Privacy Policy | Nuvra – Data Protection & User Privacy

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Cookies & Tracking Technologies Policy

Effective Date: 25 January 2025

Issued By: Nuvra Limited (Masdar City Free Zone, Abu Dhabi, UAE)

Contact: privacy@nuvra.agency

1. PURPOSE AND SCOPE

1.1 This Cookies & Tracking Technologies Policy (“Policy”) explains the use of cookies, tracking technologies, and similar mechanisms (“Cookies”) by Nuvra Limited (“Nuvra”, “Nuvra Tech”, “Company”, “we”, “us”, “our”) in connection with the access and use of the Vibe Coding Platform (“Platform”).

1.2 This Policy forms an integral part of the Privacy Policy and applies to all Users who access the Platform through web browsers, mobile browsers, or integrated applications.

1.3 This Policy is established in accordance with the UAE Personal Data Protection Law (PDPL) and its implementing regulations.

2. DEFINITIONS

For the purposes of this Policy:

2.1 “Cookies” means small text files or code fragments stored on a User’s device containing unique identifiers that enable functionality, analytics, or personalization.

2.2 “Tracking Technologies” includes web beacons, pixels, tags, scripts, SDKs, fingerprinting technologies, and similar mechanisms.

2.3 “Personal Data” has the meaning set out in the PDPL and may include identifiers collected through Cookies.

2.4 “Consent” refers to explicit, informed, and freely given agreement by the User to the use of non-essential Cookies.

3. LEGAL BASIS FOR USE OF COOKIES

3.1 Nuvra Tech processes Personal Data through Cookies and related technologies under one of the following lawful bases:

Explicit Consent of the User for non-essential Cookies;
b. Contractual necessity for essential Cookies required for platform functionality;
c. Legitimate interests of the Company, where such interests do not override User rights;
d. Compliance with legal obligations under UAE Law.

3.2 Consent may be withdrawn at any time through the User’s browser settings or cookie management tools provided on the Platform.

4. TYPES OF COOKIES USED

Nuvra Tech uses the following categories of Cookies:

4.1 Strictly Necessary Cookies (Essential)

These Cookies are required to:

enable core Platform functionality;
maintain session integrity;
authenticate User logins;
ensure security of the Platform.

Users cannot disable these Cookies without impairing Platform operation.

Examples include:

session identifiers
load balancing cookies
authentication tokens

4.2 Performance and Analytics Cookies

Used to:

measure User interactions;
evaluate system performance;
diagnose errors;
improve product features.

These Cookies may collect information about:

visited pages
session duration
device type
feature usage patterns

Analytics are typically aggregated and anonymized.

4.3 Functional Cookies

Enhance User experience by remembering:

language preferences
region settings
interface customizations
persistent User configuration

These Cookies are optional and may be disabled by the User.

4.4 Targeting or Advertising Cookies

Used to deliver relevant content or advertisements on external platforms.

These Cookies may:

track browsing behavior across sessions
build anonymized interest profiles
support remarketing campaigns

If Nuvra Tech does not use advertising cookies, this section will be removed prior to publication.

4.5 Third-Party Cookies

Certain Cookies may be set by third-party providers engaged for:

analytics (e.g., Google Analytics alternatives compliant with UAE law)
security monitoring
performance optimization
payment processing
customer support chat widgets (if applicable)

Third parties process data pursuant to contractual obligations aligning with PDPL requirements.

5. PURPOSES OF COOKIE USE

Cookies are used for the following lawful and operational purposes:

5.1 Platform Functionality
To enable authentication, maintain sessions, and support smooth operation.

5.2 Security and Fraud Prevention
To detect unauthorized access, suspicious activity, and ensure cybersecurity compliance.

5.3 Analytics and Performance Monitoring
To improve stability, optimize load distribution, and analyze feature usage.

5.4 Personalization
To tailor user experience, including saved settings and preferences.

5.5 Compliance
To preserve audit logs and ensure adherence to UAE regulatory requirements.

6. RETENTION OF COOKIE DATA

6.1 Cookies may be stored on a User’s device for varying durations:

Session Cookies: deleted when the session ends;
Persistent Cookies: retained for a period not exceeding 24 months, unless a shorter period is operationally sufficient.

6.2 Retention periods for Cookies are consistent with PDPL requirements and aligned with the Data Processing & Retention Policy.

7. USER CONSENT AND CONTROL

7.1 Users will be presented with a Cookie Consent Banner upon first access to the Platform, enabling them to:

accept all Cookies;
reject all non-essential Cookies;
customize Cookie settings.

7.2 Users may modify their consent preferences at any time through:

browser settings;
Platform cookie management interface;
clearing or blocking stored Cookies.

7.3 Disabling certain Cookies may affect availability of features or user experience.

8. THIRD-PARTY DISCLOSURES

8.1 Third-party Cookies may be used only where strictly necessary or with explicit User consent.

8.2 Third parties include:

cloud infrastructure providers;
analytics and monitoring platforms;
security verification services;
payment gateway vendors.

8.3 All third parties operate under contractual Data Processing Agreements (DPAs) compliant with PDPL Article 20.

9. INTERNATIONAL TRANSFERS

9.1 In certain cases, Cookie-derived data may be transferred to servers located outside the UAE.

9.2 Such transfers shall occur only in accordance with PDPL Articles 22–24 through:

adequacy decisions;
contractual safeguards;
explicit User consent;
necessity for service provision.

10. SECURITY MEASURES

Nuvra Tech implements security controls to protect Cookie-derived data, including:

encryption
secure transmission channels (TLS/SSL)
access control policies
intrusion detection
periodic audits and vulnerability assessments

11. USER RIGHTS

Users may exercise all rights granted under PDPL, including:

Right of access
Right of correction
Right of deletion
Right of restriction
Right to withdraw consent
Right to object to processing
Right to data portability

Requests may be submitted to: privacy@nuvra.agency

12. CHANGES TO THIS POLICY

Nuvra Tech reserves the right to update or amend this Policy at any time to reflect:

legal developments;
changes in technology;
modifications in Platform functionality;
operational requirements.

Updates will be published with a revised Effective Date. Continued use of the Platform constitutes acceptance.

13. GOVERNING LAW

This Policy is governed by:

Federal Laws of the United Arab Emirates;
Laws of the Emirate of Abu Dhabi;
Masdar City Free Zone regulations.

14. CONTACT INFORMATION

For inquiries relating to this Policy:

Nuvra Limited
Masdar City Free Zone

Abu Dhabi, United Arab Emirates

privacy@nuvra.agency