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NUCLIUS PRIVACY POLICY

Last Updated: October 30, 2025

1. Introduction

Nuclius Ltd ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our platform (the "Service").

This policy applies to enterprise clients and their authorized users. If you are an end-user of our client's services, please refer to their privacy policy.

2. Information We Collect

2.1 Information You Provide:

• Account Information: Name, email address, company name, job title, phone number
• Billing Information: Payment card details, billing address (processed through third-party payment processors)
• Client Data: Any data, files, content, or information you upload or input into the Service and any content that has been subsequently generated
• Communications: Information from your communications with our support team

2.2 Automatically Collected Information:

• Usage Data: Features accessed, time spent, actions taken within the Service
• Device Information: IP address, browser type, operating system, device identifiers
• Log Data: Server logs, error reports, performance data
• Cookies and Tracking Technologies: Session data, preferences, analytics information

2.3 System Interaction Data:

• Inputs into the application when creating and maintaining a project
• Content uploads
• Any generated outputs and responses
• Feedback provided regarding system performance

3. How We Use Your Information

3.1 Service Delivery:

• Provide, maintain, and improve the Service
• Process requests and generate outputs
• Authenticate users and manage accounts
• Process payments and billing

3.2 Communication:

• Send service-related notifications and updates
• Respond to inquiries and provide customer support
• Send marketing communications (with your consent, where required)

3.3 Analytics and Improvement:

• Analyze usage patterns to improve features and user experience
• Conduct research and development for new features
• Monitor and analyze trends, usage, and activities
• Enhancing the service to your needs through AI training

3.4 Security and Compliance:

• Detect, prevent, and address security incidents and fraud
• Comply with legal obligations and enforce our Terms of Service
• Protect the rights, property, and safety of Nuclius, our users, and the public

4. Legal Basis for Processing (GDPR)

If you are in the European Economic Area (EEA), our legal bases for processing include:

• Contract Performance: Processing necessary to provide the Service
• Legitimate Interests: Improving our Service, security, and fraud prevention
• Consent: Where you have provided explicit consent (e.g., marketing communications)
• Legal Obligations: Compliance with applicable laws and regulations

5. AI Model Training and Client Data

5.1 We take your data privacy seriously. Client Data is used to provide a bespoke implementation of our service - this is done by leveraging your brand guidelines and policies to configure the system and uploaded and generated content to train our models.

5.2 Processing of your Client Data (including via AI) occurs solely to provide the Service to you and any broader system or model improvements from your use of the platform will not identify your organisation or persons within it.

6. Data Sharing and Disclosure

6.1 We Do NOT Sell Your Personal Data.

6.2 We may share information with:

Service Providers: Third-party vendors who perform services on our behalf (cloud hosting, payment processing, analytics, customer support). These providers are contractually obligated to protect your data.

Business Transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred to the successor entity.

Legal Requirements: When required by law, subpoena, court order, or governmental request, or to protect our rights, property, or safety.

With Your Consent: When you explicitly authorize us to share information with third parties.

6.3 Aggregate Data: We may share anonymized, aggregated data that cannot identify you with partners, researchers, or the public.

7. Data Retention

7.1 We retain your information for as long as necessary to provide the Service and fulfill the purposes described in this policy.

7.2 Account information is retained while your account is active and for a reasonable period thereafter for legal and business purposes.

7.3 Client Data is retained according to your subscription agreement and data retention settings.

7.4 You may request deletion of your data, subject to legal and contractual obligations.

7.5 Backup copies may persist for a limited time in our disaster recovery systems.

8. Data Security

8.1 Security Measures:

• Encryption in transit (TLS/SSL) and at rest
• Access controls and authentication mechanisms
• Regular security assessments and penetration testing
• Employee training on data protection
• Incident response procedures

8.2 While we implement industry-standard security measures, no system is completely secure. You acknowledge the inherent risks of internet-based data transmission.

8.3 You are responsible for maintaining the security of your account credentials.

9. International Data Transfers

9.1 Your information may be transferred to and processed in countries other than your country of residence.

9.2 We ensure appropriate safeguards are in place for international transfers, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions by relevant data protection authorities
• Other legally approved transfer mechanisms

9.3 Data processing locations are specified in your service agreement.

10. Your Privacy Rights

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

10.1 Access: Request access to your personal data we hold

10.2 Correction: Request correction of inaccurate or incomplete data

10.3 Deletion: Request deletion of your personal data (subject to legal obligations)

10.4 Portability: Request a copy of your data in a structured, machine-readable format

10.5 Restriction: Request restriction of processing under certain circumstances

10.6 Objection: Object to processing based on legitimate interests

10.7 Withdraw Consent: Withdraw consent for processing where consent is the legal basis

10.8 Opt-Out: Opt-out of marketing communications at any time

To exercise these rights, contact us at: legal@nuclius.ai

Response Time: We will respond to requests within 30 days (or as required by applicable law).

11. California Privacy Rights (CCPA/CPRA)

California residents have additional rights under the California Consumer Privacy Act:

11.1 Right to know what personal information is collected, used, shared, or sold

11.2 Right to delete personal information (subject to exceptions)

11.3 Right to opt-out of the sale of personal information (Note: We do not sell personal information)

11.4 Right to non-discrimination for exercising privacy rights

11.5 Right to correct inaccurate personal information

To exercise these rights: legal@nuclius.ai

12. Children's Privacy

Our Service is not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If we learn we have collected information from a child, we will delete it promptly.

13. Cookies and Tracking Technologies

13.1 We use:

• Essential Cookies: Required for Service functionality
• Analytics Cookies: To understand usage patterns (Google Analytics, etc.)
• Preference Cookies: To remember your settings
• Marketing Cookies: For targeted advertising (with consent where required)

13.2 You can control cookies through your browser settings. Disabling cookies may affect Service functionality.

13.3 We use analytics tools that may collect information about your online activities over time and across different websites.

14. Third-Party Links

The Service may contain links to third-party websites or services. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies.

15. Changes to This Privacy Policy

15.1 We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements.

15.2 We will notify you of material changes via email or through the Service at least 30 days before they take effect.

15.3 The "Last Updated" date at the top indicates when the policy was last revised.

15.4 Your continued use after changes take effect constitutes acceptance of the updated policy.

16. Data Protection Officer

For organizations subject to GDPR, we have appointed a Data Protection Officer (DPO):

DPO Contact: chris@nuclius.ai

17. Supervisory Authority

If you are in the EEA, you have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.

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CONSENT AND ACKNOWLEDGMENT

By using the Service, you acknowledge that you have read, understood, and agree to be bound by both the Terms of Service and Privacy Policy.

For enterprise clients, these documents are supplemented by your Master Service Agreement and any applicable Data Processing Addendum.