Privacy Policy

Effective Date: August 17, 2026

Last Updated: August 17, 2026

1. Introduction

NBG Enterprises ("we," "us," "our," or "Company") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the NBG Cloud mobile application (the "App") on Android devices.

Please read this Privacy Policy carefully. By accessing or using the App, you acknowledge that you have read, understood, and agree to be bound by all the terms of this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the App.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the "Last Updated" date of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on the App, and you waive the right to receive specific notice of each such change or modification. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the App after the date such revised Privacy Policy is posted.

2. Information We Collect

We collect information about you in various ways when you use our App. The types of personal data we may collect include:

2.1 Personal Data You Provide Directly

We collect personal data that you voluntarily provide to us when you register on the App, express an interest in obtaining information about us or our products and services, participate in activities on the App, or otherwise contact us. The personal data we collect may include:

Name: We collect your full name or username to identify you and personalize your experience within the App.
Email Address: We collect your email address to communicate with you, send you important information about the App, verify your account, and respond to your inquiries.
Phone Number: We collect your phone number for account verification, security purposes, two-factor authentication, and to enable communication features within the App.

2.2 Data Accessed from Your Device

With your explicit permission, we may access certain data stored on your Android device:

Photos and Media: We may access photos, videos, audio files, and other media stored on your device when you choose to upload, share, or attach such content through the App. This access is only granted when you actively select files to upload or use within the App's features.
Contacts: We may access your device's contact list when you grant us permission to do so. This allows you to easily find and connect with other users of the App, share content with your contacts, or invite others to use the App. We only access this information when you explicitly authorize such access through your device's permission settings.

2.3 Automatically Collected Information

When you use the App, certain information may be collected automatically, including:

Device Information: We collect information about your mobile device, including device model, operating system version, unique device identifiers, mobile network information, and device settings.
Usage Data: We collect information about how you interact with the App, including the features you use, the actions you take, the time and duration of your activities, and your preferences.
Log Data: Our servers automatically record information created by your use of the App, including IP address, access times, app features or pages viewed, app crashes and other system activity, and the third-party sites or services you were using before interacting with our App.
Performance Data: We collect data about the App's performance and any errors or issues you experience to help us improve the App's functionality and user experience.

2.4 Information We Do Not Collect

We want to be transparent about information we do not collect. We do not:

Collect precise geolocation data without your explicit consent
Collect financial or payment information
Collect biometric data
Collect health or medical information
Collect information about children under the age of 13 (or the applicable age of consent in your jurisdiction) without verified parental consent

3. How We Use Your Information

We use the information we collect about you for various purposes, including:

3.1 To Provide and Maintain the App

To create and manage your account
To provide you with the features and functionality of the App
To process your requests and transactions
To authenticate your identity and prevent fraud
To enable communication features within the App
To store and manage your uploaded content, including photos and media
To facilitate connections with your contacts when you choose to use such features

3.2 To Improve and Optimize the App

To understand how users interact with the App
To analyze usage patterns and trends
To diagnose and fix technical problems
To develop new features, products, and services
To conduct research and testing to improve the App
To monitor and analyze the effectiveness of the App

3.3 To Communicate with You

To send you administrative information, such as updates to our terms, conditions, and policies
To respond to your comments, questions, and customer service requests
To send you technical notices, security alerts, and support messages
To provide you with information about the App's features and functionality
To notify you about changes to the App

3.4 For Security and Legal Purposes

To protect the security and integrity of the App
To prevent, detect, and investigate fraud, unauthorized access, and other illegal activities
To comply with legal obligations and respond to legal requests
To enforce our Terms of Service and other agreements
To protect our rights, privacy, safety, or property, and that of our users and the public

3.5 For Other Business Purposes

To fulfill any other purpose for which you provide the information
For any other purpose with your consent
To aggregate and anonymize data for statistical analysis and reporting

4. How We Share Your Information

We do not sell, rent, or trade your personal information to third parties. However, we may share your information in the following circumstances:

4.1 With Your Consent

We may share your information when you give us your explicit consent to do so, such as when you choose to share content with other users or integrate the App with other services.

