Privacy Notice

Last Modified: September 28, 2026

Nectir, Inc.

Nectir, Inc. (“Nectir,” “we,” “us,” “our”) takes your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and our information practices, meaning how and why we collect, use, disclose, sell, share, store, and retain your personal information. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a complaint or request.

We collect, use, and are responsible for certain personal information about you. When we offer goods and services to individuals in the European Economic Area (EEA), we are subject to the EU General Data Protection Regulation (EU GDPR), which applies across the entire European Union. For California consumers, we are subject to the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA).

We strive to educate parents and kids about how to appropriately safeguard their privacy when using our Services. We are committed to complying with the Children's Online Privacy Protection Act of 1998 ("COPPA"), which requires us to inform parents and legal guardians (or a school acting on a parent’s or guardian’s behalf) about our information collection and use practices. COPPA also requires that we obtain parental consent (or consent from a school acting on a parent’s behalf) before we allow children under the age of 13 to access and/or use our Services. We urge kids to check with their parents before entering information through our Services, and we recommend that parents discuss with their kids restrictions regarding the online release of personal information to anyone they don't know.

Where you use our services directly, and not through a school, college, or university, we are responsible as a “controller” of personal information for the purposes of the GDPR. Where you use our services through a school, college, or university, we are responsible as a “processor” of personal information for the purposes of the GDPR, and the school, college, or university acts as the “controller”.

1. Key Terms

Our Contact Information: support@nectir.io
Our Data Protection Officer: Maycon Santos Head of Security and Compliance / Data Protection Officer support@nectir.io 548 Market St PMB 358004 San Francisco, California 94104 United States +1 213-302-8364
Personal information: Any information relating to an identified or identifiable individual
Special category personal information: Personal information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs, or trade union membership; genetic and biometric data; and data concerning health, sex life or sexual orientation.
Sensitive Personal Information: Personal information revealing a consumer's social security number, driver's license and passport numbers, account numbers and credentials, precise geolocation, racial or ethnic origin, religious beliefs, or union membership, personal information concerning a consumer's health, sex life, or sexual orientation, contents of a consumer's mail, email and text messages where the business is not the intended recipient, genetic data, biometric information, or citizenship and immigration status
Education Records: Recorded information of any kind that is: (1) directly related to a student; and (2) maintained by an educational agency or institution or by a party acting for the agency or institution
Services: Our website, https://www.nectir.io/, our related software and online services provided on or in connection with our website, and our software and online services provided through or on behalf of a school, college, or university, including the Public Website Embed, which allows an institution to make a Nectir Assistant available to unauthenticated visitors on a public website
Public Website Embed: A feature of the Services that allows a Nectir customer to embed a Nectir assistant on a publicly accessible website for use by visitors without a Nectir account or login.

2. Personal Information We Collect About You

We may collect and use the following personal information, including sensitive personal information, that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household:

Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers): At account creation or other transaction or communication: may include name, phone number, date of birth, email address.
Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, their name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, credit card number, debit card number, or any other financial information: If provided in profile, may include the name of your college or university (name, city, state), graduation year, photo, and social media handle(s), mailing address and other contact information. If a user enrolls for the Services using a Student Account, we may request additional pieces of personal information to verify your eligibility for the Services, such as by verifying your enrollment status in a college or university. Payment information may be collected if you pay for a service.
Account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account: Login information may be collected at account creation. Payment information may be collected if you pay for a service.
Commercial information (e.g., products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies): Information concerning products/services purchased may be collected at time of purchase or use.
Internet or other electronic network activity information (e.g., information regarding a consumer’s interaction with an internet website, application, or advertisement): Information concerning your use of the Services may be collected at that time
Geolocation data: Precise information is not collected, but approximate information may be ascertainable by analyzing other information, such as your IP address
Professional or employment-related information: May be collected if you are an instructor or staff member at a school, college, or university using the Services
Education records, as defined in the Family Educational Rights and Privacy Act (FERPA): May be collected and used when provided by a school, college, or university, when provided by an instructor or staff member of a school, college, or university, or when you use the Services
Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes: May be automatically correlated as part of the Services
Racial or ethnic origin, religious or philosophical beliefs, union membership, or citizenship or immigration status: May be incidentally collected when you use the Services
Health information: May be incidentally collected when you use the Services
Sex life or sexual orientation: May be incidentally collected when you use the Services
Information obtained from Public Website Embed data, including chat messages and assistant responses, a customer- and domain-scoped pseudonymous visitor identifier stored in browser local storage, the source website domain, and basic usage information (but not name or email unless voluntarily provided): May be incidentally collected when you use the Services

If you do not provide personal information required to provide the Services to you, it may delay or prevent us from providing the Services to you.

