Welcome to Nuly AI and our website and web application at nuly.ai. This Privacy Policy applies to Personal Data that we, Nuly AI of 71-75 Shelton Street Covent Garden, London, UK(“Nuly AI”, “we”, “us”, or “our”), collect from our users of our website and web application (our “Services”) and other online users (hereinafter “you”), as well as information that we collect automatically during your visits of our website (e.g., information collected via cookies).

For purposes of this Privacy Policy, “business partners” means any subcontractors, contractors, or other legal entities with whom we have an ongoing business relationship to provide our services or information.

“Personal Data” means any information relating to an identified or identifiable natural person. This is, for example, name or address data, telephone number, mobile number, bank details, or insurance number. However, Personal Data also includes online identifiers such as your device ID and IP address.

We act as the data controller in accordance with the UK`s Data Protection Act (DPA) and the EU`s General Data Protection Regulation (GDPR).

Legal basis for processing

Our legal basis for collecting and using your Personal Data as described in this Privacy Policy depends on the Personal Data involved and the specific context in which we collect it. Generally, your Personal Data will be collected and processed by us on one or more of the following legal bases:

Your consent compliance with contractual obligations, compliance with legal obligations, and on the basis of our legitimate interests.

If you have any questions or need more information about the legal basis for the collection of your Personal Data, please contact us at support@nuly.ai

Information we collect

We may ask you for Personal Data when you:

Use our website and services, request services or information, participate online or otherwise in marketing and advertising activities, subscribe to our marketing and promotional emails or other materials, interact with us on third-party social networking sites (subject to the terms of use and privacy policies of said third parties); or contact us.

Data Automatically Collected by Us

We may automatically collect information about user behaviour and usage of our Services, your visits to our website, the links you click, and other actions you take in connection with our website and our Services.

We may also collect certain information about the browser you use to access our website and our Services, such as your IP address, device identifier, location data, browser type and language, your access times, the URL (“Uniform Resource Locator”).

Data from third-party sources

We may obtain data about you from third-party sources, such as our business partners, joint marketing partners, social networks, and other third parties. We may use this data to better analyse your user behaviour and your use of our Services to improve our ability to provide you with relevant marketing information and services, and to prevent and combat fraud.

Cookies

We use so-called cookies on our website. Cookies are small text files that are stored on your respective devices (PC, smartphone, tablet, etc.) and saved by your browser. For further information please refer to our Cookie Policy. The legal basis for the use of cookies is your consent as well as our legitimate interest.

Hosting

To provide our website, we use the services of:

Hostinger.com

which processes the data listed below and all data to be processed in connection with the operation of this website (log file when visiting the website) on our behalf. The legal basis is our legitimate interest.

Contacting us

If you contact us, we process the following data from you for the purpose of processing and handling your request: first name, last name, e-mail address, and, if applicable, other information if you have provided it, and your message. The legal basis for the data processing is our obligation to fulfill the contract and/or to fulfill our pre-contractual obligations and/or our legitimate interest in processing your request.

Account and Registration

To use all features of our Services, you can register and log in. Here, too, we process data in order to create a user account for you: Name, E-mail address, and chosen password. We store this data as long as you are registered with us. If you delete your account, we will delete your data unless there is a legal retention period on our part. In this case, we must store your data for longer in accordance with the UK`s Statutory Retention requirements and up to seven years. In addition, we process data that is required for the services we offer or your Services membership. The legal bases for processing are the contract and our legitimate interest.

Our Services

We process the Personal Data that arises when you use our services in order to provide our contractual services such as a user’s Full Name, Title, Email address, and billing details, if any. In particular, this includes our support, correspondence with you, invoicing, and fulfillment of our contractual, accounting, and tax obligations. Accordingly, the data is processed on the basis of the fulfillment of our contractual obligations and our legal obligations.

We also process the data of our service users in order to be able to provide our AI Services (AI Voiceover, Video Scripts Writer, Rephraser, Rewrite with Keywords, AI Chat, AI Code etc.) as well as to ensure security and to be able to develop it further.

