Privacy Policy

Effective Date: March 9, 2026

Nuel, Inc. ("Nuel," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your personal information when you visit our website at www.nuel.ai (the "Site") or use our services. It also describes your rights and choices regarding your data.

Nuel is a supply chain decision intelligence platform. We process data on behalf of our business clients to deliver AI-powered analytics and recommendations. This policy covers the data we collect from visitors to our public website, not the operational data we process on behalf of our enterprise clients, which is governed by separate data processing agreements.

1. Information We Collect

Information You Provide to Us

When you interact with our Site, you may provide us with personal information, including:

• Contact details (name, email address, company name, job title) when you fill out our "Book a Demo" or contact forms
• Communication content when you email us or subscribe to our Signals Newsletter
• Any other information you choose to share with us directly

Information Collected Automatically

When you visit our Site, we may automatically collect certain information, including:

• Device and browser information (browser type, operating system, screen resolution)
• Usage data (pages visited, time spent on pages, referral source)
• IP address (used in anonymized form for analytics)
• Cookies and similar technologies (see Section 8 below)

2. Lawful Basis for Processing

If you are located in the European Economic Area (EEA), United Kingdom (UK), or Switzerland, we process your personal data under the following lawful bases:

• Consent: Where you have given us clear consent to process your personal data for a specific purpose, such as subscribing to our newsletter or accepting non-essential cookies.
• Legitimate Interests: Where processing is necessary for our legitimate business interests (such as improving our Site, understanding how visitors use it, and responding to inquiries), provided those interests are not overridden by your rights.
• Contractual Necessity: Where processing is necessary to take steps at your request prior to entering into a contract (such as when you request a demo).
• Legal Obligation: Where we are required to process your data to comply with applicable law.

You may withdraw your consent at any time by contacting us at the address listed below. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

3. How We Use Your Information

We use the information we collect to:

• Respond to your inquiries and demo requests
• Deliver and improve our website and services
• Analyze site usage trends and measure performance
• Send you updates, newsletters, or marketing communications (only with your consent, and you can unsubscribe at any time)
• Protect the security of our Site and detect fraud or abuse
• Comply with legal obligations

We do not sell or rent your personal information to third parties.

4. Sharing with Third Parties

We may share your information with trusted third-party service providers who assist us in operating our Site and delivering our services. These may include:

• Website hosting and infrastructure (Framer)
• Analytics services (such as Google Analytics, if enabled)
• Email communication and newsletter platforms
• Customer relationship management tools

All third-party providers are contractually required to handle your data in accordance with applicable data protection laws and only for the purposes we specify. We do not allow them to use your personal data for their own purposes.

We may also disclose your information if required by law, legal process, or a government request, or if we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

4a. Sub-Processors

Nuel uses the following third-party sub-processors to deliver our services. All sub-processors are contractually bound to handle data in accordance with applicable data protection laws:

• DigitalOcean — Cloud infrastructure and backend hosting — United States — SOC 2 Type II
• Vercel — Frontend application hosting — United States — SOC 2 Type II
• GitHub (Microsoft) — Source code and version control — United States — SOC 2 Type II
• Google Workspace — Business email and internal collaboration — United States — SOC 2 Type II, ISO 27001
• Slack — Internal team communications — United States — SOC 2 Type II

This list is reviewed and updated upon any material change. To be notified of sub-processor changes, contact privacy@nuel.ai.

5. International Data Transfers

Nuel is based in the United States. If you are accessing our Site from the European Economic Area, United Kingdom, Switzerland, Brazil, or any other region with data transfer regulations, please be aware that your personal data may be transferred to, stored, and processed in the United States.

Where we transfer personal data outside the EEA or UK, we rely on appropriate safeguards, including the European Commission's Standard Contractual Clauses (SCCs), to ensure your data receives an adequate level of protection. You may request a copy of these safeguards by contacting us at the address below.

6. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.

For inquiries and demo requests, we typically retain your data for the duration of our business relationship and for a reasonable period afterward, unless you request earlier deletion. Newsletter subscriber data is retained until you unsubscribe.

You may request deletion of your personal data at any time by contacting us at contact@nuel.ai. We will respond to your request within 30 days.

