Privacy Policy

Last Updated: March 6, 2025

Nucleai Inc. and its affiliates d/b/a “Nucleai” (“Nucleai”, “we” or “us”) respect the privacy of the Visitors of our websites and Users of our Platform, and are committed to protection of the personal data (defined below) that is made available to us.

This Privacy Policy describes how Nucleai collects, stores, uses and discloses the following categories of personal data:

Customer Data: personal data that we collect, process, and manage on behalf of our business customers (the “Customers”) as a part of Nucleai Atom or any other service, product or solution described on one or more applicable order forms and commercial agreements with the Customer (the “Platform”).
If we process any Customer Data, we will do so solely on behalf of and under the instruction of the Customer and in accordance with the commercial agreement and data processing addendum with them. Accordingly, this Privacy Policy (which describes Nucleai’s privacy and data protection practices) does not apply to such processing done on our Customers’ behalf. To learn more about the privacy policy and practices of our Customers, please contact them directly.
User Data: personal data relating to focal persons who directly engage with Nucleai concerning their organizational account, and users of the Services on behalf of such Customers, e.g., the account administrators and users, billing contacts and authorized signatories on behalf of the Customer (collectively, “Users”).
Visitors Data: personal data relating to visitors of our websites (including https://nucleai.ai), participants at our events, prospective customers, users or partners (collectively, “Visitors”) who visit or otherwise interact with our website, online ads and content, emails or communications under our control (the “Sites” and collectively with the Platform, the “Services”).

Specifically, this Policy describes our practices regarding:

Data Collection & Processing
Data Uses
Data Location
Data Retention
Data Disclosure
Cookies and Data Collection Technologies
Communications
Data Security
Data Subject Rights
Data Controller/Processor
Opt-Out of Sale/Sharing
Additional Notices and Contact Details

If you are a Customer, User or Visitor, please read this Privacy Policy carefully and make sure that you fully understand it.

Our Services are designated for businesses and are not intended for personal or household use. Accordingly, we treat all personal data covered by this Privacy Policy, including information about any visitors to our Sites, as pertaining to individuals acting as business representatives, rather than in their personal capacity.

You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (as defined below), please do not provide it to us and avoid any interaction with us or with our Sites, or use our Services.

1. Data Collection & Processing

When we use the terms “personal data” or “personal information” in this Privacy Policy, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an individual. It does not include aggregated or deidentified information that is maintained in a form that is not reasonably capable of being associated with or linked to an individual. Nucleai does not collect, use or disclose sensitive personal data under this Privacy Policy.

Types of personal data collected. We may collect or generate the following types of personal data about individuals through the Services:

Usage, login credentials, and device information concerning Users and Visitors
Connectivity, technical and aggregated usage data, such as user agent, IP addresses and approximate location based upon such IP addresses, digital identifiers, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, log-in credentials to the Platform, the cookies and pixels installed or utilized on their device (which collect data such as how often Visitors visit or use the Sites, which pages they visit and when, and which website ad or email message brought them there), and inferred or presumed data on or generated from their use of the Services.

Information concerning our Users and Visitors
Contact and business details such as name, email, phone number, position, workplace and related business insights, our communications with such individuals (correspondences, sensory information including call and video recordings, and transcriptions and analyses thereof), feedback and testimonials received, contractual and billing details, as well as any expressed, presumed or identified needs, preferences, attributes and insights relevant to our potential or existing engagement.

Personal data contained in Customer Data
Personal Data provided by our Customers or processed on their behalf and under their instruction and in accordance with the data processing addendum with them. Such data may include any of the types of personal data described above with respect to Users or other individuals whose data is contained in the Customer Data (e.g., Customer’s patients).

For the purposes of the California Consumer Privacy Act (“CCPA“), in the last 12 months, we have collected the following categories of personal information, as defined in the CCPA: identifiers; customer record information; internet or other electronic network activity information; professional or employment-related information; geolocation data; commercial information; audio, electronic, and visual information; and inferences.

Categories of sources from which personal data is collected. We obtain personal data from the following categories of sources:

Data collected directly from you. You may provide us with your personal data, e.g., when you submit a form on our website, during an event, conference, or webinar you have participated in or during our commercial engagement with you.
Data collected from third parties. We obtain personal data from third parties, such as our Customers or Service Providers. For example, we may get your details from your employer (which is our Customer) as a part of our commercial engagement. We may also obtain personal data from our Service Providers, e.g., marketing and sales tools, data enrichment services, our sales and marketing partners, distributors, or your colleagues.
Data that is automatically generated. Some personal data is automatically generated when you visit our website and engage its features (such as your online activity, clicks, web-pages visits, chatbot use, etc.) by using Cookies and the data collection technologies described in Section 6 below. We may also collect aggregated or technical data generated when you use our Services, relating to how you use them, so we can learn how Users use our Services and improve them and our users’ experience.

