
Privacy and Personal Data Protection Policy
NOURA: Evidence-Based Wellbeing™
Effective date: 10. 06 . 25
1. Introduction
At NOURA, we take your privacy and the protection of your personal data seriously. This policy clearly describes how we collect, use, store, share, and protect your information when you interact with our AI assistant through WhatsApp or related platforms.
NOURA is currently operating in its Minimum Viable Product (MVP) phase, which means the service is in testing and limited to essential functionalities.
2. Data Controller
NOURA: Evidence-Based Wellbeing™ is a digital product owned and operated by:
Nextera Global Partners S.A.S.
📍 Legal Address: Carrera 5 # 67–68, Bogotá, Colombia
📩 Email: info@nourawellbeing.com
💼 Country of Incorporation: Colombia
3. Scope of this Policy
This policy applies to all interactions with NOURA, including use via WhatsApp, contact through our website, and any other channels controlled by Nextera Global Partners S.A.S.
4. What Data Do We Collect?
4.1 Personal Data
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Phone number associated with WhatsApp
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Name or other personal identifiers shared voluntarily in conversations
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Messages sent to NOURA
4.2 Technical Data
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Date and time of interactions
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Device metadata (if available via the messaging platform)
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Operational data for diagnostics
4.3 Inferred (Non-Personal) Data
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Frequently asked questions
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Aggregated usage patterns (non-identifiable)
5. Purpose and Legal Basis for Processing
We use your data for the following purposes and based on the following legal bases:
PurposeLegal Basis
To provide the NOURA assistant serviceConsent (Art. 6.1.a GDPR)
To improve response quality and system performanceLegitimate interest (Art. 6.1.f)
To monitor system reliability and prevent misuseLegitimate interest (Art. 6.1.f)
To respond to feedback or user requestsConsent (Art. 6.1.a)
To comply with legal obligationsLegal obligation (Art. 6.1.c)
We do not engage in profiling or automated decision-making with legal or similarly significant effects.
6. Use of Artificial Intelligence
NOURA uses a GPT-based AI model configured to provide evidence-informed responses on wellness, sustainability, and consumer products.
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Responses are automatically generated and do not constitute medical, legal, or commercial advice.
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Conversations may be reviewed anonymously to improve system accuracy and performance.
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User data is not used to train public AI models.
7. Data Sharing
We do not sell or rent your personal data. Data may only be shared when:
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Necessary for service provision (e.g., Twilio, WhatsApp, OpenAI)
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Required by law or regulatory authorities
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You have given explicit consent
All service providers are contractually bound to data protection and confidentiality obligations.
8. Cookies and Tracking
NOURA does not currently use cookies or tracking technologies. If website tracking is introduced, a cookie policy and consent mechanism will be published accordingly.
9. Information Security
We implement appropriate technical and organizational measures, including:
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End-to-end encryption via WhatsApp
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Access controls and secure credentials
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Infrastructure hosted with trusted providers
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Limited and anonymized human review for quality purposes
10. Data Retention
We retain your data only for as long as necessary to fulfill the purposes listed above.
At the end of the MVP phase, data will either be:
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Securely deleted, or
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Anonymized for statistical and system optimization purposes
11. International Data Transfers
We may work with technical providers located outside your jurisdiction. In such cases, we ensure:
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Adequacy decisions (e.g., for the EU)
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Standard Contractual Clauses (SCCs)
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Supplementary safeguards as required
12. Data from Minors
NOURA is not intended for use by individuals under the age of 18. If we discover that we have collected data from a minor, it will be deleted promptly.
13. Your Rights
You may exercise the following rights at any time, in accordance with applicable data protection laws:
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Right to access your data
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Right to rectification or deletion
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Right to restrict or object to processing
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Right to withdraw consent at any time
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Right to data portability (where applicable)
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Right to lodge a complaint with the Superintendencia de Industria y Comercio (SIC) in Colombia, or the Agencia Española de Protección de Datos (AEPD) in Spain, depending on jurisdiction
📩 To exercise your rights: info@nourawellbeing.com
14. Changes to This Policy
We may update this policy as services evolve or regulations change. Major changes will be clearly communicated on our website and/or WhatsApp interface.
15. Contact
If you have any questions or concerns regarding this policy or your data:
📩 Email: info@nourawellbeing.com
📍 Legal Entity: Nextera Global Partners S.A.S.
📬 Address: Carrera 5 # 67–68, Bogotá, Colombia
📝 Trade name: NOURA – Evidence-Based Wellbeing™