If you are under the age of 13, please do not send any personal information to us if we have not obtained prior consent from your parent, guardian, or school. If we learn we have collected Personal Information from a User under the age of 13 without parental consent, or if we learn a user under the age of 13 has provided us personal information beyond what we request from them, we will delete that information as quickly as possible. If you believe that a user under the age of 13 may have provided us Personal Information in violation of this Privacy Policy, please contact us at support@nectir.io.

3. How Your Personal Information is Collected

We collect personal information from the following categories of sources:

You, directly through the website or Services, or when you contact us by email, telephone, or another communication channel
An applicable school, college, university, instructor, administrator, or other customer
Identity providers, learning management systems, and other integrations selected by you or your institution
Service providers that support hosting, security, analytics, communications, and delivery of the Services
Cookies, browser local storage, and similar technologies
Our IT, logging, monitoring, and security systems
Publicly available sources and business contact records, where permitted by law

4. Cookies

We, and our partners, use cookies and similar technologies to give you the best possible content and experience. Cookies are used to remember you and to collect information about how you interact with the Services. If you have an account with the Services, we may link this usage data with other information. You may have the option to either accept or refuse these cookies. If you choose to refuse, you may not be able to use some portions of the Services. The Public Website Embed uses browser local storage for a customer- and domain-scoped pseudonymous visitor identifier so a returning visitor can access conversation history. This identifier is not reused across customers or used for advertising.

5. Third Party Data Collection

Third parties may collect or receive limited information as needed to provide hosting, security, analytics, authentication, communications, customer support, or website functionality. The providers used depend on the feature and customer configuration and may include:

Google Cloud, Azure (hosting and AI processing)
Cloudflare (content delivery and security)
PostHog (analytics and error monitoring)
HubSpot, Resend (communications, marketing, and customer support)
Webflow (website and scheduling functionality)

Nectir does not allow third parties to collect information through the Services for targeted advertising. We adhere to the Self-Regulatory Principles for Online Behavioral Advertising.

6. How and Why We Use Your Personal Information

Under data protection laws, we can only use your personal information if we have a proper reason for doing so, for example:

For the purpose of providing the Services
To comply with our legal and regulatory obligations
For the performance of our contract with you or to take steps at your request before entering into a contract
For our legitimate interests or those of a third party –or–
Where you have given consent

A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests.

The table below explains what we use (process) your personal information for and our reasons for doing so:

What we use your personal information for / Our reasons

To provide the Services to you: For the performance of the Services for you or to take steps at your request before entering into a contract
To prevent and detect fraud against you or an educational institution: For our legitimate interests or those of a third party, i.e., to minimize fraud that could be damaging for us and for you
Gathering and providing information required for audits, inquiries, or investigations by auditors or regulatory bodies: To comply with legal, regulatory, and contractual obligations
Ensuring business policies are adhered to, e.g., policies covering security and internet use: For our legitimate interests or those of a third party, i.e., to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control: For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Ensuring the confidentiality of commercially sensitive information: For our legitimate interests or those of a third party, i.e., to protect trade secrets and other commercially valuable information To comply with our legal and regulatory obligations
Statistical analysis to help us manage our business: For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service for you at the best price
Preventing unauthorized access and modifications to systems: For our legitimate interests or those of a third party, i.e., to prevent and detect criminal activity that could be damaging for us and for you To comply with our legal and regulatory obligations
Updating and enhancing customer records: For the performance of our contract with you or to take steps at your request before entering into a contract To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., making sure that we can keep in touch with our customers about existing orders and new products
Ensuring safe working practices, staff administration and assessments: To comply with our legal and regulatory obligations For our legitimate interests or those of a third party, e.g., to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing Nectir's services to existing customers and people who have expressed interest in our services: Consent or legitimate interests where permitted by law, with the ability to opt out
External audits, independent assessments, and quality checks, including SOC 2 and accessibility reviews: For our legitimate interests in maintaining independent assurance and to comply with legal, regulatory, and contractual obligations

For EEA Data Subjects: Nectir does not intentionally request special-category personal information. Where such information is voluntarily included in user content and Nectir acts as a processor, Nectir processes it under the applicable customer's documented instructions and legal basis.

7. EEA Data Subjects: Promotional Communications

We may use business contact information to send email updates about Nectir products and services.

We rely on consent or legitimate interests where permitted by law. Where consent is required, we request it separately and clearly.

We do not sell personal information and do not use Education Records or Public Website Embed chat content for marketing.

You may opt out of promotional communications at any time by:

Contacting us at support@nectir.io
Using the “unsubscribe” link in a promotional email

Even if you opt out of promotional communications, you may still receive service-related or security communications. We may ask you to confirm or update your marketing preferences if you instruct us to provide further products or services in the future, or if there are changes in the law, regulation, or the structure of our business.

