IANOVA Privacy Policy

1. Controller

2. Scope and roles

This Policy applies to the Nuborix website, the IANOVA web application, and the IANOVA applications for macOS, Windows, Android, iPhone and iPad.

• Nuborix as controller: for the subscriber's account, company, subscription and use of the Service.
• Nuborix as processor: for the personal data of third parties — the subscriber's own customers — entered into IANOVA by the subscriber.

3. Data we process

3.1 Account and company

• User and business name; email address; phone number; RNC or national ID; business type and contracted plan.
• Password, stored only as an irreversible cryptographic digest. Nuborix does not know and cannot recover your password.
• Two-step verification (TOTP) secret, stored encrypted; and recovery codes stored in non-reversible form.

3.2 Usage, access and security

• IP address, access date and time, and browser or application user agent.
• Session identifiers and authentication events, including failed attempts and temporary lockouts.
• Record of acceptance of the legal documents: document identifier and version, date and time in UTC, source IP address and user agent (the latter truncated to 256 characters).
• Activity records for certain administrative and messaging operations.

3.3 Business content

• Customers, products, inventory, invoices, quotes, receipts and orders created by the subscriber.
• Product images uploaded by the subscriber.
• Tax and commercial configuration of the company.

3.4 Communications

• Messages in the internal messaging system and administrative notices.
• Transactional system emails, limited to: trial start, plan activation, password setup and temporary password. These emails do not include the subscriber's customer data.

4. Purposes of processing

• Create, maintain, authenticate and administer the account.
• Provide the contracted functionality and enable issuing and managing documents.
• Manage the subscription and verify the plan's validity.
• Protect the Service: prevent unauthorised access, fraud and abuse, and apply usage limits.
• Provide technical support when the subscriber requests it.
• Send operational communications and notices about the service, the subscription and legal changes.
• Comply with legal, accounting and tax obligations, and respond to requests from competent authorities.
• Retain evidence of acceptance of the legal documents.
• Diagnose faults and improve the Service, using the minimum data necessary.

Nuborix does not sell or transfer personal data for advertising purposes, and does not carry out commercial profiling with the subscriber's business content.

5. Lawful basis

• Performance of the contract: providing the Service and managing the relationship.
• Consent: given freely, expressly and on an informed basis when accepting the legal documents during registration.
• Compliance with legal obligations: accounting retention and responding to requests.
• Legitimate interest: information security, fraud prevention and defence of rights, balanced against the data subject's rights.

6. Nuborix access to information

Nuborix does not routinely consult or use the commercial content stored by subscribers in IANOVA. IANOVA automatically processes only the data necessary to operate, synchronise, protect and back up the service. Each subscriber's data remains isolated from that of others.

6.1 What is implemented and verified

• Isolation between subscribers: every business query and mutation derives the company from the authenticated session; an identifier sent by the client does not change the effective company. Verified through negative tests across two companies.
• Role-based permissions: distinct administrative roles exist, and administrative accounts are required to use two-step verification.
• Activity logging: certain administrative operations are recorded: password resets, notice creation, product changes and messaging operations.

6.2 Nuborix staff access to business content

That access is used only on an exceptional basis to handle requested support, investigate a security incident, maintain the service or comply with a legal obligation.

7. Subscriber's customer data

When the subscriber records data about its own customers in IANOVA — name, RNC or national ID, phone, address, email:

• The subscriber is the controller of that processing and warrants that it has authorisation or a lawful basis for it.
• Nuborix acts as processor and processes that data solely to provide the Service, following the subscriber's documented instructions.
• Nuborix does not use that data for its own purposes or transfer it to third parties outside the provision of the Service.
• It is for the subscriber to inform its customers and to handle rights requests they address to it. Nuborix will provide reasonable assistance.

8. Providers and international transfers

Providers confirmed by inspection of the system configuration:

Processing region and sub-processors: Cloudflare's and Resend's infrastructure operates through internationally distributed servers. Nuborix does not contract an exclusive region, and each provider publishes its own list of sub-processors in its documentation.

