I. Introduction

When you use Nobli, you trust us with your personal data. We are deeply committed to maintaining that trust. This commitment starts with helping you understand our privacy practices. This notice explains the personal data ("data") we collect, how it's used and shared, and the choices you have regarding your data. We encourage you to read this carefully.

II. Overview

This notice applies to users of Nobli's services worldwide, including users of Nobli's app, website, features, or other services. This notice describes how Nobli and its affiliates collect and use data. It applies to all Nobli users globally. Specifically, this notice applies to:

Profile Owners: Individuals who create a Nobli account to organize, store, and share their personal data, memories, and digital legacy.
Family Members and Trusted Contacts: Individuals who are granted access to certain vaults, family tree connections, or shared content by Profile Owners.

This notice also governs Nobli's collection of data in connection with its services. All those subject to this notice are collectively referred to as "users" in this document. Our privacy practices comply with applicable laws in the regions where we operate. We engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

A. Data controller and transfer

1. Nobli LTD as the Data Controller

Nobli LTD (4 Panteli Katelari, Egkomi, Nicosia 2413, Cyprus) is the data controller for the personal data collected in connection with the use of Nobli's services. Nobli operates and processes personal data globally. Wherever and whenever you use our services, your data travels with you to provide a seamless experience. We respect your data protection rights regardless of your location, whether you are in your home country or abroad.

This means that we may transfer personal data to countries other than your home country in order to provide our services in another region at your request. We may also transfer personal data to another country to respond to customer support requests made outside your region. Additionally, data such as shared files or family tree connections may be accessed by authorized users in different countries. We undertake these transfers to fulfill our agreements with our users or based on users' instructions or prior consent. These transfers are conducted in compliance with adequacy decisions for the relevant countries or other transfer mechanisms provided under applicable laws, such as the Standard Contractual Clauses.

We may also transfer data to other countries in response to legal requests from law enforcement agencies. Nobli ensures compliance with the regulatory requirements of applicable laws, including the EU GDPR, and applies a rigorous internal procedure to process such requests. Nobli only discloses personal data to law enforcement in cases where disclosure is required by applicable law, there is imminent risk of serious harm to individuals, or the user has provided consent.

To provide consistent and robust data protection worldwide, Nobli has implemented the following measures:

Policies and procedures that limit access to and processing of personal data for specific purposes.
Specialized training for personnel managing personal data.
A government data access policy that ensures access is refused unless disclosure is mandated by law, there is imminent risk of harm, or consent is provided by the user.
Secure data transfer protocols, including encryption and pseudonymization, to protect personal data while in transit or during processing on our servers.

III. Data collections and uses

A. The Data We Collect

Nobli collects data to provide and enhance our services. This includes data:

Provided by users to Nobli, such as during account creation or updating profiles.
Created during the use of our services, such as activity logs, app usage, and device data.
Obtained from other sources, such as trusted contacts, business partners, and government authorities.

1. Data Provided by Users

User Profile Information: We collect data when users create or update their Nobli accounts. This includes:

Name, email, phone number, login credentials, and profile picture.
Files and documents uploaded to Vaults, such as photos, videos, legal documents, and medical records.
Family tree data, including relationships, names, and chosen designations for family members.
Emergency contact information.
User preferences and account settings.

Identity Verification: Users may be required to verify their identity, which can include providing photos of government-issued identification (such as passports or ID cards) and/or selfies. These may be used for security and account verification purposes.

Demographic Data: We may collect demographic data, such as age, gender, or occupation, when required for certain features or programs. This data may also be inferred from user input or collected through surveys.

2. Data Created During Use of Our Services

Activity Data: We collect data about user activity within the Nobli app, such as:

Vault creation and sharing preferences.
Tags and categorizations of uploaded files.
Interactions within the Family Tree feature, such as relationships established and Cube highlights selected.
Public content shared via the Feed.

Usage Data: We collect data on how users interact with Nobli's features. This includes: Access dates and times; Pages or app features viewed; App crashes and other system activities; Preferences set for visibility and sharing.

Device Data: We collect data about the devices used to access Nobli, including: Device hardware models, operating systems, and versions; Device IP address, unique device identifiers, and mobile network data; Browser types and preferred languages.

Communications Data: We may collect data regarding in-app communications, such as messages exchanged within Nobli, including timestamps and content where necessary.

3. Data from Other Sources

Trusted contacts who receive or share Vaults or Family Tree connections.
Users participating in referral programs, where the referring user provides the referred user's data.
Business partners that help facilitate services, such as payment providers or marketing services.
Publicly available sources for verifying information or enriching profiles.
Law enforcement or government authorities when required by applicable laws.

