Privacy Policy

This Privacy Policy describes how Nowen ("we," "us," or "our") collects, uses, shares, and protects your personal data when you use the Nowen application and related services (the "Service"). We are committed to protecting your privacy and complying with the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados — LGPD, Law No. 13,709/2018) and other applicable data protection regulations.

Nowen is the data controller responsible for your personal data. Contact: support@nowen.app

We collect the following categories of personal data: Account Data: Your name, email address, password (stored in hashed form), and profile image. User Content: Photos, videos, notes, bookmarks, and comments you create and upload to the Service. Device Data: Device model, operating system, platform, and push notification tokens. Usage Data: Session information, screen views, and feature usage, collected via privacy-focused analytics tools. Technical Data: IP address, user agent, and server log data. Payment Data: Subscription status and transaction identifiers managed through a third-party subscription management provider. Nowen does not collect or store payment card numbers or banking details.

We process your personal data for the following purposes and legal bases under LGPD: Providing the Service (Contract Performance): We use your account data and user content to operate the Service, enable sharing within Spaces, and deliver core features. AI Analysis (Contract Performance): Photos, videos, and text may be processed by third-party AI providers for auto-tagging, search, and content analysis features that are part of the Service. Push Notifications (Consent): With your consent, we send push notifications about activity in your Spaces and other relevant updates. Analytics (Legitimate Interest): We collect anonymized usage data to understand how the Service is used and to improve it. Email Communications (Contract Performance): We send transactional emails for account verification, Space invites, and essential service notifications.

We share your data with the following third-party service providers, solely for the purposes described: Cloud Storage Providers: Secure file storage for your photos, videos, and other uploaded content. AI Processing Providers: Image and video analysis, text embeddings for search and auto-tagging features. Subscription Management Provider: Subscription and in-app purchase management. Push Notification Services: Push notification delivery for iOS and Android. Analytics Provider: Privacy-focused analytics. SMTP Provider: Transactional email delivery (account verification, invitations). We do not sell your personal data to third parties.

Your data may be processed in countries outside of Brazil, including the United States, where our cloud infrastructure and AI service providers operate. When data is transferred internationally, we ensure appropriate safeguards are in place in accordance with LGPD requirements, including contractual clauses and security measures to protect your data.

We retain your data according to the following policies: Account and Content Data: Retained for as long as your account is active. Upon account deletion, all your data is permanently erased. Server Logs: Retained for a limited period for security and debugging purposes. Cache Data: Link metadata is cached for up to 7 days; other caches are retained for minutes to hours. Subscription Events: Retained for auditing and legal compliance purposes.

Under the LGPD, you have the following rights regarding your personal data: • Confirmation of whether your data is being processed • Access to your personal data • Correction of inaccurate, incomplete, or outdated data • Anonymization, blocking, or deletion of unnecessary or excessive data • Data portability to another service provider • Deletion of personal data processed with your consent • Information about third parties with whom your data is shared • Information about the possibility of denying consent and the consequences • Revocation of consent at any time • Right to petition the ANPD (Autoridade Nacional de Proteção de Dados — National Data Protection Authority) To exercise any of these rights, contact us at support@nowen.app. We will respond to your request within the timeframe established by law.

We implement appropriate technical and organizational measures to protect your personal data, including: • Encryption in transit using HTTPS/TLS • Encrypted credential storage • Presigned URLs for secure file access • Rate limiting and input validation • Regular security reviews While we strive to protect your data, no method of transmission over the Internet or electronic storage is 100% secure.

The Service is not directed at children under 13 years of age. We do not knowingly collect personal data from children under 13. If we become aware that we have collected personal data from a child under 13, we will take steps to delete that information promptly. If you believe a child under 13 has provided us with personal data, please contact us at support@nowen.app.

The Service uses the following local storage mechanisms: • Session Cookies: Used for authentication and maintaining your login session • Local Device Storage: Used to store your preferences and settings locally on your device We do not use third-party tracking cookies. Our analytics solution is privacy-focused and does not rely on cookies for tracking.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or legal requirements. We will notify you of material changes by posting the updated policy within the App or on our website. Your continued use of the Service after changes are posted constitutes your acceptance of the updated policy.

If you have questions about this Privacy Policy, wish to exercise your data protection rights, or need to contact our Data Protection Officer, please reach out to: Email: support@nowen.app You also have the right to file a complaint with the ANPD (Autoridade Nacional de Proteção de Dados) if you believe your data protection rights have been violated.