House of NOVV Privacy Policy

1. Data controller / operator

HOUSE OF NOVV is operated by MEDIAID HOLDINGS SDN. BHD. (Registration No. 202601004736), Colony @ The

MET, Mont Kiara, THE MET CLUB by Colony, A-10-02, Menara The Met, No. 20, Jalan Dutamas 2, 50480 Kuala

Lumpur, Malaysia ("MEDIAID", "NOVV", "we", "us" or "our").

This Privacy Policy explains how MEDIAID/NOVV processes personal data in connection with HOUSE OF NOVV. It is

intended to operate alongside Malaysia's Personal Data Protection Act 2010 (Act 709), as amended, and applicable

regulations/guidance.

2. Information we may collect

• Identity/contact and registration data, such as name, age or date-of-birth range, telephone number, email

address and queue/priority-access information where provided.

• Screening inputs and outputs, including information entered for a scan and estimated physiological/wellness

markers generated during facial analysis.

• Body-composition data, such as weight, body-fat percentage, muscle-related estimates, BMI and other analyser

outputs.

• Health information that you voluntarily disclose when discussing results or possible next steps.

• Consent and operational records, including consent status, date/time, session identifiers and technical logs

reasonably needed for administration, security or troubleshooting.

• Photographs and video of the HOUSE OF NOVV activation, which may include participants. Screen results and health data are not filmed or published.

3. Sensitive personal data and express consent

HEALTH DATA

Information concerning health or physical or mental condition is sensitive personal data under Malaysian

data-protection law. Where express consent is required, HOUSE OF NOVV obtains it through the required

affirmative digital consent checkbox before the screening.

Your consent is voluntary. If you do not consent to processing needed for a particular screening feature, NOVV may

be unable to provide that feature.

4. Facial scan and camera processing

The facial scan uses third-party wellness technology, currently Shen.AI, to analyse camera-derived facial signals

and estimate selected wellness markers. NOVV uses this function for general wellness/informational screening only

and does not intend to use the scan for facial recognition or identity matching.

The resulting measurement values may be displayed and may be retained by NOVV where reasonably necessary to

provide the experience, give you your results, maintain consent/operational records, respond to your request, or

support a later NOVV journey that you affirmatively choose. The facial-scan result is not treated by NOVV as

validated diagnostic data.

Third-party processing may also be subject to the relevant provider's technical and privacy practices. NOVV will

seek to use providers and arrangements appropriate to the data and purpose involved.

5. Purposes of processing

• To register you, manage the queue/priority-access process and deliver the screening you request.

• To generate, display and explain wellness-screening results.

• To maintain records of consent, safety, quality and technical administration.

• To respond when you ask to continue into a separate NOVV online assessment or health service.

• To comply with applicable legal, regulatory, professional, insurance, security, accounting or dispute-resolution

requirements.

• To create marketing and social media content about HOUSE OF NOVV, where you have not asked to be excluded.

6. What NOVV will not do with screening data

NOVV will not use the HOUSE OF NOVV facial-scan result by itself to diagnose disease, prescribe treatment,

determine medication suitability or replace appropriate clinical assessment.

NOVV does not intend to sell identifiable health-screening data. NOVV does not intend to use the facial scan for

facial recognition or identity matching.

7. Disclosure and service providers


Access is limited to persons who reasonably need information for the stated purposes. This may include authorised

NOVV/MEDIAID personnel and doctors, technology and IT/service providers supporting the activation, professional

advisers and authorities where disclosure is required or permitted by law.

NOVV aims to disclose only information reasonably necessary for the relevant function and to apply appropriate

contractual, technical and organisational safeguards where a provider processes data on its behalf.

8. Cross-border processing

Some technology or infrastructure providers may process or host information outside Malaysia. Where a

cross-border transfer occurs, NOVV will take reasonable steps to comply with applicable Malaysian requirements

and use appropriate safeguards.

9. Security

NOVV uses reasonable technical and organisational measures appropriate to the nature of the information,

including access limitation, device controls and appropriate storage/transmission safeguards. No system can be

guaranteed completely secure. Data incidents will be assessed and handled in accordance with applicable legal

requirements.

10. Retention

Personal data will be kept only as long as reasonably necessary for the purposes described, any service you later

request, and applicable legal, professional, insurance, accounting or dispute-resolution requirements. Information

no longer required should be deleted, destroyed or de-identified using reasonable measures.

If you later enter a separate NOVV clinical pathway, information collected in that pathway may be governed by

additional privacy notices and medical-record retention requirements.

11. Your rights and choices

Subject to applicable law, you may request information about processing, access or correction of personal data,

withdraw consent for future consent-based processing, and object to or opt out of direct marketing.

Withdrawal does not retrospectively invalidate lawful processing that occurred before withdrawal and may prevent NOVV from

continuing a consent-dependent feature.

NOVV may need to verify your identity before responding to a data-rights request.

You may ask us to remove or blur identifiable photos or videos of you at any time by contacting contact@novvhealth.com.