The type of data processed depends on how you use our services and some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data. You have choices about the Personal Data you provide and how you share it. You don’t have to provide Personal Data or Special Category Data; however, information about you helps you to get more from our Services. It’s your choice whether to include Personal Data or Special Category Data and to make that information available to us. Please do not share information that you would not want to be available.

The legal basis for the processing of your Personal and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent. You may withdraw your consent and request us to stop using and/or disclosing your Personal and Special Category Data by submitting your request to us. You can further change and update your account details in your profile and if you wish you may also delete your account using the Delete Account feature.

If you pay for Service Credits, your payment data will be processed via our payment service provider

Stripe

Payment data will solely be processed through Stripe and we have no access to any Payment Data you may submit. The legal basis for the provision of a payment system is the establishment and implementation of the user contract for the use of the service.

Lastly, we also process data in the context of administrative tasks and the organisation of our business and compliance with legal obligations, such as archiving. In this context, we process the same data that we process in the provision of our contractual services. The processing bases are our legal obligations and our legitimate interests.

Our use of Personal Data

We may use your Personal Data for the following purposes:

Providing you with our services and support, and conducting the transactions you request.

Sending notifications to you, including information about the status of your transaction, including information about the services, about specific business partner programs in which you may wish to participate, about solutions and services available from us.

Enabling you to use our website and Services, Providing support to respond to your online inquiries.

Customise, analyse and optimise our solutions, services (including content to gauge usage trends and determine the effectiveness of our marketing campaigns), technologies, notifications and business relationships with you,Better understanding our service and website users.

Personalising content and implementing your preferences.

Enforcing our terms and conditions, and separate contracts (if any) with you,Prevention of fraud and other prohibited or unlawful activities.

Protecting the security and integrity of our websites, businesses, and services; andOther functions and purposes disclosed to you at the time of collection or as required or permitted by law.

Retention of your data

We will retain your personal data as necessary in connection with the purposes described in this Privacy Policy, for as long as you are actively working with us, and in accordance with the UK`s Retention Periods and other applicable laws.

International transfers

We may transfer your Personal Data to other companies and/or business partners as necessary for the purposes described in this Privacy Policy. In doing so, your personal data may be transferred to countries outside the UK and the EU. In order to provide adequate protection for your Personal Data when it is transferred, we have contractual arrangements regarding such transfers. We take all reasonable technical and organisational measures to protect the personal data we transfer.

Sharing of personal data by us.

For the operation and optimisation of our website and web application and for the processing of contracts, various service companies work for us, e.g., for IT services or the hosting of our website, for the payment of fees, to whom we pass on the data required for the fulfillment of the task (e.g., name, address).

Some of these companies act for us by way of commissioned processing and may therefore use the data provided exclusively in accordance with our instructions. In this case, we are legally responsible for appropriate data protection measures at the companies we commission. We therefore agree on specific data security measures with these companies and monitor them regularly.

We may share your Personal Data with business partners for the purposes described in this Privacy Policy, including, without limitation, to carry out transactions you request or to respond more quickly to your needs in our operations. Our affiliates and/or business partners may contact you with information about our Services and offerings. We will only share your Personal Data with business partners who have agreed to protect your Personal Data and to use it only for the purposes we have specified.

With your consent, we may disclose your Personal Data for any purpose.

In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation; if Nuly AI (or a part of Nuly AI) is sold to or merged with another company; or if we have reason to believe that disclosure is necessary to protect Nuly AI, its members or the public.

In all cases other than those described above, Personal Data will not be disclosed by us to third parties for their own marketing purposes without your consent.

Updating your information

If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us using support@nuly.ai

Access Request and updating your Personal Data

In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same using support@nuly.ai

We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above).

Your rights

Under the DPA and GDPR, you can exercise the following rights:

Right to information

Right to rectification

Right to object to processing

Right to deletion

Right to information

Right to data portability

Right of objection

Right to withdraw consent

Right to complain to a supervisory authority

Right not to be subject to a decision based solely on automated processing.

If you have any questions about the nature of the personal data we hold about you, or if you wish to request the erasure or rectification of personal data we hold about you, or to exercise any of your other rights as a data subject, please contact us at support@nuly.ai

CCPA Privacy

This privacy notice section for California residents supplements the information contained in Our Privacy Policy and it applies solely to all visitors, users, and others who reside in the State of California.

