Privacy Policy

Last Updated: 27.10.2025

The nuwacom Group recognizes the importance of privacy. nuwacom will manage your Personal Data collected through the nuwacom Website, based on nuwacom belief of respect for the individual and in accordance with this nuwacom privacy policy (the “Privacy Policy”).

By using the website in any way, including browsing, using, and/or purchasing any of the services provided through the website, you agree to the privacy policy and the processing of your personal data in accordance with the terms therein. If you do not agree with this Privacy Policy, please do not provide Personal Data, and please do not use the Website. Unless defined herein, capitalized terms in this Privacy Policy shall have the meaning ascribed to them in nuwacom Terms of Service.

nuwacom collects and uses Personal Data for various purposes. In this Privacy Policy we describe what Personal Data we collect, how and why we process it, and who we share it with. We also explain your rights in relation to your Personal Data and how you can exercise them.

References to “nuwacom”, “we”, or “us” in this Privacy Policy mean  the relevant nuwacom group company, which will be either: (i) nuwacom GmbH, with its registered office at Universitätsstraße 3, 56070 Koblenz, Germany, acting as Controller for enterprise customers contracting with nuwacom GmbH in Germany, or nuwacom S.à r.l., 20 rue des Peupliers, L-2328 Luxembourg (“nuwacom”) acting as Controller for all other processing activities performed on your Personal Data as described in this Privacy Policy with the meaning of Art. 4 No. 7 of the General Data Protection Regulation (GDPR). nuwacom and its affiliated companies shall be the “nuwacom Group” under this Privacy Policy.

For the purposes of this Privacy Policy, “personal data” means any information relating to an identified or identifiable individual in line with Article 4(1) GDPR.

When does this Privacy Policy apply?

This Privacy Policy applies when nuwacom is the data controller of Personal Data — meaning, when we determine how and why your Personal Data is processed. This includes situations where you:

• visit or interact with our websites available at https://nuwacom.ai and their subdomains (together the “nuwacom Website”);

• register for or participate in our webinars, trainings, or events;

• inquire about or engage in commercial transactions with us;

• interact with the nuwacom software, apps, or related services in cases where we collect information for which we determine the means and purposes of processing (for example, service feedback, usage metrics, or product improvement analytics).

Important clarification

This Privacy Policy does not apply to the processing of Customer Content (as defined in our Terms of Service) when Nuwacom provides its services in the role of a data processor. In those cases, we process Personal Data strictly on behalf of and in accordance with the instructions of our customers (the controllers).

If your employer or another organization is using the nuwacom software and you want to understand how your Personal Data is handled within that environment, please contact your employer or the respective organization directly. Our processing activities in that context are governed by our Data Processing Agreement (DPA), available at https://trust.nuwacom.ai/.

For further information about our company, please refer to the legal notice (imprint) on our website at www.nuwacom.ai/imprint.

1. The Personal Data we process

We collect Personal Data from various sources, including: (i) directly from you; and (ii) from third parties (such as our partners or service providers). Some data is collected automatically, for example, information related to the device you use to engage with the nuwacom Website, our Product, or other Services provided by us.

Contact information and other identifiers. When you register for a demo, trial, webinar or event, request certain content, or otherwise contact us to receive information about our products and services (either on the nuwacom Website or on a third-party website), we collect the contact details you provide. This may include your full name, private or company email address, (company) phone number, and physical address. We may also ask for your job title, role, or other relevant information. We use this information to communicate with you and provide you with information about our products and services in line with your marketing preferences.

Prospect and customer account details. If you represent an organization that has expressed an interest in nuwacom (a prospect) or an organization that is an existing nuwacom customer, we collect your business contact information to create or link you to a business account. Account details include your name, company email address, phone number, job title, and the name of your organization. We use this information to manage the organization’s account (including invoicing and other account-related activities) and to communicate with you.

Communication data. When you contact us via email, telephone, or any other communication channel, we collect any Personal Data contained in those communications so we can respond and follow up appropriately.

Call recordings. If you have a scheduled a call with a nuwacom representative, we may record the call. You will be notified prior to the call and will have the opportunity to object. We use recordings for internal training and coaching. We may also use AI-assisted tools to analyze recordings to understand prospect and customer interests in order to better tailor our products and services.

Financial information. If you register for a paid event or webinar organized by nuwacom, we may collect billing information such as billing name, billing address, and payment card details. Payment information is encrypted and handled only by PCI-certified organizations.

Technical information when you visit the nuwacom Website. When you visit the nuwacom Website, we automatically collect information linked to your device: IP address, browser type, domain names, internet service provider (ISP), Time zone difference to GM, Content of the web page, Access status (HTTP status), Amount of data transferred, request website, browser language, browser version, operating system, and cookies. To continuously improve the nuwacom Website and how we interact with you, we may use tracking technologies to analyze which sections you visit, how long you stay, and how you engage with certain (email) communications and advertisements. You can find more information about the cookies we use and how to control these technologies in our Cookie Notice and via our Cookie Preferences. For certain cookies, we ask for your consent when you first visit our website. You can withdraw your consent at any time by changing your cookie preferences in the nuwacom Cookie Preferences menu (link available on our site). Our cookie consent is managed with Cookiebot (Usercentrics A/S).

