Privacy Policy
Last updated: 19 October 2026
This policy explains how NexaEthos handles personal data when you use the Nexa Agora app for iPhone. It is written to be read: where a legal term is needed, it is explained.
1. Who we are
NexaEthos S.L. ("NexaEthos", "we", "us") is a limited company incorporated in Spain, tax identification number B93751808, with its registered office at Calle Santa Juliana 9, 29130 Alhaurín de la Torre (Málaga), Spain. We develop and operate Nexa Agora.
- Privacy contact, for any question about this policy and to exercise your rights: privacy@nexaethos.com
- App support: support@nexaethos.com
- General contact: hello@nexaethos.com
We have not appointed a Data Protection Officer: the law does not require one for our activities. The privacy contact above handles every data-protection matter.
2. Our two roles
Data-protection law distinguishes the controller, who decides why and how personal data is used, from the processor, who handles it on the controller's behalf and on its instructions. We are both, for different data.
- We are the controller of your account, your sign-in and security records, your devices and sessions, your choices on the App Terms and on AI sharing, your support requests, and the logs and diagnostics of our service.
- Your organisation is the controller of the content of its workspace: messages and discussions, conversations with agents and your Buddy, documents and files, notes and tasks, and the requests sent to AI models and their answers. We process that content on your organisation's behalf, under its agreement with us. Your organisation's own privacy information tells you what it does with that content, and requests about it go to your organisation. If you write to us about it, we pass your request on and help your organisation answer it.
3. The personal data the app processes
Account. Your name, email address and username, your password (stored only as a one-way hash, never readable), your profile details, your language, your two-factor settings, the workspaces you belong to and your role in each.
Content you create. What you write, post, upload, dictate or capture in the app: chat messages to your Buddy and agents, Agora messages and reactions, documents, photos and files, notes and tasks, and your answers to agents' questions. Content may contain personal data about you or about other people.
AI processing. When you use an AI feature, your request, the relevant part of the conversation, attachments and the results of the tools an agent uses are sent to AI services (section 5). For each AI turn, the service keeps a technical trace: the request sent to the model, its answer, the tools it called, timings and the amount of text processed. For each person and day, the service also counts usage: tokens, tools, voice and credits, with no content.
Voice. When you dictate, your recording is sent to a speech service and turned into text; when you choose to listen, the text is sent to a speech service and turned into audio. Our service does not store the recording: it is processed in memory and discarded. The audio of an answer read aloud is saved in the app's cache on your iPhone so that it can be played.
Camera, microphone, photos and notifications. The app asks for the camera only when you take a photo in the app, for the microphone only when you dictate, and for notifications only if you want them. When you choose photos, the app receives only the photos you pick. The app does not ask for your location or your contacts. You can withdraw any permission at any time in your iPhone's Settings.
Push notifications. If you turn on notifications or let your iPhone answer sign-ins, the app registers a push token for your iPhone with our service. A notification names the event, the sender and the room; the item's title and a short excerpt appear only if your workspace turned that on (it is off by default).
Devices and sessions. For each sign-in session: a label for the device, its platform and, where you allowed notifications, its push token. Your sign-in register: the time and outcome of each sign-in or attempt, the IP address and the app or browser identifier. Requests to approve a sign-in on your phone, with the requesting device's IP address, identifier and platform. On your iPhone, your sign-in is kept in the iPhone's secure storage, and, if you use this iPhone as your authenticator, so is its authenticator.
Your choices. Each time you accept the App Terms or allow, refuse or withdraw AI sharing, we record the choice, the version of the text you saw, the platform and the time.
Reports. If you report a message or an AI answer, we process your reason, the reported content, the name of its author (for an Agora message) or the agent (for an AI answer), your identity, your workspace and the time. If someone reports a message you wrote, the same applies to your message and your name.
Support. What you write to us, from the app or by email, and our replies.
Activity records. Each workspace keeps an audit log of who did what and when, including what an agent did on a person's behalf.
Diagnostics. Application logs and error records of our service.
We do not ask for special categories of data (such as data about health, religious or political beliefs, or biometric data used to identify a person).
4. Why we use personal data, and on what legal basis
| Purpose | Legal basis (Article 6(1) GDPR) |
|---|---|
| Create and run your account, sign you in, keep your settings, send the notifications you turned on | Performance of the contract with you (b) |
| Provide the workspace's features in the app — chat, Agora, Library, Desk, dictation and read-aloud — for your organisation | We act as processor; the legal basis is your organisation's. In the app, AI features also need your permission (section 5) |
| Keep accounts and the service secure: sign-in register, approvals on your phone, sessions, audit log, investigation of incidents | Our legitimate interest in the security of the service and of your account (f), which is also a duty of every controller (Article 32 GDPR) |
| Record your choices on the App Terms and on AI sharing, to show what you chose and when | For AI sharing, our legal obligation to be able to demonstrate your consent, Article 7(1) GDPR (c); for the App Terms, performance of the contract (b) |
| Handle reports of messages and AI answers, and act on them | Our legitimate interest in a safe service free of objectionable content (f) |
| Answer your support requests | Performance of the contract (b) and our legitimate interest in answering you (f) |
| Find and fix faults, keep the service reliable: logs, error records, AI turn traces | Our legitimate interest in a working, reliable service (f) |
| Count usage per person and day | Performance of the contract (b) |
| Prove that a deletion was carried out | Our legal obligation to demonstrate that we complied with an erasure, Articles 5(2) and 17 GDPR (c) |
| Establish, exercise or defend legal claims | Our legitimate interest (f) |
Where we rely on our legitimate interests, you may object (section 10).
