1. Who We Are
- Business Name: Nuputa OÜ (LLC), an European Union company based in Estonia.
- Email: nuputa.oy@gmail.com
We are the data controller for personal data collected through our Site and Service under the scope of the General Data Protection Regulation (GDPR).
2. Information We Collect
- Anonymized Chat Conversations We collect conversations with our AI assistant for the purpose of improving and developing our Service. These conversations are anonymized and do not directly identify any individual. However, users may include personal information in their messages at their own discretion; such disclosure is not requested or encouraged by us.
- Email Addresses We may collect email addresses when users voluntarily provide them (for example, to join our mailing list, request updates, or otherwise contact us).
- Cookies and Tracking Technologies We use cookies and similar technologies (including Google Analytics and Google Ads) to analyze Site traffic, measure ad performance, and better understand user behavior. You can set your browser to refuse cookies or to alert you when cookies are being sent. However, some features of our Site may not function properly without cookies.
- Other Data We do not collect IP addresses or any other unique identifiers for the chat function. We do not intentionally collect data from children. Our Site and Service are intended for adults.
3. How We Use Your Information
We use the information we collect for the following purposes:
- Service Development: To analyze anonymized chat conversations to guide feature development, improve our AI models, and enhance user experience.
- Communications: If you provide your email address, we may send you newsletters, updates, or other marketing communications. You can opt out at any time by clicking the unsubscribe link or by emailing us at nuputa.oy@gmail.com.
- Analytics & Performance: To monitor and analyze usage of our Site and Service using cookies and other tracking technologies, and to measure the effectiveness of our advertising.
- Compliance & Enforcement: To enforce our policies, comply with applicable laws and regulations, and protect our rights or the rights of others.
4. Legal Bases for Processing (GDPR)
Under the GDPR, we rely on the following legal bases for processing your personal data (where applicable):
- Consent: When you voluntarily subscribe to our mailing list or otherwise opt in to receive communications.
- Legitimate Interests: To analyze anonymized data to improve our Service and ensure the functionality and security of our Site.
5. Data Retention
- Chat Data: We store anonymized chat data for 180 days to analyze usage and improve our Service. After 180 days, we delete or anonymize the data (to the extent it can be further anonymized).
- Email Data: We retain email addresses for as long as necessary to send communications or until you opt out, whichever occurs first.
6. How We Protect Your Information
- Encryption: All data in transit between the frontend and backend is encrypted via HTTPS. Chat data stored in our database is encrypted at rest using a secure key.
- Security Measures: We implement reasonable and appropriate technical, administrative, and organizational safeguards to protect your personal data from unauthorized access, disclosure, alteration, or destruction.
- No Absolute Guarantee: While we strive to protect your information, no security system is infallible, and we cannot guarantee the absolute security of your data.
7. Sharing and Disclosure of Information
- We do not sell or rent your personal data to third parties.
- We may share anonymized data with our service providers or partners strictly to help us operate or analyze the use of our Site and Service (e.g., OpenAI’s API for our AI assistant).
- We may disclose your information if required to do so by law, to protect our rights or the rights of others, or as part of a business transaction (e.g., a merger, acquisition, or transfer of assets).
8. Your Rights Under GDPR
If you are located in the European Economic Area (EEA), you have certain rights regarding your personal data, including:
- Access: Request a copy of personal data we hold about you.
- Rectification: Request corrections to any incorrect or incomplete data.
- Erasure: Request deletion of your data. (Note: For anonymized chat data, we have no way to identify specific users to fulfill individual erasure requests.)
- Objection: Object to our processing of your personal data under certain circumstances.
- Withdrawal of Consent: If we rely on consent as the legal basis for processing, you can withdraw your consent at any time.
If you wish to exercise any of these rights, please contact us at nuputa.oy@gmail.com. You also have the right to lodge a complaint with a supervisory authority in your country of residence.
9. International Data Transfers
We are based in Estonia, but our services may be accessed from the United States, United Kingdom, Ireland, the Netherlands, or other countries. Your data may be transferred to, stored, or processed in a country other than the one in which it was collected. We take measures to ensure that such transfers comply with applicable data protection laws, such as entering into standard contractual clauses with our service providers where required.
10. Third-Party Services
Our Site may contain links to third-party websites or services (e.g., Google Ads, Google Analytics, and OpenAI’s API). We do not control the privacy practices of these third parties. We encourage you to review their privacy policies to learn about their data practices.
11. Children’s Privacy
Our Site and Service are intended for adults and are not directed to individuals under 18. We do not knowingly collect personal information from anyone under 18.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make changes, we will post the updated policy on this page and update the “Last Updated” date above. We encourage you to review this Privacy Policy periodically to stay informed about our data practices.
13. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:
Nuputa OÜ (LLC)
Email: nuputa.oy@gmail.com
We will review and address all issues on a case-by-case basis.