4.2 For Legal Reasons

We may disclose your information if required to do so by law or in response to valid requests by public authorities, including to meet national security or law enforcement requirements. This includes:

Complying with a court order, subpoena, search warrant, or other legal process
Responding to claims that any content violates the rights of third parties
Protecting the rights, property, or personal safety of NBG Enterprises, our users, or the public
Enforcing our Terms of Service or other agreements
Investigating and preventing fraud, security issues, or illegal activities

4.3 Business Transfers

In the event of a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of NBG Enterprises' assets, or similar business transaction, your information may be transferred to the successor entity. We will provide notice before your personal information is transferred and becomes subject to a different privacy policy.

4.4 Service Providers

While we currently do not use third-party service providers, we may in the future engage service providers to perform functions on our behalf, such as hosting, data storage, data analysis, customer service, email delivery, or technical support. If we do engage such service providers, they will have access to your personal information only to perform these tasks on our behalf and will be obligated not to disclose or use it for any other purpose.

4.5 Aggregated or Anonymized Data

We may share aggregated or anonymized information that cannot reasonably be used to identify you. This information may be used for research, marketing, analytics, or other purposes.

4.6 Other Users

Depending on the features you use, certain information may be visible to other users of the App. For example, if you choose to share content, your name and the shared content may be visible to the recipients you select.

5. Third-Party Services

The App currently does not integrate with or use third-party services, analytics tools, advertising networks, or social media platforms. We do not share your data with third-party service providers for advertising, analytics, or other purposes at this time.

If we decide to integrate third-party services in the future, we will update this Privacy Policy accordingly and notify you of such changes. Any third-party services would be required to comply with this Privacy Policy and applicable data protection laws.

Please note that this Privacy Policy does not apply to third-party websites or services that you may access through external links, even if such links are provided through the App. We are not responsible for the privacy practices of these third parties, and we encourage you to review their privacy policies before providing them with any personal information.

6. Data Security

We take the security of your personal information seriously and implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. These security measures include:

6.1 Technical Safeguards

Encryption: We use industry-standard encryption technologies to protect data in transit and at rest.
Secure Servers: Your information is stored on secure servers with restricted access.
Access Controls: We implement strict access controls to limit who can access your personal information.
Authentication: We use secure authentication mechanisms to verify user identity.
Regular Security Updates: We regularly update our security measures to address new threats and vulnerabilities.

6.2 Organizational Safeguards

Employee Training: Our employees are trained on data protection and privacy principles.
Confidentiality Agreements: Personnel with access to personal data are bound by confidentiality obligations.
Data Minimization: We collect and retain only the data necessary for the purposes outlined in this Privacy Policy.
Incident Response: We have procedures in place to detect, respond to, and mitigate security incidents.

6.3 Your Role in Security

While we implement robust security measures, the security of your information also depends on you. You should:

Keep your account credentials confidential and not share them with others
Use a strong, unique password for your account
Log out of your account when using shared or public devices
Be cautious about the information you choose to share through the App
Keep your device and the App updated with the latest security patches
Report any suspicious activity or security concerns to us immediately

6.4 Limitations

Despite our security measures, no method of transmission over the Internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.

In the event of a data breach that affects your personal information, we will notify you and relevant authorities as required by applicable law, and we will take appropriate steps to mitigate the impact and prevent future incidents.

7. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

7.1 Retention Periods

The criteria we use to determine our retention periods include:

Account Information: We retain your account information (name, email address, phone number) for as long as your account remains active or as needed to provide you with the App's services.
Content Data: Photos, media, and other content you upload to the App are retained until you delete them or close your account.
Usage Data: Usage data and log files are typically retained for a limited period necessary for analytics, troubleshooting, and security purposes, usually not exceeding 24 months.
Contact Data: Information about your contacts is retained only while you maintain permission for the App to access your contacts and is deleted when you revoke this permission or delete your account.
Legal Requirements: We may retain certain information for longer periods if required by law, regulation, legal process, or to protect our legal rights.