2. Data Uses

We use personal data for the following business and commercial purposes (and in reliance on the legal bases for processing noted next to them, as appropriate):

User personal data

To facilitate, operate, enhance, improve and provide our Services (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to provide and improve our Services);
To provide assistance and support, to test and monitor the Services, or diagnose or fix technology problems (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to ensure the ongoing availability of our Services);
To personalize our Services, including by recognizing an individual and remembering their information when they return to our Services, and to provide further localization and personalization capabilities (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to provide a better user experience).

User and Visitor personal data

To gain a better understanding of how individuals use and interact with our Services, which content and data they have processed through our Services, and how we could improve their and others’ user experience and the value they can generate from using the Services, so we can continue improving our products, offerings and the overall performance of our Services (Legitimate Interests to improve the user experience and performance of our Services);
To contact our Customers, Users and Visitors with general or personalized service-related messages, as well as promotional messages that may be of specific interest to them (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to send service-related messages; Consent to receive marketing messages);
To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal, criminal or prohibited activity (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to secure our services; Legal Obligation to implement appropriate security measures);
To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose (Legitimate Interests to improve and enhance our Services);
To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including to provide personalized ads and share data with our authorized service providers to support such activity (Legitimate Interests to enhance engagement with our Services and promote them; Consent (including by using Cookies) to use and share personal data including job or position information, if applicable and relevant with specific third-party service providers to provide personalization of ads);
To facilitate, sponsor and offer certain events, contests and promotions (Legitimate Interests to enhance engagement with our Services);
To enforce our User Terms and commercial agreements, to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties (Legitimate Interests to resolve disputes);
To comply with our contractual and legal obligations and requirements, and maintain our compliance with applicable laws, regulations and standards (Performance of Contract with our Customers, to the extent applicable; Legitimate Interests to maintain and improve our compliance; Legal Obligation, to the extent applicable).

If you reside or are using the Services in a territory governed by privacy laws under which “consent” is the only or most appropriate legal basis for the processing of personal data as described herein (in general, or specifically with respect to the types of personal data you expect or elect to be processed by or via the Services, or due to nature of such processing), your acceptance of our User Terms (and/or the terms that govern your use of the Platform) (collectively, the “Terms”) and this Privacy Policy will be deemed as your consent to the processing of your personal data for all purposes detailed herein. If you wish to revoke such consent, please contact us at info@nucleai.ai .

3. Data Location and Transfers

We and our authorized Service Providers maintain, store and process personal data in the United States, Israel, the European Union and in other locations as reasonably necessary for the proper delivery and performance of our Services, or as may be required by law.

Since we operate globally and may use service providers worldwide, including in the US, EU, Israel and other locations as reasonably necessary for the proper performance of our Services, or as may be required by law, we may transfer your personal data outside your country of residence.

While privacy laws may vary between jurisdictions, Nucleai is committed to protecting personal data in accordance with this Privacy Policy and customary industry standards, and such appropriate lawful mechanisms and contractual terms requiring adequate data protection, regardless of any lesser legal requirements that may apply in the jurisdiction to which such personal data is transferred.

For data transfers from the European Economic Area, the UK and Switzerland, we will transfer your personal data only to such countries approved by the European Commission, FDPIC and UK Information Commissioner’s Office (ICO) respectively, as providing adequate level of data protection, or enter into Standard Contractual Clauses as approved by the relevant data protection authority. You can obtain a copy of these clauses by contacting us as indicated in Section 12 below.

4. Data Retention

We retain personal data for as long as we deem it reasonably necessary in order to maintain and expand our relationship and provide you with our Services and offerings; in order to comply with our contractual obligations; or to protect ourselves from any potential disputes (i.e., as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.

To determine the appropriate period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and the applicable legal requirements.

If you have any questions regarding our data retention practices, please contact us by email at info@nucleai.ai .