Contractual safeguards: Nuborix relies on the data protection and security commitments each provider assumes in its terms of service. Signing specific processing agreements with each provider is in progress.

These providers' infrastructure operates through internationally distributed servers, so data may be stored or processed outside the Dominican Republic. By accepting this Policy, the subscriber consents to that international transfer, which is necessary to perform the contract.

9. Retention periods

9.1 Four distinct situations

• Immediate deletion: the data is removed from the active database at once.
• Legal blocking: the data stops being used but is retained because a legal obligation or the defence of a claim requires it. It is restricted, not available for ordinary use.
• Persistence in backups: data deleted from the active database may still exist in backups until they are rotated. Backups are not used for ordinary operation.
• Definitive erasure: the data disappears from the active database and from current backups once the rotation cycle completes.

10. Storage on your device

IANOVA uses only strictly necessary mechanisms. No advertising, third-party tracking or profiling cookies are used. The applications contain no advertising or third-party analytics SDKs.

10.1 What remains and why

• What remains: the local database continues to exist after sign-out, with its session contents and queue emptied, and retains a device identifier.
• Why: the device identifier allows the device to be recognised at the next offline activation and avoids duplicating authorisations.
• How it is protected: it resides in the browser or application storage, subject to operating system and user profile isolation. Additional protection of the local store via the system keychain (Keychain/Keystore) is identified as pending in the internal audit.
• How you can delete it: on the web, by clearing the site's data in your browser; in the applications, by clearing the app's data or uninstalling it.
• On uninstall: the application's local storage is removed according to the behaviour of the relevant operating system.

10.2 Several users on the same device

Local storage is per browser or per application installation, not per IANOVA user. If several people share the same browser profile or the same operating system user, they must sign out when finished. Signing out empties the session data and the local queue. For complete separation, use separate browser profiles or system accounts.

11. Security measures

Only controls verified in the system are described:

• Encryption in transit: HTTPS with HSTS.
• Passwords: PBKDF2-SHA256 with a random per-credential salt, at the maximum iteration count the execution platform allows. Never stored in clear text.
• Two-step verification: mandatory for administrative roles; the TOTP secret is stored encrypted with AES-GCM.
• Sessions: HttpOnly cookie, Secure over HTTPS and SameSite=Lax, with revocation on critical changes.
• Company isolation: derived from the authenticated session, not from client-supplied values.
• Role-based access control: distinct administrative roles.
• Activity logging: for certain administrative and messaging operations (see section 6).
• Abuse protection: per-IP request limiting on sign-in, registration, password setup, two-step verification, administrative email and internal tasks; temporary account lockout after failed attempts; and generic sign-in messages to prevent user enumeration.
• Browser protection: content security policy, headers against framing, MIME sniffing and referrer leakage; size and type limits on file uploads.
• Backups: a full copy of the database is made before every significant platform change, and the infrastructure provider also allows restoring the database to an earlier point in time. The copy made before each change does not follow a fixed schedule: it is made with every change. A daily encrypted backup with a weekly restoration test is being put in place, not yet operational. No backup automation exists within the application: the process is operational.
• Encryption at rest: a property of the contracted infrastructure platform. It is a property of the contracted platform, not a control implemented by Nuborix in the application code.
• Incident procedure: described in section 15. Its documentary formalisation is in progress.

12. Data subject rights

Under Law 172-13, the data subject may exercise the rights of access, rectification, updating, objection and deletion, and may withdraw consent given.

12.1 How to submit a request

Send it to [email protected] stating at least:

• the data subject's full name and contact details for the reply;
• the right being exercised and a clear description of the request;
• information that allows the data to be located, where applicable;
• the identity evidence described below.

12.2 Proportionate identity verification

Verification will be proportionate to the risk of the request. Ordinarily it is enough to demonstrate control of the email address registered to the account. A full copy of an identity document is not required by default. Enhanced evidence will be requested only where the request carries elevated risk — for example, deletion of information or a change of contact details — or where there is well-founded doubt as to identity; in that case, the least intrusive sufficient means will be requested.