7.2 Deletion of Data

When personal information is no longer needed for the purposes for which it was collected, or when you request deletion of your data, we will:

Securely delete or anonymize the information so it can no longer be associated with you
Remove the data from our active databases and systems
Ensure that any backup copies are deleted in accordance with our backup retention policies

However, we may retain certain information in our archives for legitimate business purposes, such as fraud prevention, regulatory compliance, or to resolve disputes. Such retained information will be kept secure and used only for these specific purposes.

7.3 Account Deletion

If you choose to delete your account, we will delete or anonymize your personal information, except where we are required to retain it by law or for legitimate business purposes. Some information may persist in backup copies for a limited period but will not be available for active use.

8. Your Privacy Rights

Depending on your location and applicable law, you may have certain rights regarding your personal information. We are committed to respecting these rights regardless of your jurisdiction.

8.1 Access and Portability

You have the right to:

Request access to the personal information we hold about you
Receive a copy of your personal information in a structured, commonly used, and machine-readable format
Request that we transmit your data to another service provider where technically feasible

8.2 Correction and Updates

You have the right to:

Request correction of inaccurate or incomplete personal information
Update your account information directly through the App's settings
Request that we update or modify your personal data

8.3 Deletion and Erasure

You have the right to:

Request deletion of your personal information, subject to certain legal exceptions
Delete your account and associated data through the App or by contacting us
Request that we erase your data when it is no longer necessary for the purposes for which it was collected

8.4 Restriction and Objection

You have the right to:

Request restriction of processing of your personal information under certain circumstances
Object to processing of your personal information for specific purposes
Withdraw consent for processing where we rely on consent as the legal basis

8.5 Device-Level Permissions

You can control the App's access to certain device features and data through your Android device settings:

Photos and Media: You can revoke the App's permission to access your photos and media files at any time through your device's app permissions settings.
Contacts: You can revoke the App's permission to access your contacts at any time through your device's app permissions settings.

Please note that revoking certain permissions may limit your ability to use some features of the App.

8.6 Marketing Communications

If we send you marketing communications, you have the right to:

Opt out of receiving marketing emails by following the unsubscribe instructions in those emails
Adjust your communication preferences in the App's settings
Contact us to request removal from marketing lists

Please note that even if you opt out of marketing communications, we may still send you non-promotional messages related to your account and our business relationship with you.

8.7 How to Exercise Your Rights

To exercise any of these rights, please contact us using the contact information provided in Section 16 of this Privacy Policy. We will respond to your request within the timeframe required by applicable law, typically within 30 days.

When you make a request, we may ask you to verify your identity to protect your personal information from unauthorized access. We will not discriminate against you for exercising your privacy rights.

8.8 Complaints

If you are not satisfied with how we handle your personal information or your privacy rights, you have the right to lodge a complaint with a supervisory authority in your jurisdiction. However, we encourage you to contact us first so we can address your concerns directly.

9. International Data Transfers

NBG Enterprises operates globally, and your information may be transferred to, stored in, and processed in countries other than your country of residence. These countries may have data protection laws that are different from the laws of your country.

9.1 Legal Basis for Transfers

When we transfer your personal information internationally, we take steps to ensure that your information receives an adequate level of protection, including:

Implementing appropriate safeguards, such as standard contractual clauses approved by relevant authorities
Ensuring that the recipient country provides an adequate level of data protection
Obtaining your explicit consent for the transfer when required
Ensuring transfers are necessary for the performance of a contract with you or for important reasons of public interest

9.2 Specific Regional Considerations

European Economic Area (EEA), United Kingdom, and Switzerland: If you are located in the EEA, UK, or Switzerland, we will ensure that any transfer of your personal data to countries outside these regions is protected by appropriate safeguards, such as Standard Contractual Clauses or other legally approved mechanisms.

