Privacy Policy

1. Introduction

This Privacy Policy explains how Kamal Agbaria (Reg. No. 034650887), operating under the brand name Nula ("we", "us", "our"), collects, uses, shares, and protects information from businesses ("you", "your") that use the Nula Partners platform ("Platform", "Service").

We are committed to protecting your privacy and handling your data transparently. This policy applies to all business accounts on the Nula Partners platform.

2. Data Controller

Kamal Agbaria, trading as Nula (Reg. No. 034650887), Almadina 62, Umm el Fahem, Israel, is the data controller for the information collected through the Partners platform. For payment-related data, AllPayprocesses payments on our behalf as a data processor.

3. Information We Collect

3.1 Account Information

When you register and manage your business account, we collect:

• Business name, address, and contact details
• Account holder name, email address, and phone number
• Login credentials (passwords are hashed and never stored in plain text)
• Business type, category, and service descriptions
• Business logo and images you upload

3.2 Subscription & Billing Data

Subscription and payment data is processed by AllPay (our payment processor). We receive from AllPay:

• Subscription plan details and status
• Transaction IDs and billing history
• Currency and pricing information

We do not store full payment card details. AllPay securely processes payment transactions on our behalf.

3.3 Platform Usage Data

We automatically collect:

• Features used, pages visited, and actions taken within the dashboard
• Device type, browser, operating system, and screen resolution
• IP address and approximate geographic location
• Login timestamps and session duration
• Error logs and performance data

3.4 Client Data You Manage

Through the Platform, you may input, store, and manage data about your own clients (e.g., client names, contact details, appointment history). You are the data controller for your client data and are responsible for ensuring you have the appropriate legal basis and consents to process it. We process this data on your behalf as a data processor.

4. How We Use Your Information

We use your information to:

• Provide, operate, and maintain the Platform
• Process and manage your subscription
• Communicate with you about your account, billing, and service updates
• Provide customer support and respond to inquiries
• Analyze usage patterns to improve the Platform
• Ensure security and prevent fraud
• Comply with legal obligations
• Send you product updates, feature announcements, and relevant marketing communications (with your consent or where permitted by law)

5. Legal Basis for Processing (GDPR)

If you are in the European Economic Area (EEA), we process your data based on:

• Contract Performance: Processing necessary to provide the subscription service you have purchased.
• Legitimate Interests: Analytics, security, fraud prevention, and product improvement, balanced against your rights.
• Consent: Marketing communications and non-essential cookies, which you may withdraw at any time.
• Legal Obligation: Compliance with applicable laws, tax regulations, and legal requests.

6. Data Sharing

We share your information only in the following circumstances:

• AllPay (Payment Processor): Payment processing for subscription billing and transactions.
• Cloud Infrastructure Providers: Hosting, storage, and computing services (data processed under strict data processing agreements).
• Analytics Services: Aggregated, anonymized usage data to improve the Platform.
• Legal Requirements: When required by law, court order, or governmental authority.
• Business Transfers: In connection with a merger, acquisition, or sale of assets, with appropriate notice.

We do not sell your personal data or business data to third parties.

7. Cookies & Tracking

We use cookies and similar technologies to:

• Essential cookies: Maintain your session, remember login state, and ensure the Platform functions correctly.
• Analytics cookies: Understand how you use the Platform so we can improve it (only with your consent where required).

You can manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent the Platform from functioning properly.

8. International Data Transfers

Your data may be transferred to and processed in countries outside your country of residence, including countries that may not provide the same level of data protection. When we transfer data outside the EEA, we rely on:

• EU Standard Contractual Clauses (SCCs)
• Adequacy decisions by the European Commission
• Data processing agreements with appropriate safeguards

9. Data Retention

We retain your data as follows:

• Active account data: For the duration of your subscription plus 30 days after cancellation.
• Billing & transaction records: Up to 7 years as required by tax and accounting regulations.
• Usage analytics: Aggregated data is retained indefinitely; identifiable data is deleted or anonymized within 24 months.
• Client data you manage: Deleted within 90 days of account termination unless you export it prior.

10. Data Security

We implement industry-standard security measures including:

• Encryption of data in transit (TLS) and at rest
• Regular security audits and vulnerability assessments
• Access controls and authentication mechanisms
• Monitoring and logging of system access
• Secure development practices and code review processes

While we take reasonable precautions, no system is completely secure. We cannot guarantee absolute security of your data.

11. Your Rights

11.1 GDPR Rights (EEA Residents)

If you are in the EEA, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request correction of inaccurate or incomplete data.
• Erasure: Request deletion of your data (subject to legal retention requirements).
• Restriction: Request that we limit processing of your data in certain circumstances.
• Portability: Receive your data in a structured, machine-readable format.
• Object: Object to processing based on legitimate interests or for direct marketing.
• Withdraw Consent: Withdraw consent at any time where processing is based on consent.

You may also lodge a complaint with your local data protection authority.

11.2 CCPA / CPRA Rights (California Residents)

California residents have additional rights including:

• Right to know what personal information is collected and how it is used
• Right to delete personal information
• Right to opt out of the sale of personal information (we do not sell data)
• Right to non-discrimination for exercising privacy rights

11.3 Israeli Privacy Protection Law

Israeli residents have rights under the Privacy Protection Law, 5741-1981, including the right to access and correct personal data. We comply with all applicable Israeli privacy regulations.

12. Children's Privacy

The Nula Partners platform is designed for business use and is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have collected data from a minor, we will take steps to delete it promptly.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or through a notice in the Partners dashboard at least 30 days before they take effect. Your continued use of the Platform after the effective date constitutes acceptance of the updated policy.

14. Contact Us

For privacy-related questions, data access requests, or to exercise your rights, please contact us at:

• Email: privacy@nula.me
• Phone: +972 50-229-2309
• Platform:Nula Partners Dashboard > Support

For billing or payment-related inquiries, please contact us at support@nula.me.