Privacy Policy

1. Introduction

Nelieo ("Nelieo," "we," "us," or "our") is committed to protecting your privacy and ensuring transparency in how we collect, use, and safeguard your personal data. This Privacy Policy explains our practices regarding data collection and processing when you use our AI-native operating system and related services (collectively, the "Services").

This policy applies to all users of our website, waitlist, and Services. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy.

2. Data Controller

The controller within the meaning of data protection laws, in particular the EU General Data Protection Regulation (GDPR) and California Consumer Privacy Act (CCPA), is:

For any questions regarding this Privacy Policy or our data processing practices, please contact our Data Protection Officer using the contact details above.

3. Data We Collect

We collect several types of information from and about users of our Services:

3.1 Information You Provide

3.2 Automatically Collected Information

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Data: Pages visited, features used, interaction patterns, session duration
• Location Data: General location based on IP address (country/region level)
• Cookies & Tracking: See Section 9 for detailed information
• Log Data: Server logs, error reports, performance metrics

3.3 Information from Third Parties

We may receive information about you from third-party services you choose to connect with our Services, such as OAuth providers (Google, Microsoft), analytics providers, and business intelligence tools.

4. Legal Basis for Processing

Under GDPR, we process your personal data based on the following legal grounds:

5. How We Use Your Data

We use the collected information for the following purposes:

6. Data Sharing & Processors

We do not sell your personal data. We may share your information with the following categories of recipients:

6.1 Service Providers (Processors)

6.2 Other Disclosures

• Legal Requirements: When required by law, court order, or government request
• Business Transfers: In connection with mergers, acquisitions, or asset sales
• Protection: To protect our rights, privacy, safety, or property
• With Consent: When you explicitly authorize disclosure

7. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required by law.

Upon deletion, data is removed from active systems within 30 days and from backups within 90 days.

8. Your Rights as a Data Subject

Depending on your location, you have the following rights regarding your personal data:

8.1 How to Exercise Your Rights

To exercise any of these rights, please contact us at triunex.shorya@gmail.com with:

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

Response Time: We will respond to your request within 30 days (GDPR) or 45 days (CCPA) of verification.

8.2 Supervisory Authorities

You have the right to lodge a complaint with your local supervisory authority:

10. International Data Transfers

As a global service, we may transfer your personal data to countries outside your jurisdiction, including to the United States where our primary servers are located.

10.1 Transfer Mechanisms

For transfers from the EU/EEA to third countries, we implement appropriate safeguards:

10.2 Additional Safeguards

• Encryption: All data transfers are encrypted using TLS 1.3
• Data Processing Agreements: Binding contracts with all processors
• Security Measures: Technical and organizational measures meeting EU standards
• Regular Audits: Compliance assessments of transfer mechanisms

You can request copies of the safeguards we have in place by contacting triunex.shorya@gmail.com.

9. Cookies & Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver personalized content.

9.1 Types of Cookies We Use

9.2 Third-Party Cookies

We work with third-party services that may set their own cookies:

• Google Analytics: Website analytics and user behavior tracking
• YouTube: Video embedding and playback
• Stripe: Payment processing and fraud detection

9.3 Managing Cookie Preferences

You can control cookies through:

• Cookie Consent Banner: Adjust preferences through our cookie consent tool
• Browser Settings: Configure your browser to reject or delete cookies
• Opt-Out Tools: Use industry opt-out mechanisms like DAA Opt-Out or Your Online Choices

11. Security Measures

We implement comprehensive technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or alteration.

11.1 Technical Safeguards

11.2 Organizational Measures

• Employee Training: Regular privacy and security training for all staff
• Data Minimization: Collect only necessary data
• Access Logging: Audit trails for all data access
• Vendor Management: Due diligence on all third-party processors
• Incident Response: Documented breach notification procedures

11.3 Certifications & Compliance

12. Third-Party Services

Our Services integrate with various third-party platforms. When you use these integrations, additional privacy policies may apply.

12.1 Analytics & Performance

12.2 Payment Processing

12.3 Communication & Email

12.4 Embedded Content

12.5 Social Media

We use a 2-click solution for social media plugins to protect your privacy:

• Plugins are initially inactive
• No data is transmitted until you manually activate them
• Activation enables direct connection to the social network
• If you're logged into the social network, your visit may be tracked

13. Children's Privacy

Our Services are not intended for individuals under the age of 16 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal data from children.

13.1 Age Verification

• We require users to confirm they meet the minimum age requirement
• Account creation is restricted to individuals 16 years or older
• We implement age-appropriate design measures

13.2 Parental Rights

If you believe we have inadvertently collected data from a child:

• Contact us immediately at triunex.shorya@gmail.com
• We will delete the data within 48 hours of verification
• Parents can request access to their child's data

14. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

14.1 California Consumer Rights

14.2 Categories of Personal Information

In the past 12 months, we have collected the following categories of personal information:

• Identifiers (name, email, IP address)
• Commercial information (transaction history)
• Internet activity (browsing behavior, interactions)
• Geolocation data (general location)
• Inferences (preferences, characteristics)

14.3 Sale of Personal Information

14.4 Exercising California Rights

To submit a request, contact us at:

• Email: triunex.shorya@gmail.com
• Subject Line: "California Privacy Rights Request"
• Include: Your name, email, and specific right you wish to exercise

Verification: We will verify your identity before processing requests. Response within 45 days.

14.5 Authorized Agent

You may designate an authorized agent to make a request on your behalf. The agent must provide proof of authorization.

14.6 "Shine the Light" Law

California Civil Code Section 1798.83 permits California residents to request information about disclosures to third parties for direct marketing. We do not share personal information with third parties for their direct marketing purposes.

15. GDPR Compliance (EU/EEA/UK)

For individuals in the European Union, European Economic Area, and United Kingdom, we comply fully with the General Data Protection Regulation (GDPR).

15.1 Lawful Basis Summary

15.2 Data Protection Officer

You can contact our Data Protection Officer at: triunex.work@gmail.com

15.3 Representative in the EU

If required under GDPR Article 27, we will appoint an EU representative and provide contact details here.

15.4 Cross-Border Transfers

We use Standard Contractual Clauses (SCCs) approved by the European Commission for transfers outside the EU/EEA. See Section 10 for details.

15.5 Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority in your EU member state:

• Find your authority: EDPB Member List
• UK: Information Commissioner's Office

16. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

16.1 Notification of Changes

• Material Changes: We will notify you via email and/or prominent notice on our website at least 30 days before changes take effect
• Minor Changes: Updated "Last Updated" date at the top of this policy
• Version History: Available upon request

16.2 Your Continued Use

Your continued use of our Services after the effective date of changes constitutes acceptance of the updated policy. If you do not agree to changes, please discontinue use and contact us to delete your account.

16.3 Archived Versions

Previous versions of this Privacy Policy are archived and available upon request at triunex.shorya@gmail.com.

17. Contact Information

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

17.1 Request Response Time

• GDPR (EU/UK): Within 30 days (may extend to 60 days for complex requests)
• CCPA (California): Within 45 days (may extend to 90 days)
• General Inquiries: Within 3 business days