B. How We Use Personal Data

Nobli uses data to provide a secure, personalized platform for users to share their stories, organize their digital lives, and create a lasting legacy. We also use such data:

To enhance the safety and security of our users and services.
For customer support.
For research and development to improve the user experience.
To enable communications between users.
For marketing and advertising (with user consent where required).
To send non-marketing communications to users.
In connection with legal proceedings.

1. To Provide Our Services

Nobli uses data to provide, personalize, maintain, and improve its services. This includes: Creating and updating user accounts; Enabling core features, such as creating and managing Vaults, establishing and interacting with Family Tree connections, uploading, tagging, and sharing personal files, and highlighting specific memories within the Cube feature; Processing permissions for sharing Vault content with trusted contacts; Sending updates about changes to Nobli's terms, services, or policies; Performing necessary operations to maintain the app, such as troubleshooting software bugs and addressing operational issues. Nobli performs the above activities to fulfill its agreements with users and to serve its legitimate interest in providing secure, high-quality services.

2. Safety and Security

We use data to help maintain the safety, security, and integrity of our platform and users. This includes verifying user identities, using device and activity data to prevent fraud or misuse, and identifying behaviors that violate our terms of service.

3. Customer Support

We use the information we collect to provide customer support, including investigating and addressing user concerns and monitoring and improving our support processes.

4. Research and Development

We use data for testing, analysis, and product development to improve user experience, enhance safety, and develop new features.

5. Enabling Communications Between Users

Nobli facilitates communication between users to enhance collaboration and connection. For example: Trusted contacts may receive notifications when Vault content is shared with them, and Family Tree members may interact through the platform to share memories or updates.

6. Marketing and Advertising

Nobli may use data to market its services or those of its partners, including sending emails, push notifications, or in-app messages and displaying personalized advertising on third-party platforms. These activities are performed with user consent or to serve Nobli's legitimate interest.

7. Non-Marketing Communications

We may use data to send surveys or other communications unrelated to marketing, such as informing users about changes to features or policies and gathering feedback.

8. Legal Proceedings and Requirements

We use data to investigate claims or disputes related to Nobli services and comply with applicable laws, regulations, or legal requests from governmental authorities.

C. Data Sharing and Disclosure

Some of Nobli's features and services require sharing data with other users or at a user's request. We may also share data with our affiliates, service providers, and partners, for legal reasons, or in connection with claims or disputes.

1. With Other Users

This includes sharing content within Vaults with authorized recipients, and allowing users in your Family Tree to access your profile and highlights based on permissions you set. It also includes sharing certain data for referral programs.

2. At the User's Request

This includes sharing data with Emergency Services (if opted in) and Trusted Contacts chosen by the user.

3. With the General Public

Content in Public Vaults or the Public Feed is accessible to all Nobli users. Questions or comments on social media pages or public forums may also be viewable by the general public.

4. With Nobli Service Providers and Business Partners

These include: Cloud Storage Providers; Payment Processors; Identity Verification Providers; Research Partners; Social Media Platforms (e.g., for analytics or advertising); and Professional Service Providers (consultants, lawyers, accountants).

5. For Legal Reasons or in the Event of a Dispute

Nobli may share data if required by applicable law, regulation, or governmental request; to enforce our Terms of Service; or to protect Nobli's rights, property, or the safety of others. This may include sharing with law enforcement or in the event of a merger, acquisition, or sale of assets.

6. With Consent

Nobli may share data in ways not described in this notice if the user is informed and consents to such sharing.

E. Cookies and Third-Party Technologies

Nobli and its partners use cookies and other identification technologies on our app, website, emails, and online advertisements. Cookies are small text files stored on browsers or devices. Nobli uses them for: Authenticating users; Remembering user preferences; Analyzing app and site traffic; and Delivering and measuring the effectiveness of advertising campaigns.

F. Data Retention and Deletion

Nobli retains user data for as long as it is necessary to provide its services and comply with legal obligations. Active account data (profiles, Vault content, Family Tree information) is retained for the life of a user’s account. Data may be retained after an account deletion request to comply with legal requirements, prevent fraud, or resolve outstanding issues such as unpaid credits or disputes.

Account Deletion Requests: Users may request deletion of their accounts at any time through Nobli’s app or website contact form. Upon request, Nobli will delete the account and associated data unless retention is necessary for legal/regulatory obligations, safety/fraud prevention, or addressing unresolved issues.

IV. Updates to this notice

We may occasionally update this Privacy Notice. If significant changes are made, we will notify users in advance through the Nobli app or other means, such as email. We encourage users to periodically review this notice to stay informed. Continued use of Nobli’s services after an update constitutes your acceptance of the updated notice, as permitted by applicable law.