8. Who We Share Your Personal Information With

We routinely share personal information with:

Schools, colleges, universities, customer administrators, instructors, and other authorized users, according to applicable roles, permissions, and customer instructions
Approved service providers and subprocessors that host, secure, monitor, analyze, support, or otherwise help deliver the Services
Professional advisers, auditors, insurers, and other parties that support legal, compliance, security, and business operations
Identity providers, learning management systems, and other integrations selected by you or your institution

We only allow our service providers to handle your personal information if we are satisfied they take appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure they can only use your personal information to provide services to us and to you. We may also share personal information with external auditors.

We may disclose and exchange information with law enforcement agencies and regulatory bodies to comply with our legal and regulatory obligations.

We may also need to share some personal information with other parties, such as potential buyers of some or all of our business or during a re-structuring. We will typically anonymize information, but this may not always be possible. The recipient of the information will be bound by confidentiality obligations.

We do not disclose personal information except as described in this Privacy Policy, as directed by an applicable customer, or with appropriate authorization.

9. Personal Information We Sold or Shared

In the preceding 12 months, the limited categories that may have been shared are:

Identifiers and online identifiers, such as cookie identifiers and IP addresses
Internet or other electronic network activity information, such as interactions with the public marketing website

10. Categories of Personal Information We Disclosed for a Business Purpose

In the preceding 12 months, Nectir disclosed the following categories of personal information:

Identifiers and contact information, including names, email addresses, account identifiers, online identifiers, and IP addresses
Account, profile, institutional, commercial, and customer relationship information
User content and communications, including chat messages, assistant responses, support requests, and education records where applicable
Internet or other electronic network activity information and security logs
Approximate geolocation information
Professional, employment, and education information
Sensitive personal information voluntarily included in user content

11. How Long Your Personal Information Will Be Kept

We will keep your personal information while you have an account with us or while we are providing the Services to you. Thereafter, we will keep your personal information for as long as is necessary:

To respond to any questions, complaints or claims made by you or on your behalf
To show that we treated you fairly –or–
To keep records required by law

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information. Public Website Embed transcripts are retained for 30 days by default, unless a different period is required by contract or law. Visitors can delete conversation history associated with their browser visitor identifier through the available delete-history function.

When it is no longer necessary to retain personal information for any permitted reason, we will delete or anonymize it in accordance with our retention practices and applicable law and obligations.

12. California Consumers: Your Rights Under the CCPA/CPRA

You have the right under the California Consumer Privacy Act of 2018 (CCPA), as amended by the California Privacy Rights Act of 2020 (CPRA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

Disclosure of Personal Information We Collect About You

You have the right to know, and request disclosure of:

The categories of personal information we have collected about you, including sensitive personal information
The categories of sources from which the personal information is collected
The categories of third parties to whom we disclose personal information, if any –and–
The specific pieces of personal information we have collected about you

Please note that we are not required to:

Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained
Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information –or–
Provide the personal information to you more than twice in a 12-month period

Disclosure of Personal Information Sold, Shared, or Disclosed for a Business Purpose

In connection with any personal information we may sell, share, or disclose to a third party for a business purpose, you have the right to know:

The categories of personal information about you that we sold or shared and the categories of third parties to whom the personal information was sold or shared –and–
The categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom the personal information was disclosed for a business purpose

You have the right to opt-out of the sale of your personal information or sharing of your personal information for the purpose of targeted behavioral advertising. If you exercise your right to opt-out of the sale or sharing of your personal information, we will refrain from selling or sharing your personal information, unless you subsequently provide express authorization for the sale or sharing of your personal information.

To opt-out of the sale or sharing of your personal information, email support@nectir.io

Right to Limit Use of Sensitive Personal Information

You have the right to limit the use and disclosure of your sensitive personal information to the use which is necessary to:

Perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services
To perform the following services: (1) Helping to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for these purposes; (2) Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of a consumer's current interaction with the business, if the consumer's personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer's experience outside the current interaction with the business; (3) Performing services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business; and (4) Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business –and–
As authorized by further regulations

You have a right to know if your sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes.

To limit the use of your sensitive personal information, email support@nectir.io

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

Delete your personal information from our records –and–
Delete your personal information from our records –and–
Direct third parties to whom the business has sold or shared your personal information to delete your personal information unless this proves impossible or involves disproportionate effort

Please note that we may not delete your personal information if it is reasonably necessary to:

Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us
Help to ensure security and integrity to the extent the use of the consumer's personal information is reasonably necessary and proportionate for those purposes
Debug to identify and repair errors that impair existing intended functionality
Exercise free speech, ensure the right of another consumer to exercise their right of free speech, or exercise another right provided for by law
Comply with the California Electronic Communications Privacy Act
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent
Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us
Comply with an existing legal obligation –or–
Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information

Right of Correction

If we maintain inaccurate personal information about you, you have the right to request us to correct that inaccurate personal information. Upon receipt of a verifiable request from you, we will use commercially reasonable efforts to correct the inaccurate personal information.