5. Data Disclosure

We disclose personal data in the following ways:

Service Providers: We engage selected third-party companies and individuals to perform services on our behalf or complementary to our own. Such service providers may include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, billing and payment processing services, fraud detection and prevention services, web and product analytics, e-mail distribution and monitoring services, session or activity recording services, chatbot services, remote access services, content transcription and analysis services, performance measurement, data optimization and marketing services, social and advertising networks, content and data enrichment providers, event production and hosting services, e-mail, voicemails, support, enablement and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Services, and may only use the data as determined in our agreements with them.
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data in response to a legal request, such as a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations, with or without notice to you. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interest, including the security or integrity of our products and Services.
Disclosing Personal Data to our Customers: We may disclose Users’ personal data to their affiliated organization. In certain cases, other Users from your organization may control your account and will be entitled to monitor, process and analyze your data and associated content, including (i) view any content you submit and your activities on the Services; (ii) view statistics regarding your account; (iii) change your account password or other access credentials or privileges; (iv) suspend or terminate your account access; and (v) access or retain data stored as part of your account. Please note that in these circumstances, Nucleai is not responsible for and does not control any further disclosure, use or monitoring by or on behalf of your organization, that acts as the “Data Controller” of such data (as further described in Section 10 below).
Protecting Rights and Safety: We may disclose your personal data to others, if we believe in good faith that this will help protect the rights, property or personal safety of Nucleai, any of our Visitors, Customers or Users, or any members of the general public.
Nucleai Subsidiaries and Affiliated Companies: We may disclose personal data internally to our affiliated companies, for the purposes described in this Privacy Policy. In addition, should Nucleai or any of its subsidiaries or affiliates undergo any change in control, including by means of merger, acquisition or purchase of substantially all of its assets, your personal data may be disclosed to the parties involved in such event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail and/or prominent notice on our Services.
Additional Disclosures: Nucleai may disclose your personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. Additionally, we may transfer, disclose or otherwise use non-personal data at our sole discretion and without the need for further approval.

For the purposes of the CCPA, in the past 12 months, we may have disclosed identifiers; customer record information; internet or other electronic network activity information; professional or employment-related information; geolocation data; commercial information; audio, electronic, and visual information; and inferences to Service Providers, for Legal Compliance, to our Customers, to Protect Rights and Safety or to Nucleai Subsidiaries and Affiliated Companies. We did so in pursuit of the business and commercial purposes described in Section 2 above.

6. Cookies and Data Collection Technologies

We and our Service Providers use cookies and other similar technologies to enable and improve the Services we provide, to track the performance of our Sites, perform analytics and gain insights on the use of our Services and the performance of our activities, and for personalization purposes including personalization of ads if we have obtained your consent, where required. For more information on our cookie and data collection technologies practices, please visit our Cookie Policy.

Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.

Some cookies are necessary for the Services to function properly, and cannot be declined or disabled unless you delete and block them through your web browser settings. Other cookies, which are used for functional, performance, analytics and marketing purposes, are optional. You may opt in to or opt out from the use of optional cookies through the “Your Privacy Choices” feature available on our website, depending on your location and activity on our Services, as applicable. If you choose to opt out of certain cookies, this will typically generate a new cookie which will preserve your choice, and indicate it to our Services in your next visit so that the cookies you opted out of will not be utilized. You can also manage your cookies preferences, and accept, remove or entirely block cookies, through your browser settings.

Please note that certain web browsers may transmit “Do Not Track” signals to websites with which the browser communicates, telling the website not to follow its online movements. Because of differences in how web browsers interpret this feature and send those signals, and lack of standardization, we currently do not respond to such “Do Not Track” signals.

We also use the web analytics tool Google Analytics. This tool helps us understand users’ behavior on our Services, including by tracking page content, and click/touch, movements, scrolls and keystroke activities. Further information about the privacy practices of our analytics service provider is available at: www.google.com/policies/privacy/partners. Further information about your option to opt out of this analytics service is available at: https://tools.google.com/dlpage/gaoptout.

Please note that if you get a new device, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt out, so an additional opt-out will be necessary to prevent additional tracking.

7. Communications

Service Communications: Nucleai may contact you with important information regarding our Services. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, billing issues, service maintenance or changes, password retrieval notices, etc. You will not be able to opt out of receiving such service communications while using our Services, as they are integral to such use.

Notifications and Promotional Communications: We may send you notifications concerning new features, offerings, events, and special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contacts means available to us (e.g., phone, mobile or email), through the Services, or through our marketing campaigns on any other websites or platforms. Where consent is required, we will obtain consent before sending any notifications and promotional communications.

If you do not wish to receive such promotional communications, you may notify us at any time by sending an email to info@nucleai.ai or by following the “unsubscribe”, “stop” or “change email preferences” instructions contained in the promotional communications you receive.

8. Data Security

Nucleai and its Service Providers implement systems, applications, and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. These measures provide sound industry-standard security. However, please be aware that regardless of any security measures used or implemented, we cannot and do not guarantee the absolute protection and security of any personal data stored with us or with any third parties.

9. Data Subject Rights

Individuals have rights concerning their personal data. Please contact us by e-mail at: info@nucleai.ai if you wish to exercise your privacy rights under any applicable law, including the EU or UK General Data Protection Regulation (“GDPR”) ,the CCPA, and others such as – to the extent applicable – the right to know/request access to (specific pieces of personal data collected; categories of personal data collected; categories of sources from whom the personal data was collected; purpose of collecting personal data; categories of third parties with whom we have shared personal data), to request correction or erasure of your personal data held with Nucleai, or to restrict or object to such personal data’s processing (including the right to direct us not to sell or share your personal data to third parties now or in the future, as described below), or to port such personal data, or the right to equal services and prices (e.g. freedom from discrimination) (each to the extent available to you under the laws which apply to you). Under some regulatory frameworks, such as the GDPR, you may also have the right to lodge a complaint with the relevant supervisory authority, as applicable. These rights are also subject to various exclusions and exceptions under applicable laws. We will not charge a fee to process or respond to your verifiable privacy request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request. Alternatively, we may refuse to comply with your request in such circumstances.

To the extent applicable to you, you may also designate an authorized agent, in writing or through a power of attorney, to request to exercise your privacy rights on your behalf. The authorized agent may submit a request to exercise these rights by emailing us.

When you or an authorized agent ask us to exercise any of your rights, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal data related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. If your request relates to personal data contained in Customer Data (i.e., personal data we process on our Customer’s behalf as its “data processor” or “service provider”, as further explained in Section 10 below), such Customer exclusively determines how the data may be processed, as well as if and how your request should be handled. In such circumstances, we advise that you submit your request directly to them.

We may redact from the data which we will make available to you, any personal data or confidential information related to others.

10. Data Controller/Processor

Certain data protection laws and regulations, such as the EU GDPR, UK GDPR, and CCPA, typically distinguish between two main roles for parties processing personal data: the “Data Controller” (or under the CCPA, the “Business”), who determines the purposes and means of processing; and the “Data Processor” (or under the CCPA, the “Service Provider”), who processes the data on behalf of the Data Controller. Below, we explain how these roles apply to our Services, to the extent that such laws and regulations apply.

Nucleai is the “Data Controller” of its Visitors’ and Users’ Personal Data. With respect to such data, we assume the responsibilities of Data Controller (solely to the extent applicable under law), as set forth in this Privacy Policy. In such instances, our Service Providers processing such data will assume the role of “data processor”.

Nucleai is the “Data Processor” of Customer Data. Such data is being processed by Nucleai on behalf of the Customer (who is the “Data Controller” of such data; and our Service Providers who process such Customer Data on our behalf are the “sub-processors” of such data). Accordingly, Nucleai processes Customer Data strictly in accordance with our Customer’s reasonable instructions and as further stipulated in our data processing addendum and commercial agreement with such Customer.

Our Customers are solely responsible for determining whether and how they wish to use our Services, and for ensuring that all individuals using the Services on the Customer’s behalf or at their request, as well as all individuals whose personal data may be included in Customer Data processed through the Services, have been provided with adequate notice and given informed consent to the processing of their personal data, where such consent is necessary or advised, and that all legal requirements applicable to the collection, recording, use or other processing of data through our Services are fully met by the Customer, including specifically in the context of an employment relationship. Our Customers are also responsible for handling data subject rights requests under applicable law, by their Users and other individuals whose data they process through the Services.

12. Additional Notices and Contact Details

Updates and Amendments: We may update and amend this Privacy Policy from time to time by posting an amended version on our Services. The amended version will be effective as of the published date. We will provide prior notice if we believe any substantial changes are involved via any of the communication means available to us or via the Services. After such notice period, all amendments to this Privacy Policy shall be deemed accepted by you.

External Links: While our Services may contain links or integrations to other websites, social networks or services, we are not responsible for their privacy practices, and encourage you to pay attention when you leave our Services for the website or services of such third parties, or interact with social network integrations. We recommend you read the privacy policies of each and every website and service you visit. This Privacy Policy only applies to our Services.

Children’s Privacy: Our Services are not intended for use by children under the age of 18. We do not knowingly collect personal data from minors under the age of 18 and do not wish to do so. In the event that it comes to our knowledge that a minor is using the Services, we will prohibit and block such user from accessing the Services (to the extent reasonably possible) and will make all efforts to promptly delete any personal data stored with us with regard to such user.

EU Representative: Nucleai has designated Ido Kunst as its representative in the European Union, for data protection matters pursuant to Article 27 of the GDPR. Ido Kunst may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to ido.kunst@nucleai.ai.

UK Representative: Nucleai has designated Ido Kunst as its representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Inquiries regarding our UK privacy practices may be sent to: ido.kunst@nucleai.ai

Contacting Us: If you have any comments or questions about this Privacy Policy or if you have any concerns regarding your personal data held with us, please contact us at info@nucleai.ai

Privacy Policy

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