Privacy Policy

Welcome to Nubiera ("Company," "we," "us," or "our"). We operate an AI-powered chatbot platform that helps businesses automate customer communications through messaging channels like WhatsApp.

This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our services. By using our platform, you consent to the practices described in this policy.

Data Controller Information:

The data controller responsible for processing your personal data is Nubiera, with registered address in Mexico City, Mexico. For any matters related to the processing of your personal data, please contact us at privacy@nubiera.com.

We collect the following types of information:

Account Information:

Messaging Data:

Google Calendar Data (if enabled):

Technical Data:

AI Processing Data:

SENSITIVE DATA (Express Identification per LFPDPPP):

In accordance with Article 3, Section VI of Mexico's Federal Law for the Protection of Personal Data Held by Private Parties (LFPDPPP), sensitive personal data is defined as data that affects the most intimate sphere of the data subject, or whose misuse could give rise to discrimination or pose a serious risk.

When using our platform, the following data MAY be considered sensitive depending on its content:

- Voice messages and transcriptions: May contain biometric voice characteristics

- Shared images: May reveal information about racial or ethnic origin, health status, or other sensitive characteristics

- Conversation content: Depending on context, may include health information, religious beliefs, sexual preferences, or political opinions

IMPORTANT: Processing of this sensitive data requires your express written consent. By using features that involve these types of data, you expressly grant such consent through active acceptance on the platform.

We use your information for the following purposes:

Service Delivery:

Service Improvement:

Communications:

Legal and Security:

Important: We limit our use of Google user data to providing and improving user-facing features. We do not use Google data for advertising or any purpose unrelated to the core functionality of our service.

When you connect your Google account to our platform:

What We Access:

How We Use It:

What We Do NOT Do:

Data Retention:

Compliance:

We may share your information with:

Service Providers:

Legal Requirements:

Business Transfers:

With Your Consent:

We do NOT:

We implement industry-standard security measures:

Technical Safeguards:

Organizational Measures:

Third-Party Security:

While we strive to protect your information, no system is completely secure. We cannot guarantee absolute security of data transmitted over the internet.

Retention Periods:

Deletion:

To Request Deletion:

Depending on your location, you may have the following rights:

All Users:

How to Exercise Rights:

Account Settings:

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Your CCPA Rights:

Categories of Information Collected:

How to Exercise CCPA Rights:

Authorized Agents:

If you are a resident of Mexico, this Privacy Notice is governed by the Federal Law for the Protection of Personal Data Held by Private Parties (LFPDPPP) published in the Official Gazette of the Federation on March 20, 2025, and its Regulations.

ARCO RIGHTS (Articles 22-26 LFPDPPP):

- Access (Art. 22): You have the right to know what personal data we hold about you and the conditions and generalities of its processing

- Rectification (Art. 23): You have the right to request correction of inaccurate, incomplete, or outdated personal data

- Cancellation (Art. 24): You have the right to request deletion of your personal data from our files, records, and systems

- Opposition (Art. 26): You have the right to object, at any time and for legitimate cause, to the processing of your personal data

- Portability: You have the right to receive your data in a structured, commonly used, machine-readable format (CSV, JSON)

TYPES OF CONSENT (Article 8 LFPDPPP):

*Tacit Consent:*

For NON-sensitive personal data, we may assume tacit consent if, after 5 business days from when this Privacy Notice was made available to you, you do not express opposition.

*Express Consent:*

Required for financial or patrimonial data. May be granted verbally or in writing.

*Express Written Consent:*

MANDATORY for sensitive data. This consent must be granted through:

By using features that process sensitive data (voice messages, images, content that may reveal sensitive information), you grant express consent through active acceptance on the platform.

PURPOSES OF DATA PROCESSING:

*Primary Purposes (do NOT require additional consent - Art. 37 LFPDPPP):*

*Secondary Purposes (REQUIRE your consent):*

To deny consent for secondary purposes, send an email to privacy@nubiera.com with the subject "Deny Secondary Purposes" within 5 business days of receiving this notice.

DATA TRANSFERS AND REMISSIONS:

*Remissions (Controller to Processor - do NOT require consent):*

The following providers act as DATA PROCESSORS under our instructions:

These processors are contractually bound to:

*Transfers (Controller to Controller):*

Your personal data may be TRANSFERRED to third-party controllers located in the United States for:

These transfers are made with your consent, which you may deny by sending an email to privacy@nubiera.com with the subject "Deny Transfers".

PROCEDURE FOR EXERCISING ARCO RIGHTS (Art. 28-31 LFPDPPP):

Send your request to:

Your request MUST contain:

1. Full name of the data subject

2. Address or email to communicate the response

3. Copy of valid official identification (INE, passport, professional license)

4. Clear and precise description of the personal data regarding which you seek to exercise your rights

5. Any document or information that facilitates locating your data

6. In case of rectification, indicate the modifications and provide supporting documentation

RESPONSE DEADLINES (Art. 31 LFPDPPP):

- 20 business days: To communicate the determination adopted

- 15 additional business days: To make the request effective, if applicable

- Extension: Deadlines may be extended ONCE ONLY for an equal period when circumstances justify it

FREE OF CHARGE: Exercise of ARCO rights is FREE. Charges may only be made to cover shipping, reproduction, or document certification costs.

CONSENT REVOCATION:

You may revoke your consent at any time by sending an email to privacy@nubiera.com with the subject "Consent Revocation". Revocation will not have retroactive effects.

PROCESSING LIMITATIONS:

CHANGES TO PRIVACY NOTICE (Art. 17 LFPDPPP):

REGULATORY AUTHORITY:

If you believe your rights have been violated, you may file a complaint with the Secretaria Anticorrupcion y Buen Gobierno (Secretary of Anti-Corruption and Good Governance), the competent authority for personal data protection as of March 2025.

LAST UPDATE DATE: December 30, 2025

Cookies We Use:

Third-Party Tracking:

Your Choices:

Our service is not intended for children under 16 years of age. We do not knowingly collect personal information from children under 16. If you believe we have collected information from a child under 16, please contact us immediately at privacy@nubiera.com, and we will take steps to delete such information.

Your data may be transferred to and processed in countries other than your own, including the United States. These countries may have different data protection laws.

Safeguards:

EU/UK Users:

We may update this Privacy Policy from time to time. We will notify you of significant changes by:

We encourage you to review this policy periodically. Continued use of our service after changes constitutes acceptance of the updated policy.

For new types of data processing or new uses of Google user data, we will obtain your consent before proceeding.

If you have questions about this Privacy Policy or our data practices, please contact us:

Email: privacy@nubiera.com

For Data Protection Inquiries:

For Data Access/Deletion Requests:

Response Time: