Legal · Privacy

Privacy Policy

Effective Date

25 January 2025

Entity

Nuvra Limited — Masdar City Free Zone, Abu Dhabi, UAE

Contact

hey@nuvra.agency

Section 01

Purpose and Scope

1.1 This Privacy Policy ( “Policy”) sets out the principles governing the collection, processing,
retention, transfer, disclosure, and protection of Personal Data by Nuvra Limited (“Nuvra”, “Nuvra Tech”, “Company”, “we”, “us”, “our”) in accordance with:

1.2 This Policy applies to all Users of the Vibe Coding Platform (“Platform”), including registered Users, subscribers, website visitors, and API consumers.

1.3 By accessing or using the Platform, the User expressly acknowledges and consents to the practices described herein.

Definitions​

Section 02

For purposes of this Policy:

2.1 “Personal Data” means any data relating to an identified or identifiable natural person, as defined under the UAE PDPL.

2.2 “Processing” means any operation performed on Personal Data, including collection, storage, use, retrieval, disclosure, transfer, or deletion.

2.3 “Controller” means Nuvra Limited, which determines the purpose and means of processing Personal Data.

2.4 “Processor” means any third party engaged by the Company to process Personal Data on its behalf.

2.5 “User Data” means Personal Data collected from or relating to Users of the Platform.

2.6 “AI Output Data” means machine-generated content or results produced by the Platform in response to User inputs.

Section 03

Lawful Basis for Processing

We process Personal Data under one or more of the lawful bases permitted by the PDPL, including:

3.1 Consent freely given and informed by the User

3.2 Contractual necessity to provide Services under the Terms of Service

3.3 Legitimate interests of the Company, provided they do not override User rights

3.4 Compliance with legal obligations under UAE Law

3.5 Protection of public interest

Where consent is required, Users may withdraw consent at any time without affecting prior lawful processing.

Section 04

Categories of Data We Collect

We may collect the following categories of Personal Data:

4.1 Identity and Account Data

4.2 Subscription and Billing Data

4.3 Usage and Technical Data

4.4 User-Generated Inputs

4.5 AI Outputs

4.6 Communications Data

4.7 Cookies and Tracking Data

(See the Cookies Policy for full details.)

Section 05

Purposes of Processing Personal Data

Personal Data is processed for the following purposes:

5.1 Provision of Services

To authenticate users, allocate subscription resources, process requests, and deliver technical functionality.

5.2 Administration and Operations

To manage accounts, subscriptions, billing cycles, and user activity.

5.3 Security and Fraud Prevention

To detect unauthorized activity, enforce access controls, and prevent cybercrime as required by UAE Law.

5.4 Platform Improvement and Analytics

To monitor usage trends, enhance system performance, and develop new features.

5.5 Customer Support

To respond to inquiries, troubleshoot issues, and provide technical assistance.

5.6 Legal and Regulatory Compliance

To comply with PDPL, Cybercrime Law, tax requirements, and other statutory obligations.

5.7 AI Model Enhancement (Optional, with User Consent)

We may process anonymized and aggregated data for internal model improvement. We do not use identifiable Personal Data for AI model training without explicit consent.

Section 06

Disclosure of Personal Data

We may disclose Personal Data to the following parties:

6.1 Third-Party Processors

Including but not limited to:

All Processors operate under written agreements compliant with PDPL Article 26.

6.2 Legal and Regulatory Authorities

Where disclosure is required under UAE Law, including for:

6.3 Affiliates and Group Companies

For operational support and service delivery, provided such entities comply with this Policy.

6.4 Business Transfers

In the event of a merger, restructuring, or sale of assets, Personal Data may be transferred subject to equivalent protections.

We do not sell Personal Data under any circumstances.

Section 07

International Data Transfers

7.1 Personal Data may be transferred outside the UAE where necessary for service provision.

7.2 All transfers shall comply with PDPL Articles 22-24, using one of the following mechanisms:

7.3 Users acknowledge that data stored on foreign servers may be subject to the laws of the host jurisdiction.

Section 08

Data Retention

8.1 We retain Personal Data only for the minimum period necessary to fulfill the purposes outlined in this Policy or as required by UAE Law.

8.2 Retention periods include:

Section 09

User Rights Under UAE PDPL

Users have the following rights, subject to lawful exceptions:

9.1 Right to Access

To obtain confirmation of processing and access a copy of Personal Data.

9.2 Right to Correction

To request correction of updating of inaccurate or incomplete data.

9.3 Right to Deletion

To request deletion of Personal Data where:

9.4 Right to Restrict Processing

To request suspension of data processing.

9.5 Right to Data Portability

To receive Personal Data in a machine-readable format.

9.6 Right to Object

To object to processing based on legitimate interests.

9.7 Right Not to Be Subject to Automated Decisions

Where such decisions have legal or materially significant effects.

Submitting Requests: Requests shall be directed to: privacy@nuvra.agency

We will respond within the timeframe mandated under PDPL.

Section 10

Security Measures

We employ administrative, technical, and organizational safeguards consistent with UAE PDPL, including:

Section 11

Data Breach Notification

11.1 In the event of any Personal Data breach that may pose a risk to Users, Nuvra Tech shall notify:

in accordance with PDPL Articles 9 and 10.

11.2 Notifications will include the nature of the breach, likely consequences, and remedial measures taken.

Section 12

Children's Data

12.1 The Platform is not knowingly intended for individuals under the age of 18.

12.2 We do not knowingly collect Personal Data from minors. Any such data, if detected, shall be deleted immediately.

Section 13

Governing Law

This Policy is governed by:

Section 14

Changes to This Policy

Nuvra Tech reserves the right to amend this Policy at any time to reflect legal, operational, or technological changes.

Updates will be posted on the Platform with a revised Effective Date.

Continued use of the Platform constitutes acceptance of the updated Policy.

Section 15

Contact Information

For questions, requests, or concerns relating to this Policy, Users may contact:

Nuvra Limited
Masdar City Free Zone
Abu Dhabi, United Arab Emirates
Email: privacy@nuvra.agency

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