Product usage data. When you use our Product through your employer or other organization (a nuwacom customer), we log certain technical information automatically. This may include IP address, device type, OS type and version, Product version, date/time stamps, cookies, and browser type. To understand which features are effective and where to invest, we also collect information about which features you use and how you use them. Product usage data is primarily technical, anonymized, or aggregated; however, it may occasionally contain limited information that constitutes Personal Data under applicable laws.

Information from third parties and publicly available sources. We may collect information about you or your company from third-party sources or services, including partners with which we engage in joint marketing or sales. Such information may include: your name, company email address, social media account, IP address, telephone number, company name/description/website, company revenue and employee range, industry, role, title, and seniority. This information is used to enhance our marketing and sales efforts.

Training and e-learning platform details. nuwacom may offer an external or integrated learning platform (e.g., “nuwacom Academy”). Use is voluntary. If you participate, you may be asked to create an account. Upon registration, we may collect your full name, email address (business and/or private), job title, areas of interest, and information about your organization. We also process your training progress and may issue certificates upon course completion.

Feedback about our Product and services. We enable partners and customers to provide ideas and feedback about the nuwacom Product. Before submitting feedback, we may request your name and email address to keep you updated on status. Sometimes we request feedback through other channels—e.g., forms, panels, surveys, or third-party platforms. In those cases, we may collect your name, email address, location, type of organization, role, and other study-relevant information. For certain studies we may collect photos, video, or audio (with your permission).

Any other information voluntarily provided by you. If you participate in user-experience interviews or other activities or events organized by nuwacom, we collect any additional information you voluntarily provide. With your permission, we may publish testimonials or featured customer stories to promote our Services.

No processing of Personal Data of children under 16. The nuwacom Website is not intended for anyone under the age of 16. We do not knowingly collect Personal Data from children under 16. If we learn that we have collected Personal Data from a child under 16, we will delete it. If you are a parent or legal guardian and you are aware that your child under 16 has provided us with Personal Data, please contact us at support@nuwacom.ai. Controller and contact details are provided in our policy.

2. The purpose and legal basis of processing

We process the Personal Data described above for the purposes set out below and based on the corresponding legal bases under the GDPR.

Fulfil our (pre)contractual obligations and provide support to customers. We process prospect and customer account details to manage your organization’s account and deliver the Product/Services—including communicating with you and managing invoices and other account-related administrative or contractual matters. Legal basis: Art. 6(1)(b) GDPR (contract) and, where applicable, Art. 6(1)(f) GDPR (legitimate interests).

Improve our Product and other services (incl. customer service). We analyze Product usage data, feedback, communications, and (where applicable) call recordings to understand needs, prioritize testing and feature development, improve forecasting, define product and pricing strategy, and anticipate market demand. Legal basis: Art. 6(1)(f) GDPR (legitimate interests).

Send you marketing communication. We use your information to send requested content, marketing information, product recommendations, and other non-transactional communications (including newsletters and telemarketing calls) that we believe may interest you, in accordance with applicable laws. You can unsubscribe at any time via the link at the bottom of our marketing emails or by contacting us. Legal basis: Art. 6(1)(a) GDPR (consent) or, where permitted, Art. 6(1)(f) GDPR (legitimate interests). Newsletter operations (including double opt-in and retention) are handled as described in our policy.

Expand our business through marketing and sales channels. We use third-party and publicly available business information (e.g., company size, industry) so that we only approach people and companies likely to benefit from our Product and Services and to better understand the needs of leads, prospects, or customers. Legal basis: Art. 6(1)(f) GDPR (legitimate interests).

Provide and improve the nuwacom Website. We process technical information to provide access to the nuwacom Website and to continuously improve the content and user experience. This includes analyzing interactions with our Website and communications via cookies or similar technologies. For analytics and tag management, we use Google Analytics and Google Tag Manager (consent where required). Legal basis: Art. 6(1)(f) GDPR (legitimate interests) and, where applicable, Art. 6(1)(a) GDPR (consent).

Manage event or webinar registration and attendance. We process Personal Data to plan and host events or webinars for which you have registered or that you attend, and to send related communications. Legal basis: Art. 6(1)(b) (contract) GDPR.

Improve any nuwacom training/e-learning offerings. Where available, we may analyze which modules are most visited and which company profiles/industries are most engaged, including integrations with our CRM to understand customer health and provide tailored support. Legal basis: Art. 6(1)(f) GDPR (legitimate interests).

Secure the nuwacom Website, Services, and Product. We process technical and Product usage data to operate, maintain, and secure our Website and Product and to protect against malicious, deceptive, fraudulent, or illegal activity, including violations of our contracts and policies. Legal basis: Art. 6(1)(f) GDPR (legitimate interests).