California Residents: If you are a California resident, your personal information may be transferred outside of California. We ensure such transfers comply with the California Consumer Privacy Act (CCPA) and other applicable California laws.

Other Jurisdictions: If you are located in other jurisdictions with specific data localization or transfer requirements, we will comply with applicable laws governing international data transfers.

9.3 Your Rights Regarding International Transfers

You have the right to:

Obtain information about the safeguards we use for international transfers
Request a copy of the safeguards we have in place
Object to transfers in certain circumstances

For more information about our international data transfer practices, please contact us using the information provided in Section 16.

10. Children's Privacy

NBG Enterprises is committed to protecting the privacy of children. The App is not intended for use by children under the age of 13, or the equivalent minimum age in the relevant jurisdiction, without verifiable parental consent.

10.1 Age Restrictions

We do not knowingly collect personal information from children under the age of 13 (or the applicable age of consent in your jurisdiction, such as 16 in some European countries). Different age thresholds may apply based on your location:

United States: Under 13 years of age
European Union: Under 16 years of age (or lower as determined by individual member states)
Other Jurisdictions: As specified by local laws

10.2 Parental Consent

If we become aware that we have collected personal information from a child without verifiable parental consent, we will take steps to delete that information as quickly as possible. If you are a parent or guardian and you believe your child has provided us with personal information without your consent, please contact us immediately using the contact information in Section 16.

10.3 Verification and Deletion

If we learn that we have collected personal information from a child under the applicable age without proper parental consent, we will:

Immediately cease collection and use of that child's information
Delete the child's account and all associated personal information from our systems
Notify the parent or guardian if contact information is available
Take steps to prevent the child from re-registering

10.4 Parental Rights

Parents and legal guardians have the right to:

Review any personal information collected from their child
Request deletion of their child's personal information
Refuse to permit further collection or use of their child's information
Provide or withdraw consent for data collection from their child

10.5 Compliance with Children's Privacy Laws

We comply with applicable children's privacy laws, including:

The Children's Online Privacy Protection Act (COPPA) in the United States
The General Data Protection Regulation (GDPR) provisions regarding children's data in the European Union
Similar laws and regulations in other jurisdictions

11. Region-Specific Privacy Information

This section provides additional privacy information for users in specific jurisdictions as required by applicable law.

11.1 European Economic Area (EEA), United Kingdom, and Switzerland

If you are located in the EEA, UK, or Switzerland, the following additional information applies:

Legal Basis for Processing: We process your personal data based on the following legal grounds:

Consent: When you have given us clear consent to process your personal information for a specific purpose, such as accessing your contacts or photos.
Contract Performance: When processing is necessary to perform our contract with you or to take steps at your request before entering into a contract.
Legal Obligation: When we must process your data to comply with our legal obligations.
Legitimate Interests: When processing is necessary for our legitimate interests or those of a third party, provided your interests and fundamental rights do not override those interests.

Data Protection Officer: For questions about our data processing practices or to exercise your rights, you may contact our designated representative at the email address provided in Section 16.

Your GDPR Rights: Under the GDPR, you have the right to:

Access your personal data
Rectify inaccurate personal data
Erase your personal data ("right to be forgotten")
Restrict processing of your personal data
Data portability
Object to processing based on legitimate interests
Withdraw consent at any time (without affecting the lawfulness of processing based on consent before withdrawal)
Lodge a complaint with your local supervisory authority

Automated Decision-Making: We do not use automated decision-making or profiling that produces legal effects or similarly significantly affects you.

11.2 California Residents (CCPA/CPRA)

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

Categories of Personal Information Collected:

Identifiers (name, email address, phone number)
Personal information as defined in California Customer Records law (name, contact information)
Commercial information (usage data)
Internet or other electronic network activity (device information, log data)
Audio, electronic, visual, or similar information (photos and media you upload)

Sources of Personal Information: Directly from you, automatically from your device, from your device's storage (contacts, photos).

