Effective Date: April 2026

Controller: Real Estate Growth Solutions Coaching Ltd. (“REGS”, “we”, “us”, or “our”)
Contact: [email protected] | [email protected]
Mailing Address: Real Estate Growth Solutions Coaching Ltd., Alberta, Canada

1. Introduction

Real Estate Growth Solutions Coaching Ltd. (“REGS”) operates Nova — THE Agent Operating System (“Nova” or the “Service”). This Privacy Policy explains how we collect, use, disclose and protect personal information and Customer Content in connection with Nova and related websites, applications and services. “Customer Content” and “Nova Data” are defined below. Please read carefully. By using the Service you accept the practices described in this policy.

Key point: Customers retain ownership of their Customer Content (contacts, listings, messages and similar). REGS owns platform-level assets and aggregated or de-identified data described below as Nova Data. For details about Nova ownership and IP, see our IP & Ownership page.

2. Scope & Applicability

This Policy applies to personal information collected through Nova and through our websites, onboarding, support, events and other interactions where we are the data controller. It does not create a contract or change any customer agreement. For enterprise customers and partners, data processing may be governed by separate Data Processing Addenda (DPAs) or contractual terms.

3. Key Definitions

Customer Content. Data uploaded or submitted to the Service by a Customer or its users, including contact records, listings, messages, attachments, notes and other operational records. Customers retain ownership of Customer Content.

Nova Data. Platform-level system data, aggregated or anonymized datasets, templates, Nova-specific training content, system-level metrics, benchmarks, and other Nova assets. Nova Data is proprietary to REGS and may be used by REGS for product development and analytics.

4. Information We Collect

We collect different types of information depending on the Service features you use:

A. Account & Contact Information
Name, business name, billing contact, email address, phone number, job title, company, and billing information.

B. Customer Content
Contacts, listings, messages, attachments, notes and other content that Customers upload or synchronize into Nova (including data synced from third-party CRMs such as Sierra Interactive).

C. Payment & Billing Data
Payment card information, billing address and transactions handled by our third-party payment processors. REGS does not store full card data unless explicitly stated; payment processors store payment credentials under their terms.

D. Usage & Technical Data
Log data, IP addresses, device and browser information, operating system, pages visited, session duration, feature usage, performance metrics, errors and diagnostic data.

E. Cookies & Tracking
Identifiers placed on devices or browsers (cookies, local storage, pixel tags) used for essential site operations, analytics, performance monitoring and advertising/marketing (where applicable).

F. Support & Communications
Records of communications with support and sales (emails, chat transcripts, recordings where consented), feedback and training participation.

G. Derived & Aggregated Data
Anonymized, aggregated metrics and models derived from Customer Content or usage (these are part of Nova Data and used for product development and analytics).

5. How We Use Information

We use personal information to:

Provide, operate and maintain the Service, including provisioning accounts, onboarding, and support;

Deliver the features of the Service, including dashboards, execution lists, Supernova follow-ups, templates and integrations with third-party platforms;

Process payments, billing and collections;

Communicate about the Service (account notices, updates, support, training and important security messages);

Improve, analyze and develop products and services (including use of aggregated and anonymized Nova Data for analytics and model training);

Prevent, detect and respond to fraud, abuse or security incidents;

Comply with legal obligations, protect legal rights and respond to lawful requests; and

With consent, for marketing and promotional purposes.

Legal bases (where applicable): performance of contract (to provide the Service), legitimate interests (service improvement and fraud prevention), consent (marketing and certain cookies), and legal compliance.

6. Nova Data, Aggregation & Use

REGS owns Nova Data. We may aggregate, de-identify or anonymize Customer Content and usage data to create Nova Data which we use to improve the Service, build analytics and train models. Aggregated or anonymized data does not identify individual customers and is used for lawful business purposes consistent with this Policy and applicable agreements. This use is consistent with REGS’ IP and commercialization framework.

7. How Information Is Shared

We may disclose personal information to:

Service providers and subprocessors. Vendors that provide hosting, analytics, customer support, payments, email delivery and other operational services. These providers act under contract and are required to protect the information.

Integration partners. Third-party platforms you connect to Nova (e.g., Sierra Interactive). Use of such integrations is subject to the third party’s terms and your choices.

Commercial partners & resellers. Where a customer has engaged with a partner or enterprise reseller under a written agreement, limited information may be shared consistent with that agreement and applicable consent. Partner commercial terms are governed by REGS partnership agreements.

Legal and safety circumstances. Where required by law, legal process, or to defend or enforce our rights; to prevent fraud or imminent harm; or to respond to lawful requests by public authorities.

Business transfers. In connection with a merger, acquisition, sale of assets or other corporate transaction, personal information may be transferred as part of the transaction subject to confidentiality and, where required, notice.

Aggregated or anonymized disclosures. REGS may publish aggregated and non-identifiable statistics or share anonymized data with partners.