Manage our social media channels. We may process your contact details to manage and maintain our presence on social media platforms, enabling timely engagement, communication, and relevant content. Legal basis: Art. 6(1)(f) GDPR (legitimate interests).

3. How and why we share your Personal Data

Third-party service providers. We employ service providers to act on our behalf (e.g., web analytics, web hosting, marketing and advertising, email services, CRM systems, chat software, payment services, learning platforms, and video/webinar software). These service providers may have access to your Personal Data but may only process it on our instructions and under confidentiality and data protection agreements. Disclosed tools include Cookiebot, Google Analytics, Google Tag Manager, and HubSpot.

Third-party websites and social media providers. The nuwacom Website may contain or embed links to websites or services not owned or controlled by nuwacom. We are not responsible for their privacy practices. Please review the privacy notices of any linked websites or services you visit.

nuwacom partners. We may share your information with partners, for example to co-organize an event. In such cases, we will inform you in advance and identify the receiving party and their intended use.

Advertising agencies. When you visit the nuwacom Website, we may enable third parties to use cookies and similar technologies to show you advertisements on third-party websites. See our Cookie Notice for details and manage your preferences via our Cookie Preferences. Cookiebot is used to obtain and document consent.

nuwacom Group To provide our services efficiently, we may share information within the nuwacom group of entities. We may also disclose or transfer information in connection with corporate transactions (e.g., mergers, reorganizations).

Government authorities or law enforcement. In exceptional circumstances, we may disclose Personal Data to a governmental authority or law enforcement agency when reasonably necessary to (a) comply with applicable law, regulation, legal process, or governmental request; (b) enforce our agreements and policies; (c) protect the security or integrity of our products and services; (d) protect nuwacom, our customers, or the public from harm or illegal activities; or (e) respond to an emergency requiring disclosure to prevent death or serious bodily injury.

How we transfer Personal Data internationally. Subprocessor and partners, or other recipients may be located outside the European Economic Area (EEA) or use servers outside the EEA. Where applicable, we ensure adequate protection through mechanisms such as the European Commission’s Standard Contractual Clauses, adequacy decisions (e.g., EU-US Data Privacy Framework), or other GDPR-compliant transfer tools. Our intra-group data processing also relies on appropriate safeguards.

4. How we store and secure Personal Data

We implement industry-standard technical and organizational measures to protect your Personal Data against unauthorized access, destruction, or modification. This includes encryption (in transit and at rest), strict access controls, confidentiality obligations for authorized staff, and regular security and privacy training for our employees so they understand the measures needed to safeguard your information. We also review our service providers to ensure they meet our stringent requirements, supported by data protection agreements, and all payment information is fully encrypted and handled solely by PCI-certified organizations. Personal Data is retained only as long as necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law, while anonymous or aggregated information may be stored indefinite.

5. Your privacy rights and how to exercise them

Under the GDPR, you have the following rights with respect to your Personal Data:

Right to be informed and access (know whether we process data about you and obtain access to it).
Right to rectification (correct or update Personal Data).
Right to deletion (have your Personal Data erased).
Right to restrict processing.
Right to withdraw consent at any time (for processing based on consent).
Right to object (where processing is based on legitimate interests).
Right to data portability (receive your data in a structured, commonly used, machine-readable format and transmit it to another controller, where technically feasible).
Right to lodge a complaint with a supervisory authority
No automated decision-making with legal or similarly significant effects.

How to exercise your rights.
Please contact us at support@nuwacom.ai. We may ask for additional information to verify your identity. In some cases, we may be unable to fulfill your request due to legal obligations or compelling legitimate interests. If we received your Personal Data from or on behalf of a nuwacom customer (your employer), please contact that customer (the controller) directly to exercise your rights. Controller and contact details are set out in our policy.

6. How to unsubscribe from direct marketing

We want to communicate with you in the ways that you want to hear from us. If you no longer want to receive marketing messages from us, you can click on the appropriate link at the bottom of Our marketing emails. Please allow sufficient time for your preferences to be processed.

If you no longer want to receive delivery notifications from us, you can change Your delivery notification triggers at any time by emailing Us or by clicking on the appropriate link at the bottom of Our emails. Please allow sufficient time for Your preferences to be processed.

7. Contact Us

If you have any questions related to nuwacom privacy, you can contact our Data Protection Officer directly via email at datenschutz@heydata.eu. If you have any further complaints, you can contact with the supervisory authority of the place where you live. For Luxembourg this is the Luxembourg National Commission for Data Protection (Commission nationale pour la protection des données (“CNPD”)).  It can be reached by mail at 15, Boulevard du Jazz, L-4370 Belvaux, Luxembourg, via website at the following address: https://cnpd.public.lu/en/particuliers/faire-valoir/formulaire-plainte.html and by phone at: (+352) 26 10 60 -1.