Business or Commercial Purposes: As described in Section 3 of this Privacy Policy.

Categories of Third Parties: We do not sell or share personal information. We may disclose information to service providers (when engaged) and for legal purposes as described in Section 4.

Your California Rights:

Right to Know: You have the right to request that we disclose what personal information we collect, use, disclose, and sell.
Right to Delete: You have the right to request deletion of your personal information, subject to certain exceptions.
Right to Correct: You have the right to request correction of inaccurate personal information.
Right to Opt-Out: You have the right to opt out of the sale or sharing of your personal information. We do not sell or share personal information.
Right to Limit Use of Sensitive Personal Information: You have the right to limit our use of sensitive personal information. We do not use or disclose sensitive personal information for purposes other than those permitted under the CPRA.
Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your CCPA rights.

Shine the Light Law: California Civil Code Section 1798.83 permits California residents to request certain information about our disclosure of personal information to third parties for direct marketing purposes. We do not share personal information with third parties for their direct marketing purposes.

Authorized Agents: You may designate an authorized agent to make requests on your behalf. We will require written proof of the agent's authority.

Verification: To protect your privacy, we will verify your identity before fulfilling requests. The verification process may require you to provide information that matches information we have on file.

11.3 Brazil (LGPD)

If you are located in Brazil, you have rights under the Lei Geral de Proteção de Dados (LGPD):

Legal Basis for Processing: We process your data based on consent, contract performance, legal obligation, legitimate interest, or protection of your rights.

Your LGPD Rights:

Confirmation of the existence of processing
Access to your data
Correction of incomplete, inaccurate, or outdated data
Anonymization, blocking, or deletion of unnecessary or excessive data
Portability of data to another service provider
Deletion of data processed with your consent
Information about public and private entities with which we share data
Information about the possibility of not providing consent and the consequences
Revocation of consent

Data Protection Officer: You may contact our designated representative for Brazilian data protection matters at the email address in Section 16.

11.4 Canada (PIPEDA)

If you are located in Canada, you have rights under the Personal Information Protection and Electronic Documents Act (PIPEDA):

Right to access your personal information
Right to challenge the accuracy and completeness of your information and have it amended as appropriate
Right to withdraw consent for processing (subject to legal or contractual restrictions)
Right to file a complaint with the Privacy Commissioner of Canada

11.5 Australia (Privacy Act)

If you are located in Australia, you have rights under the Privacy Act 1988:

Right to access your personal information
Right to correct inaccurate personal information
Right to complain to the Office of the Australian Information Commissioner
Right to request that we stop sending you marketing communications

11.6 Other Jurisdictions

If you are located in a jurisdiction not specifically mentioned above, you may still have privacy rights under local law. We are committed to complying with applicable privacy laws regardless of your location. Please contact us to inquire about your specific rights.

12. Cookies and Tracking Technologies

The NBG Cloud App may use certain tracking technologies to collect information about your use of the App and to improve your experience.

12.1 Types of Technologies Used

We may use the following types of technologies:

Local Storage: We may use local storage technologies to store preferences, settings, and other information on your device to provide a better user experience.
Session Data: We maintain session information to keep you logged in and to remember your preferences during your use of the App.
Analytics Tools: Although we do not currently use third-party analytics services, we may collect usage data directly to understand how users interact with the App.
Device Identifiers: We may use device identifiers to recognize your device and provide personalized experiences.

12.2 Purpose of Tracking Technologies

We use these technologies for the following purposes:

To authenticate users and prevent fraud
To remember your preferences and settings
To analyze usage patterns and improve the App
To provide and maintain the App's functionality
To ensure the security of the App and your data

12.3 Managing Tracking Technologies

You can control certain tracking technologies through your device settings:

You can clear local storage and cached data through your device's application settings
You can reset your advertising identifier through your device settings
You can uninstall the App, which will remove all locally stored data