Privacy Policy

Effective Date: July 13, 2026
Last Updated: July 13, 2026

1. INTRODUCTION

4Novas LLC ("4Novas," "Angel AI," "we," "us," or "our") operates the Angel AI companion calling service at myangelcalls.com (the "Service"). We recognize that the individuals who use our Service — and particularly the Care Recipients who receive AI check-in calls — are often among the most vulnerable members of our communities. We take that responsibility seriously.

This Privacy Policy describes how we collect, use, disclose, retain, and protect personal information in connection with the Service. It applies to all Subscribers who create accounts and manage enrollments, and to the extent applicable, to Care Recipients whose information is provided to us by Subscribers.

By using the Service, you agree to the collection and use of information as described in this Privacy Policy. If you do not agree, please discontinue use of the Service.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Subscriber Account Information

When you register for an account, we collect your full name, email address, telephone number, mailing or billing address, password credentials, and relationship to the Care Recipient.

Care Recipient Profile Information

When you enroll a Care Recipient, we collect the Care Recipient's name, telephone number, date of birth, preferred call times and frequency, and any supplemental context you choose to provide to personalize call interactions (such as hobbies, general health context, or topics of comfort and familiarity). You are responsible for providing only information for which you have authority to disclose.

Payment Information

Subscription payments are processed through a third-party payment processor. We collect and store limited payment-related information (such as the last four digits of a card and billing address) for account management purposes. Full payment card numbers are processed and stored by our payment processor and are never stored on 4Novas servers.

Communications

If you contact us via email, our website, or support channels, we retain records of those communications to assist in resolving your inquiry and improving our service.

2.2 Information Generated Through the Service

Call Recordings and Transcripts

With consent as described in our Terms of Service, AI-generated calls to Care Recipients may be recorded and transcribed. These recordings and transcripts are processed by our AI systems to generate wellness reports and are retained in accordance with our data retention practices described in Section 7.

AI-Derived Wellness Data

Our AI systems analyze call interactions to generate wellness assessments including estimated mood scores, topics discussed, potential concerns or distress signals detected, resources referenced or recommended, and follow-up action recommendations. This derived wellness data is made accessible to the Subscriber through in-app wellness reports and notifications.

Call Metadata

We collect operational data about each call, including the date, time, duration, call outcome (completed, missed, unanswered), and retry and escalation event logs.

Escalation and Alert Events

When our systems detect patterns associated with wellness concerns, missed calls, or distress indicators, we generate and log escalation alerts delivered to the Subscriber.

2.3 Information Collected Automatically

Usage Data

When you access our website or account dashboard, we collect information about pages viewed, features used, links clicked, session duration, and general navigation patterns.

Technical and Device Data

We collect device type, operating system, browser type and version, IP address, approximate geographic location (city or region level), referring URLs, and similar technical identifiers. This information is used for security, fraud prevention, and service optimization.

Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to maintain session state, remember preferences, analyze traffic, and improve our website experience. You can configure your browser to refuse cookies; however, some features of the Service may not function properly if cookies are disabled.

2.4 Information from Third Parties

We may receive information from payment processors (transaction confirmations, billing status), telephony providers (call delivery status, carrier data), and analytics platforms, which we use to operate, maintain, and improve the Service.

3. HOW WE USE YOUR INFORMATION

We use the information we collect for the following purposes:

• (a) Service Delivery — To place scheduled AI check-in calls, generate wellness summaries, deliver escalation alerts, and fulfill all Service obligations;
• (b) Account Management — To create and manage your account, process subscriptions and payments, and send transactional communications including receipts, renewal reminders, and account notifications;
• (c) Call Personalization — To tailor AI call interactions to the Care Recipient's background, preferences, and comfort topics as provided by the Subscriber;
• (d) Wellness Reporting — To produce AI-generated post-call wellness summaries and trend analyses for the Subscriber;
• (e) Service Improvement — To evaluate service quality, identify patterns, conduct internal research, and improve our AI models, using only anonymized and aggregated data;
• (f) Safety and Fraud Prevention — To detect, investigate, and prevent fraudulent activity, unauthorized access, security threats, and Terms of Service violations;
• (g) Legal Compliance — To comply with applicable federal and state laws, respond to legal process, and enforce our Terms of Service;
• (h) Customer Support — To respond to your inquiries, resolve issues, and improve support quality.

We do not use personal information for third-party advertising, behavioral targeting, or data brokerage.

4. HOW WE SHARE YOUR INFORMATION

We do not sell, rent, trade, or otherwise disclose for valuable consideration any personal information or Care Recipient data to third parties.

