This Privacy Policy explains how Nina (“we”) collects, uses, shares and protects personal data when you visit our website or use the Nina dashboard and traffic filtering service (the “Service”), in accordance with the Brazilian General Data Protection Law (Law 13,709/2018 — LGPD) and other applicable laws.
01Who we are
Controller: Nina (ninacloaker.com). Contact: contact@ninacloaker.com.
Data protection officer (encarregado): admin@ninacloaker.com.
02Data we collect
2.1 Website visitors
When you visit this website, we receive technical data sent by your browser — such as IP address, browser and device type, pages accessed, date and time — to deliver the site, keep it secure and understand how it performs.
2.2 Customers
- Account data: name, email, password (stored only in encrypted form by our authentication provider) and two-factor authentication settings.
- Billing data: plan, payment history and status. Card details are collected and processed directly by our payment provider (Stripe); we do not store full card numbers.
- Usage data: the campaigns, domains, rules and settings you create, access logs (such as IP address and date and time of access) and records of actions in the dashboard.
- Communications: messages you send to our support and the transactional emails we send you.
2.3 Visitors to our customers’ campaigns
When someone opens a campaign link managed by Nina, the Service processes technical data about that visit — IP address, user agent, device type, approximate location (country), referrer, date and time, and the decision taken (safe page or offer page) — to filter and route the traffic and to show reports to the customer.
For this data, the customer is the controller and Nina acts as processor (operador), following the customer’s instructions. Visitors should send their requests to the customer who owns the campaign; we will support the customer as required by law.
03Purposes and legal bases
- Create and manage your account and provide the Service — performance of a contract (LGPD, art. 7, V).
- Process payments, issue receipts and keep tax records — performance of a contract and compliance with legal obligations (art. 7, II and V).
- Keep the Service secure, prevent fraud and abuse and moderate campaigns — legitimate interest (art. 7, IX) and compliance with legal obligations.
- Keep access logs for the period required by the Brazilian Internet Civil Framework (Law 12,965/2014, art. 15) — legal obligation (art. 7, II).
- Send service messages about security, billing and account status — performance of a contract.
- Improve the Service and understand how it is used — legitimate interest, using aggregated data whenever possible.
- Send news and offers — consent, which you can withdraw at any time through the unsubscribe link.
04Sharing
We do not sell personal data. We only share it with:
- infrastructure and hosting providers that run the website, the database and the filtering servers;
- our payment provider (Stripe), to process charges;
- our email delivery provider, to send transactional messages;
- public authorities, when required by law or court order;
- a successor company in case of merger, acquisition or sale of assets, which will remain bound by this Policy.
Providers process data on our behalf, under contracts that require confidentiality and security.
05International transfers
Some of our providers store or process data outside Brazil, for example in the United States. In these cases, we adopt the safeguards required by the LGPD (art. 33), such as contractual clauses and providers that offer an adequate level of protection.
06Cookies
This website uses a strictly necessary cookie to remember your language and does not use advertising cookies. The dashboard uses cookies and local storage needed to keep you signed in. If we start using analytics or marketing cookies, we will update this Policy and ask for your consent where required.
07Retention
- Account and usage data: while your account is active and, after it is closed, for as long as needed to comply with legal obligations or to exercise rights in legal proceedings.
- Access logs: for at least 6 months, as required by Law 12,965/2014.
- Billing records: for the period required by tax law.
- Visit data from customers’ campaigns: for as long as needed to provide the Service and the reports to the customer, who may request earlier deletion.
When data is no longer needed, it is deleted or anonymized.
08Security
We use technical and organizational measures to protect personal data, such as encrypted connections (HTTPS), access control based on least privilege, two-factor authentication for administrative access and monitoring. No system is completely secure, so we also ask you to keep your password safe and to enable two-factor authentication.
If a security incident may cause relevant risk or damage to data subjects, we will notify the Brazilian Data Protection Authority (ANPD) and the people affected, as required by the LGPD (art. 48).
09Your rights
Under the LGPD (art. 18), you may ask us for: confirmation that we process your data; access to it; correction of incomplete, inaccurate or outdated data; anonymization, blocking or deletion of unnecessary or excessive data; portability; information about who we share data with; information about the option not to consent and its consequences; withdrawal of consent; and review of decisions made solely by automated processing (art. 20).
To exercise your rights, write to admin@ninacloaker.com. We may ask for information to confirm your identity. You may also file a complaint with the ANPD.
If you are in the European Economic Area or the United Kingdom, you have similar rights under the GDPR, including the right to object and to lodge a complaint with your local supervisory authority.
10Children
The Service is intended for adults. We do not knowingly collect data from people under 18.
11Changes to this Policy
We may update this Policy. The current version is always on this page with its date, and we will notify you of significant changes.
12Contact
Data protection officer (encarregado): admin@ninacloaker.com. Other questions: contact@ninacloaker.com.