Protection Against Retaliation

You have the right to not be retaliated against by us because you exercised any of your rights under the CCPA/CPRA. This means we cannot, among other things:

Deny goods or services to you
Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties
Provide a different level or quality of goods or services to you –or–
Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or services to you, if that difference is reasonably related to the value provided to our business by your personal information. We may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with these rights or payments as compensation, for the collection of personal information, the sale of personal information, or the retention of personal information.

13. EEA Data Subjects: Your Rights Under the EU GDPR

Right to Be Informed: The right to know or be notified about the collection and use of your personal information
Right to Access: The right to be provided with a copy of your personal information (the right of access)
Right to Rectification: The right to require us to correct any mistakes in your personal information
Right to be Forgotten: The right to require us to delete your personal information—in certain situations
Right to Restriction of Processing: The right to require us to restrict processing of your personal information—in certain circumstances, e.g., if you contest the accuracy of the data
Right to Data Portability: The right to receive the personal information you provided to us, in a structured, commonly used, and machine-readable format and/or transmit that data to a third party—in certain situations
Right to Object: The right to object:At any time to your personal information being processed for direct marketing (including profiling)In certain other situations to our continued processing of your personal information, e.g., processing carried out for our legitimate interests
Right Not to be Subject to Automated Individual Decision-Making: The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you

For further information on each of those rights, including the circumstances in which they apply, see the guidance from the UK Information Commissioner's Office (ICO) on individual rights under the EU General Data Protection Regulation.

14. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please email support@nectir.io

Public Website Embed visitors can use the delete-history function to delete conversations associated with the browser visitor identifier without creating an account.

Please note that you may only make a CCPA/CPRA-related data access or data portability disclosure request twice within a 12-month period.
If you choose to contact us directly you will need to provide us with:
Enough information to identify you (e.g., your full name or email address)
Additional information reasonably necessary to verify your identity and authority to make the request. The information requested will depend on the nature of the request; we do not require government identification unless reasonably necessary.
A description of what right you want to exercise and the information to which your request relates
We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person's behalf.
Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

15. EEA Data Subjects: Where Your Personal Information is Held

Information is stored in the United States, primarily through Google Cloud Platform in the us-west1 (Oregon) region. Information may also be processed by approved service providers supporting cloud infrastructure, security, analytics, monitoring, communications, and AI services, including Microsoft Azure. Google LLC and Microsoft Corporation participate in the EU–U.S. Data Privacy Framework. For transfers of personal information from the EEA to the United States or other countries outside the EEA, Nectir relies on the EU–U.S. Data Privacy Framework where applicable, the European Commission’s Standard Contractual Clauses, or another lawful transfer mechanism.

Some of these third parties may be based outside the EEA. For more information, including on how we safeguard your personal information when this occurs, see below: “Transferring Your Personal Information Out of the EEA.”

16. EEA Data Subjects: Transferring Your Personal Information Out of the EEA

To deliver services to you, it is sometimes necessary for us to share your personal information outside the EEA, e.g.:

With our offices outside the EEA
With your and our service providers located outside the EEA
If you are based outside the EEA –or–
Where there is an international dimension to the services we are providing to you

These transfers are subject to special rules under European and UK data protection law.

Non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. We will, however, ensure the transfer complies with data protection law and all personal information will be secure. Our standard practice is to use standard data protection contract clauses that have been approved by the European Commission.

If you would like further information, please contact our Data Protection Officer (see “How To Contact Us” below).

17. Keeping Your Personal Information Secure

We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We maintain a security program that includes independent SOC 2 Type II audits and periodic security testing. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Our safeguards include encryption in transit and at rest, role-based access controls, multi-factor authentication, vulnerability management, logging and monitoring, incident-response procedures, and contractual confidentiality obligations.

18. EEA Data Subjects: How to File a GDPR Complaint

We hope that our Data Protection Officer can resolve any query or concern you raise about our use of your information.

The GDPR also gives you the right to lodge a complaint with a supervisory authority, in the European Union (or EEA) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

19. Changes to This Privacy Notice

This privacy notice was published on September 28, 2026 and last updated on September 28, 2026.

We may change this privacy notice from time to time–when we do, we will provide notice via our website or other means of contact such as email.

20. How to Contact Us

Please contact us and/or our Data Protection Officer by post, email, or telephone if you have any questions about this privacy policy or the information we hold about you.

Our contact details are shown below

Our contact details: Nectir, Inc. 548 Market St PMB 358004 San Francisco, California 94104 United States support@nectir.io +1 213-302-8364
Data Protection Officer contact details: Maycon Santos Head of Security and Compliance / Data Protection Officer Nectir, Inc. 548 Market St PMB 358004 San Francisco, California 94104 United States support@nectir.io +1 213-302-8364