We do not sell personal information for money. Where we exercise commercial relationships that share customer leads or referral arrangements, those are subject to contractual protections documented in our commercial agreements.

8. International & Cross-Border Transfers

REGS is based in Canada and may transfer and process personal information in Canada, the United States and other jurisdictions where we or our subprocessors operate. When personal information is transferred across borders we apply contractual and organizational safeguards (standard contractual clauses, DPAs, technical controls) to provide an appropriate level of protection. Enterprise customers may request a DPA or specific transfer mechanisms. See Section 12 (Data Processing Addendum).

9. Data Retention & Deletion

Customer Content. We retain Customer Content as long as the Customer’s account is active and thereafter in accordance with our backup and retention policy or as required by law. Customers may export or delete their data via the Service prior to account termination.

Service & Billing Records. We retain transactional, billing and support records for a reasonable period necessary for business and legal purposes.

Aggregated/Anonymized Data. Aggregated or anonymized Nova Data may be retained indefinitely for product development and analytics.

Deletion requests. Where permitted by applicable law, Customers may request deletion of personal information. Deletion may be constrained by contractual obligations, legal holds or technical limitations (for example, residual backups). We will inform requestors of any exceptions.

10. Security

We implement administrative, technical and physical safeguards to protect personal information, including encryption in transit and at rest where feasible, access controls, network protections, monitoring, and employee training. We require subprocessors to maintain reasonable security measures. While we strive to protect information, no system is perfect; we cannot guarantee absolute security.

Incident response & notification. In the event of a data breach that creates a real risk of significant harm, we will investigate and, where required by law, notify affected individuals and regulators as soon as practicable.

11. Your Rights & Choices

Depending on your jurisdiction, you may have rights to:

Access personal information about you and obtain a copy;

Correct inaccurate or incomplete data;

Request deletion of personal information;

Object to or restrict processing (including direct marketing);

Portability of certain personal information to another service provider; and

Withdraw consent where processing is based on consent.

To exercise rights, contact [email protected]. We may need to verify identity and will respond within applicable legal timeframes. For certain requests (for example deletion), REGS may need to retain limited data for legal, safety or legitimate business reasons and will inform you of any legal basis for denial.

12. Data Processing Addendum (DPA) & Enterprise Controls

REGS will enter into a DPA with enterprise or regulated customers on request. The DPA will describe categories of data processed, purposes, subprocessors, security measures and mechanisms to assist with data subject rights and regulatory obligations. To request a DPA or discuss enterprise controls, contact [email protected].

13. Cookies & Tracking

We use cookies and similar technologies. Categories include:

Strictly necessary cookies. Required for site functionality and account access.

Performance & analytics cookies. To understand site and feature usage and improve performance.

Functional cookies. To remember user preferences and facilitate features.

Advertising & marketing cookies. For marketing analytics and to deliver relevant content (where applicable and with consent where required).

You can manage cookie preferences via the cookie banner and browser settings. Blocking cookies may affect functionality.

14. Children

The Service is not intended for children under the age of 16 (or higher age required by local law). We do not knowingly collect personal information from children under applicable age thresholds. If a parent or guardian believes we have collected such information, contact us and we will take steps to remove it.

15. Links to Third-Party Sites

Nova may contain links to third-party websites and services. We are not responsible for third-party privacy practices. Please review the privacy notices of those third parties before providing personal information.

16. Changes to This Policy

We may modify this Privacy Policy. For material changes we will provide notice via the Service or email. Continued use of the Service following notice constitutes acceptance of the revised Policy.

17. Complaints & Supervisory Authorities

If you are not satisfied with our response to a privacy inquiry or request, you may lodge a complaint with a competent data protection authority in your jurisdiction. We will cooperate with supervisory authorities to the extent required by law.

18. Contact Us

For privacy inquiries, to exercise rights, to request a DPA, or for other questions:
[email protected] | [email protected]
Real Estate Growth Solutions Coaching Ltd., Alberta, Canada

19. Additional Notices & Jurisdictional Information

Canadian & Alberta users: We comply with applicable Canadian privacy laws. For Alberta-specific requests, contact us at the addresses above.

European users: Where the GDPR applies, processing is based on contract, legitimate interests, or consent as appropriate; you may exercise GDPR rights by contacting [email protected]. We will provide standard contractual clauses or other mechanisms where required for transfers.

California residents: California residents may have additional rights under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA). To exercise rights, please contact [email protected].

Business transfers & corporate transactions: Personal information may be transferred in connection with a corporate reorganization, sale or transfer of assets; in such events we will seek to ensure the recipient uses personal information in a manner consistent with this Policy.

Note & Sources: This Policy reflects Nova’s legal and commercial position, including REGS’ ownership of Nova and Nova Data, and the commercial partner framework used in REGS’ commercialization and partnership agreements. Please have legal counsel review to ensure compliance with applicable law.