personal data that you voluntarily provide to us, including but not limited to:

• First and last name

• Email address

• Phone number

• City, state, and country

• Mailing address (if applicable)

• Payment information (if applicable)

• Any information submitted through forms, assessments, or consultations

C. Health & Wellness Information

We may collect health-related information only when you voluntarily submit it through consultations, assessments, intake forms, or medical services. This may include:

• Medical history and clinical information

• Wellness, emotional, belief-based, or quality-of-life data

• Information necessary to provide medical or advisory services

3. Why We Process Your Data

Our top priority is the security and confidentiality of your data. We process only the minimum amount of personal information necessary to operate our services and deliver requested functionality.

We process your data for purposes such as:

• Providing personalized education, medical care, and advisory services

• Matching individuals with appropriate experts or care pathways

• Supporting research, quality improvement, and service optimization

• Communicating regarding appointments, updates, and educational content

• Maintaining platform security, integrity, and compliance

Information collected automatically is used primarily to identify potential cases of abuse and to establish statistical information regarding website usage. Such statistical information is not aggregated in a manner that would identify any particular user.

You may choose not to provide personal data; however, this may limit your ability to access certain features such as contacting us through the website or receiving newsletters.

4. HIPAA Notice of Privacy Practices

When applicable, HAS Consulting LLC, Novorêx, and Dr. Sater Boutique Clinic comply with the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

Protected Health Information (PHI):

• Is accessed only by authorized personnel

• Is used solely for treatment, healthcare operations, and permitted purposes

• Is disclosed only with your authorization or as required by law

You have the right to:

• Access your health records

• Request corrections

• Request restrictions or confidential communications

• Receive an accounting of disclosures

Educational tools, belief-based assessments, and wellness analytics are not a substitute for emergency care or independent medical diagnosis.

5. Your Rights (Including GDPR / EU Rights)

If you are a European resident, you have the following rights related to your personal data:

• The right to be informed

• The right of access

• The right to rectification

• The right to erasure

• The right to restrict processing

• The right to data portability

• The right to object

• Rights in relation to automated decision-making and profiling

If you would like to exercise these rights, please contact us at support@novorex.org.

If you are a European resident, we note that we are processing your information in order to fulfill contracts we might have with you (for example, if you make an order through the site), or otherwise to pursue our legitimate business interests.

Your information may be transferred outside of Europe, including Canada and the United States.

6. Sharing of Information

We may share information only:

• With trusted service providers under strict confidentiality agreements

• With licensed professionals involved in your care, with consent

• To comply with legal, regulatory, or safety obligations

We do not sell, rent, or trade personal or health information. We do not permit third parties to use your data for marketing purposes.

7. Cookies & Tracking Technologies

We use cookies and similar technologies to improve functionality, understand usage, and enhance user experience.

You may disable cookies through your browser settings.

8. Links to Other Websites

Our website may contain links to other websites that are not owned or controlled by us. We are not responsible for the privacy practices of such other websites or third parties.

We encourage you to read the privacy statements of any website you visit that may collect personal information.

9. Information Security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure.

We maintain reasonable administrative, technical, and physical safeguards to protect against unauthorized access, use, modification, and disclosure of personal data in our custody or control.

However, no data transmission over the Internet or wireless network can be guaranteed to be 100% secure.

10. Legal Disclosure

We will disclose any information we collect, use, or receive if required or permitted by law, such as to comply with a subpoena or similar legal process, or when we believe in good faith that disclosure is necessary to:

• Protect our rights

• Protect your safety or the safety of others

• Investigate fraud

• Respond to a government request

11. Policy Updates

We may update this Privacy Policy periodically. Updates will be posted with a revised effective date.

Your continued use of our services reflects acceptance of the updated policy.

12. Contact Information

If you would like to contact us to understand more about this Policy, or wish to contact us concerning any matter relating to individual rights and your Personal Information, you may send an email to:

support@novorex.org