We share information only as described below:

4.1 Service Providers and Subprocessors

We engage trusted third-party vendors to help us operate and deliver the Service. These vendors are authorized to use your information only as necessary to provide services on our behalf and are contractually required to maintain appropriate data security standards. Current categories of service providers include:

• Payment Processors — For subscription billing, payment authorization, and fraud prevention
• Telephony and Voice AI Providers — For AI call placement, voice processing, and call delivery
• Cloud Infrastructure and Hosting Providers — For data storage, compute resources, and system operations
• Customer Relationship Management Platforms — For subscriber account management and communication logging
• Email and SMS Delivery Providers — For transactional messages, wellness alerts, and account notifications

4.2 Legal Requirements and Safety

We may disclose personal information if we believe in good faith that disclosure is required or permitted by:

• (a) Applicable law, regulation, or legal process (including valid subpoenas, court orders, or government demands);
• (b) The need to protect the rights, property, or safety of 4Novas, our Subscribers, Care Recipients, or the general public;
• (c) The investigation or prevention of fraud, security breaches, or illegal activity.

Where legally permissible, we will attempt to notify you before disclosing your information pursuant to legal process.

4.3 Business Transfers

In the event of a merger, acquisition, sale of all or a portion of our assets, reorganization, or bankruptcy proceeding, personal information may be transferred to the successor or acquiring entity. We will provide notice of such transfer and the privacy practices of the successor entity prior to any transfer becoming effective.

4.4 With Your Consent

We may share personal information for purposes not described in this Policy with your express prior written consent.

5. WELLNESS DATA — HEIGHTENED PROTECTION

Angel AI processes sensitive wellness-derived information generated from AI analysis of Care Recipient call interactions. We apply the following heightened protections to this data:

• (a) Wellness data — including mood assessments, flagged concerns, and AI-generated notes — is accessible only to the enrolled Subscriber and to 4Novas personnel with a documented operational need;
• (b) Wellness data is never sold, licensed, or shared with insurers, employers, healthcare clearinghouses, pharmaceutical companies, or marketing entities;
• (c) Wellness data is used exclusively to provide the Service to the enrolled Subscriber and to improve our AI systems in anonymized, non-identifiable form;
• (d) All wellness data is treated as sensitive personal information regardless of applicable legal classification;
• (e) Wellness assessments generated by Angel AI do not constitute clinical evaluations, medical records, or professional diagnoses and should not be treated or relied upon as such.

6. CALL RECORDING — NOTICE AND CONSENT

In compliance with the Federal Wiretap Act and applicable state call recording laws (which vary by state and may require all-party consent), 4Novas implements the following practices:

• (a) Where required by law, a verbal disclosure is provided at the beginning of each AI-generated call notifying the Care Recipient that the call may be recorded and processed by an AI system;
• (b) By enrolling a Care Recipient, Subscribers represent that they have proper authority to consent to recording on the Care Recipient's behalf, or that the Care Recipient has directly consented;
• (c) Care Recipients in states with all-party consent recording laws (including California, Florida, Illinois, Maryland, Massachusetts, Nevada, New Hampshire, Oregon, Pennsylvania, and Washington) may have additional rights. Subscribers in those states should ensure Care Recipient consent is clearly documented;
• (d) Subscribers may request information about call recording practices by contacting privacy@myangelcalls.com.

7. DATA RETENTION

We retain personal information for as long as your account is active and as needed to provide the Service, comply with our legal obligations, resolve disputes, and enforce our agreements. Our general retention schedule is as follows:

You may request earlier deletion of specific categories of data by submitting a request to privacy@myangelcalls.com. We will process such requests subject to our legal retention obligations.

8. DATA SECURITY

4Novas implements industry-standard administrative, technical, and physical security measures to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. Our security program includes:

• (a) Encryption of personal data in transit using Transport Layer Security (TLS);
• (b) Encryption of personal data at rest using AES-256 encryption or equivalent;
• (c) Role-based access controls limiting personnel access to personal data on a strict need-to-know basis;
• (d) Regular security assessments, vulnerability scanning, and penetration testing;
• (e) Third-party vendor security review and contractual data protection requirements;
• (f) Incident response procedures for detecting and responding to potential data security events.

No method of data transmission or storage is 100% secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 4Novas will notify affected individuals as required by applicable law.

9. YOUR PRIVACY RIGHTS

9.1 General Rights (All Users)

Regardless of your location, you may exercise the following rights by submitting a request to privacy@myangelcalls.com:

• (a) Right to Access — Request confirmation of whether we process your personal information and obtain a copy of the specific information we hold;
• (b) Right to Correction — Request correction of inaccurate or incomplete personal information;
• (c) Right to Deletion — Request deletion of your personal information, subject to our legal retention obligations and operational necessity;
• (d) Right to Opt Out — Opt out of non-essential or marketing communications at any time;
• (e) Right to Data Portability — Request a copy of your account data in a structured, machine-readable format where technically feasible;
• (f) Right to Withdraw Consent — Where processing is based on consent (including consent to call recording), withdraw that consent at any time, understanding that withdrawal may impact Service availability.

We will respond to all verifiable privacy rights requests within 45 days, or within the timeframe required by applicable law.