12.3 Notification to recipients

Where rectified or deleted data has been communicated to third parties, Nuborix will pass on the correction where appropriate and materially possible.

12.4 Limits and exceptions

Exercise may be limited, with reasons given, where there is:

• a tax or accounting retention obligation falling on the subscriber or on Nuborix;
• performance of a current contract;
• prevention, detection or investigation of fraud or security incidents;
• defence of claims or compliance with a request from a competent authority.

In such cases the data may be blocked rather than deleted, in accordance with section 9.1.

12.5 Exportable copy

Law 172-13 does not expressly recognise a general right to data portability. Independently of that, IANOVA may provide the subscriber with an exportable copy of certain data as an additional service, where technically and legally possible. There is currently no automated export function: requests are handled manually through the privacy channel.

12.6 If you are a customer of a business that uses IANOVA

Please contact that business, which is the controller. Nuborix, as processor, will forward the request to the relevant subscriber.

13. Complaints

1. Direct request to Nuborix. Write to [email protected], which is the privacy channel. This is the first step and resolves most cases.
2. Response deadlines. Five (5) business days for access; ten (10) business days for rectification, updating or deletion.
3. Habeas data action. If your request is not addressed or the response is unsatisfactory, Law 172-13 allows you to bring a habeas data action before the competent court of the Dominican Republic, to know, update, rectify or delete your data.
4. Pro Consumidor. Where there is a consumer relationship or an adhesion contract, the National Institute for the Protection of Consumer Rights (Pro Consumidor) may intervene within its consumer protection remit.

14. Minors

14.1 IANOVA accounts

IANOVA is intended for businesses and professionals. It is not directed at persons under eighteen (18) and Nuborix does not knowingly collect minors' data for account creation. If an account created by a minor without the relevant authorisation is detected, it will be deleted.

14.2 Minors recorded as customers by a subscriber

A subscriber may need to record a minor's data as a customer of its business. In that case the subscriber is the controller and must hold the authorisation of parents or guardians, or another lawful basis, under Law 172-13.

14.3 Subscriber responsibility

Nuborix, as processor, does not verify the age of the customers a subscriber records, nor does it replace the authorisations the subscriber must obtain. It is for the subscriber to obtain and retain them.

Any matter concerning minors' data may be reported to [email protected].

15. Security incidents

If a security breach affecting personal data occurs and poses a risk to data subjects, Nuborix will notify the affected subscribers without undue delay and, where appropriate, the competent authority or court, describing the nature of the incident, the categories of data affected, the measures taken and the applicable recommendations.

Where Nuborix acts as processor, it will notify the controlling subscriber so that the subscriber can meet its own notification obligations.

16. Automated decisions

Nuborix does not take decisions producing legal effects on the data subject based solely on automated processing, nor does it build profiles for that purpose. The existing automatic controls — request limits, temporary lockout after failed attempts and plan validity checks — are technical in nature and reversible by contacting support.

17. Languages and versions

This Policy is published in full in Spanish and in English, with the same numbering, scope and meaning.

Unless a legal decision establishes otherwise, in the event of any discrepancy between versions the Spanish version prevails. Legal names of persons and entities are not translated.

18. Changes and acceptance

The version in force is always published at this address, identified by version number and date. Previous versions are archived: version 1.0.

18.1 Acceptance record

Nuborix keeps an electronic record of each acceptance with: identifier and version of the accepted document, date and time in UTC, source IP address and truncated user agent. Each acceptance is bound to the specific version accepted; an acceptance of version 1.0 is not reassigned to or converted into an acceptance of version 1.1.

18.2 Minimisation of the evidence

The IP address and user agent are recorded for the sole purpose of evidencing acceptance. The user agent is truncated. Their retention period is the one stated in section 9 for legal acceptance records.

18.3 Renewed acceptance

Version 1.1 introduces substantial changes compared with version 1.0 — among them the statement on staff access, the deadlines for exercising rights, the retention table and the detail of local storage — and therefore requires a fresh, express acceptance. Minor or drafting changes will not, and will be communicated through the Service or by email with reasonable notice.