7. Your Rights

For EEA, UK, and Swiss Residents (GDPR)

Under the General Data Protection Regulation, you have the right to:

• Access: Request a copy of the personal data we hold about you.
• Rectification: Request that we correct inaccurate or incomplete data.
• Erasure: Request that we delete your personal data, subject to certain exceptions.
• Restriction: Request that we restrict the processing of your data.
• Data Portability: Request a copy of your data in a structured, commonly used, machine-readable format.
• Objection: Object to processing based on legitimate interests or for direct marketing purposes.
• Withdraw Consent: Where processing is based on consent, withdraw that consent at any time.

To exercise any of these rights, please contact us at contact@nuel.ai. We will respond to your request within 30 days. If you are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.

For Brazilian Residents (LGPD)

If you are located in Brazil, you have similar rights under the Lei Geral de Proteção de Dados (LGPD), including the right to access, correct, delete, and port your personal data. Contact us at contact@nuel.ai to exercise these rights.

8. Cookies and Similar Technologies (Cookie Policy)

What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They help the site function properly, remember your preferences, and understand how you interact with the content.

Cookies We Use

• Essential Cookies: These are necessary for the basic operation of our Site. They cannot be disabled. No consent is required for these cookies.
• Analytics Cookies: We use Framer's built-in analytics, which are fully anonymized and do not use cookies or persistent identifiers. If we also use Google Analytics or similar services, those tools place cookies to help us understand site traffic and usage patterns. These cookies are only activated after you give consent.
• Marketing Cookies: If enabled, these cookies track your activity across websites to deliver targeted advertising. Examples include LinkedIn Insight Tag or similar pixels. These cookies are only activated after you give consent.

Your Cookie Choices

When you first visit our Site, you will see a cookie consent banner that allows you to accept or decline non-essential cookies. You can also adjust your preferences at any time by clicking the cookie settings link in the footer of our Site.

If you decline non-essential cookies, only essential cookies required for the Site to function will be placed on your device. No analytics or marketing cookies will be set without your explicit consent.

You can also manage cookies through your browser settings. Most browsers allow you to block or delete cookies. Please note that blocking all cookies may impact your experience on our Site.

Third-Party Cookies

Some cookies on our Site may be set by third-party services. These third parties have their own privacy policies:

• Google Analytics: https://policies.google.com/privacy
• LinkedIn: https://www.linkedin.com/legal/privacy-policy
• Framer: https://www.framer.com/legal/privacy-statement/

9. Security

We employ organizational and technical safeguards designed to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include encryption in transit (TLS/SSL), role-based access controls, sandbox environments for data processing, and regular security reviews.

While we take reasonable steps to protect your information, no method of transmission or electronic storage is completely secure. We cannot guarantee absolute security but are committed to maintaining and improving our protections.

10. Children's Privacy

Our Site and services are not directed at individuals under the age of 16 (or the applicable age of digital consent in your jurisdiction). We do not knowingly collect personal data from children. If we become aware that we have collected personal data from a child, we will take steps to delete it promptly.

11. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act provide you with additional rights regarding your personal information:

• Right to Know: You may request information about the categories and specific pieces of personal information we have collected about you.
• Right to Delete: You may request that we delete the personal information we have collected from you.
• Right to Opt Out: You may opt out of the sale or sharing of your personal data. Note: Nuel does not sell personal data.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

To exercise your rights under California law, please contact us at contact@nuel.ai. We will verify your identity before processing your request and respond within 45 days.

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. When we make material changes, we will update the "Effective Date" at the top of this page. We encourage you to review this page periodically.

13. Contact Us

If you have questions, concerns, or requests related to this Privacy Policy or your personal data, please contact us:

Nuel, Inc. Email: contact@nuel.ai Privacy inquiries: privacy@nuel.ai Website: www.nuel.ai

14. Data Processing Agreement

For enterprise clients whose data Nuel processes as a data processor, a Data Processing Agreement (DPA) is available upon request and is incorporated into all client engagement agreements. The DPA governs how Nuel collects, processes, stores, and deletes client data in accordance with GDPR Article 28 and applicable data protection law.

To request a copy of our standard DPA, contact privacy@nuel.ai.

This privacy policy was last updated on March 9, 2026. Version 26.1