(a) ‍Categories of Personal Information Collected.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or Device. The following is a list of categories of personal information which we may collect or may have been collected from California residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected by Us, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been collected. For example, certain categories of personal information would only be collected if You provided such personal information directly to Us.

i. Category A: Identifiers.

·Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

Collected: Yes.

ii. Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Collected: Yes.

iii. Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Collected: No.‍

iv. Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.‍

v. Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Collected: No.

vi. Category F: Internet or other similar network activity.

Examples: Interaction with our Service or advertisement.

Collected: Yes.

vii. Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

viii. Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

ix. Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

x. Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

xi. Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

Publicly available information from government records

Deidentified or aggregated consumer information

Information excluded from the CCPA’s scope, such as:

Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.

Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

(b) ‍Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

·Directly from You. For example, from the forms You complete on our Service, preferences You express or provide through our Service, or from Your purchases on our Service.

Indirectly from You. For example, from observing Your activity on our Service.

Automatically from You. For example, through cookies We or our Service Providers set on Your Device as You navigate through our Service.

From Service Providers. For example, third-party vendors to monitor and analyze the use of our Service, third-party vendors to provide advertising on our Service, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other third-party vendors that We use to provide the Service to You.

(c) ‍Use of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose personal information We collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples:

To operate our Service and provide You with our Service.

To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our Service.

To fulfill or meet the reason You provided the information. For example, if You share Your contact information to ask a question about our Service, We will use that personal information to respond to Your inquiry. If You provide Your personal information to purchase a product or service, We will use that information to process Your payment and facilitate delivery.

To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

As described to You when collecting Your personal information or as otherwise set forth in the CCPA.

For internal administrative and auditing purposes.

To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

‍Please note that the examples provided above are illustrative and not intended to be exhaustive. For more details on how we use this information, please refer to the “Use of Your Personal Data” section.

‍If We decide to collect additional categories of personal information or use the personal information We collected for materially different, unrelated, or incompatible purposes We will update this Privacy Policy.

(d) ‍Disclosure of Personal Information for Business Purposes or Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve (12) months the following categories of personal information for business or commercial purposes:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D: Commercial information

Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact disclosed, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been disclosed.

‍When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

(e) ‍Sale of Personal Information

As defined in the CCPA, “sell” and “sale” mean selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration.

This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

‍Please note that the categories listed below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact sold, but reflects our good faith belief to the best of our knowledge that some of that information from the applicable category may be and may have been shared for value in return.

‍We may sell and may have sold in the last twelve (12) months the following categories of personal information:

Category A: Identifiers

Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Category D: Commercial information

Category F: Internet or other similar network activity

Complaint to a supervisory authority

The Information Commissioner’s Office (ICO) is the relevant authority in the UK. The ICO is located at Wycliffe House, Water Ln, Wilmslow SK9 5AF, UK (www.ico.org.uk). If you believe that the processing of your Personal Data is not lawful, you can lodge a complaint with a data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the ICO or any other supervisory authority.

How we protect your Personal Data

Nuly AI takes all reasonable steps to protect your Personal Data from misuse, alteration, and loss, and from unauthorised access, alteration, or disclosure. To this end, we use the following means, among others:

Use of encryption when collecting and transmitting sensitive data such as credit card information, technical and organisational measures to ensure the continuous integrity, availability, and fail-safety of processing systems and services, Restricting physical access to our sites, Restricting access to data we collect about you, Ensuring appropriate safeguards are in place at our facilities and those of our business partners to ensure the security of your personal data; and, where required by law, deleting or anonymizing Personal Data.

Collection and Use of Children’s Personal Data

Nuly AI takes the privacy of children very seriously. We do not knowingly collect Personal Data from children through our website.

Validity and questions

This Privacy Policy was last updated on Wednesday, December 6, 2023, and is the current and valid version. However, we want to point out that from time to time due to actual or legal changes a revision to this policy may be necessary.

If you have any questions about this policy or our data protection practices, please contact us using

support@nuly.ai