9.2 California Residents — CCPA / CPRA

If you are a California resident, you have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA/CPRA):

• (a) Right to Know — The categories and specific pieces of personal information collected, the purposes of collection, and the categories of third parties to whom information is disclosed;
• (b) Right to Delete — Deletion of personal information collected from you, subject to applicable exceptions;
• (c) Right to Correct — Correction of inaccurate personal information;
• (d) Right to Opt Out of Sale or Sharing — 4Novas does not sell personal information and does not share personal information for cross-context behavioral advertising purposes;
• (e) Right to Limit Use of Sensitive Personal Information — To the extent 4Novas processes sensitive personal information (including wellness-derived data), you may request that its use be limited to what is necessary for Service delivery;
• (f) Right to Non-Discrimination — 4Novas will not discriminate against you in price, service quality, or access for exercising any CCPA/CPRA right.

To submit a California privacy request, contact privacy@myangelcalls.com. We honor requests from authorized agents with appropriate written authorization.

9.3 Virginia Residents — VCDPA

Virginia residents have rights under the Virginia Consumer Data Protection Act (VCDPA) including the right to access, correct, delete, and obtain a portable copy of personal data, and the right to opt out of targeted advertising, profiling for decisions with significant effects, and sale of personal data. To submit a VCDPA request, contact privacy@myangelcalls.com.

9.4 Additional State Privacy Rights

Residents of Colorado (CPA), Connecticut (CTDPA), Texas (TDPSA), Oregon (OCPA), and other states that have enacted comprehensive consumer privacy legislation may have similar rights to those described above. We are committed to honoring applicable state privacy rights. Contact privacy@myangelcalls.com to exercise any state privacy right.

9.5 How to Submit a Request

To exercise any privacy right, submit a written request to privacy@myangelcalls.com with:

• Your full name and email address associated with your account
• A description of the right you wish to exercise
• Sufficient information to verify your identity

We may request additional verification before processing your request. We will not charge a fee for reasonable requests.

10. CHILDREN'S PRIVACY

The Service is designed for and directed to adults. We do not knowingly collect personal information from children under the age of 13. If we learn that we have inadvertently collected personal information from a child under 13, we will promptly delete such information.

Care Recipients enrolled in the Service are expected to be adults. Enrollment of a minor as a Care Recipient may only be performed by that minor's parent or legal guardian, who is solely responsible for obtaining all applicable consents and ensuring the appropriateness of the Service for the minor.

If you believe a child under the age of 13 has had their personal information submitted to us without parental consent, please contact privacy@myangelcalls.com immediately.

11. AI AND AUTOMATED PROCESSING

The Angel AI Service is powered by artificial intelligence and automated processing systems. We are committed to transparency about how these systems work and how they affect you:

• (a) AI-Generated Calls — All check-in calls are conducted by an artificial intelligence voice agent, not a human. Care Recipients are informed of this at the start of each call;
• (b) Automated Wellness Analysis — Wellness assessments, mood scores, concern flags, and follow-up recommendations are generated by automated AI analysis of call content. These are not clinical evaluations;
• (c) Escalation Logic — Escalation alerts are triggered by AI detection of patterns associated with missed calls, distress signals, or wellness concerns. These automated triggers are designed to supplement — not replace — human judgment;
• (d) No High-Stakes Automated Decisions Without Oversight — 4Novas does not use automated processing to make decisions with legal or similarly significant effects on individuals without appropriate human review and the opportunity to contest such decisions;
• (e) AI Limitations — AI systems are imperfect and may misinterpret context, tone, or content. Wellness reports and alerts should be treated as informational supplements, not as definitive assessments.

12. TELEPHONE COMMUNICATIONS AND SMS

By using the Service, you consent to receive:

• (a) AI-generated outbound calls to the Care Recipient at the enrolled telephone number, at scheduled times;
• (b) SMS or text message notifications to the Subscriber's telephone number for account alerts, missed call notifications, escalation alerts, wellness summaries, and other Service-related communications.

Standard carrier messaging and data rates may apply for SMS communications. You may opt out of SMS notifications at any time by replying STOP to any SMS from Angel AI or by contacting support@myangelcalls.com. Note that opting out of certain critical communications (such as escalation alerts) may affect the Subscriber's ability to receive timely care notifications.

13. THIRD-PARTY LINKS

Our website may contain links to third-party websites or services that are not operated or controlled by 4Novas. This Privacy Policy applies solely to the Angel AI Service. We are not responsible for the privacy practices or content of third-party sites and encourage you to review their privacy policies independently.

14. INTERNATIONAL USERS

The Service is operated from and data is processed within the United States. If you access the Service from outside the United States, your personal information will be transferred to and processed in the United States. Data protection laws in the United States may differ from those in your jurisdiction. By using the Service from outside the United States, you consent to such transfer and processing.

15. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. We will notify you of material changes by:

• (a) Posting the revised Privacy Policy at myangelcalls.com/privacy with an updated effective date;
• (b) Where practicable, sending email notice to your registered email address prior to the change taking effect.

Your continued use of the Service following the effective date of any update constitutes your acceptance of the revised Privacy Policy.

16. CONTACT US

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

4Novas LLC
Washington, D.C., United States

Privacy Inquiries: privacy@myangelcalls.com
General Support: support@myangelcalls.com
Website: myangelcalls.com

For formal privacy rights requests, please email privacy@myangelcalls.com with the subject line: "Privacy Rights Request — [Your Name]."

This Privacy Policy was last updated on July 12, 2026.