We do not sell personal data, use it for advertising or add you to marketing lists. We do not use your content to train AI models.
5. Artificial intelligence in the app, and your permission
Before the app sends your content to AI services, it asks your permission on a screen that shows the full text, the companies that may receive your content and your recorded choice. The app asks for it when you use:
- a chat with your Buddy or an agent;
- posting a message in Agora;
- dictation and read-aloud;
- uploading a document, photo or file, which is read, indexed for search and catalogued by an AI model;
- handing a Desk task to an agent, answering an agent's question, or confirming an agent's assumptions.
If you do not allow it, these features do not work in the app; the rest of the app keeps working. You can change your choice at any time in Account → Privacy and AI sharing → Review AI sharing permission. Withdrawing stops sharing from the app from your next request; work already started can finish. Withdrawing does not delete content already processed: to delete it, see section 10. If the text changes, the app asks you again.
Your choice applies to the app only. It does not change Nexa Agora on the web, where your workspace's AI features keep working as your organisation set them up. Content already in your workspace stays there and can still be used by your workspace's AI features.
Every model in Nexa Agora carries a label stating where it is processed: in the EU, or globally. By default the platform uses globally processed models, so a request may be processed outside the European Union and the European Economic Area (EU/EEA). Your workspace can choose models labelled as processed in the EU.
Your workspace can also add models with its own key for another AI provider, or connect its own models through Nexa Bridge. Those models are chosen by your organisation and used under its own agreement with that provider: for them, your organisation and that provider, not NexaEthos, decide how your data is handled.
Agents' messages are marked as produced by AI. AI can be wrong: check important output before relying on it. No decision producing legal effects on you, or affecting you in a similarly significant way, is taken by automated means alone (Article 22 GDPR).
6. Who receives personal data
6.1 The providers that help us run the service
These providers act as our processors, under contracts that bind them to protect the data and use it only to provide their service. We do not name them here; their names are in the sub-processor list that is part of our Data Processing Agreement with customers. In the app, the AI sharing screen lists the companies that may receive your workspace's content for AI processing.
| Category | What they do | Data they receive | Where |
|---|---|---|---|
| Hosting and infrastructure | Run the service: servers, databases, file storage, backups | All data held in the service | Inside the EU/EEA |
| Disaster recovery | Keep a standby copy of the service | All data held in the service | Inside the EU/EEA |
| AI model providers | Run the AI models that carry out requests | Requests, conversation context, attachments, tool results | Inside or outside the EU/EEA, depending on the model (section 5) |
| AI search and document reading | Turn text into searchable form, rank results, read the text of documents and scans | Extracts of text, search queries, document contents | Inside the EU/EEA |
| Speech | Transcribe dictation and read answers aloud | Recordings, transcripts, text to be spoken | Inside the EU/EEA |
| Send service emails; host our own mailboxes, including support | Email addresses, names, message content | Inside the EU/EEA | |
| Web search | Run the web searches agents make | The search words | Outside the EU/EEA |
| Mobile notifications | Deliver notifications to your iPhone | Push token and the notification (section 3) | Outside the EU/EEA |
| Domain name and network services | Answer for our domain names and, where enabled, protect and deliver traffic | Technical connection data, such as IP addresses | Global network, inside and outside the EU/EEA |
Some of our providers inside the EU/EEA belong to groups headquartered outside it.
6.2 Inside your workspace
The other members of your workspace see what you share there, as the workspace's settings allow. Its administrators manage memberships and roles. They receive the Agora reports their members send, with the reason and the reported message, even for rooms they are not in, and they can delete a reported message. Administrators can download a copy of what a member shared with the workspace — never that member's private conversations, private documents or memories. Support requests sent from the app are listed for your workspace.
6.3 Others
We disclose personal data to public authorities or courts when the law requires it, and to our professional advisers (such as lawyers and accountants), who are bound by confidentiality, when needed for the purposes above.
7. Transfers outside the EU/EEA
The service is hosted inside the EU/EEA. Some processing takes place outside it: AI model processing with globally processed models (the default), web search, mobile notifications, and domain name and network services.
Where personal data is transferred outside the EU/EEA, we rely on the Standard Contractual Clauses adopted by the European Commission and, where the recipient is certified under it, on the EU-US Data Privacy Framework. You can ask for a copy of the safeguards by writing to privacy@nexaethos.com.
8. How long we keep personal data
| Data | How long |
|---|---|
| Account and profile | As long as the account exists; erased when the account is deleted |
| Your choices on the App Terms and AI sharing | As long as the account exists; erased when the account is deleted |
| Conversations with your Buddy and agents | No fixed expiry: deleted when you delete your account or when the workspace is deleted |
| Agora messages | For the life of the workspace. When you delete your account, your messages stay, signed "Deleted user", because they are part of your colleagues' conversations. The text of a message its author deleted is cleared 30 days after the deletion |
| Documents and files | As long as your account and the workspace exist. A deleted document stays 30 days in the bin, where it can be restored, and is then deleted |
| Voice | Recordings are not stored by our service. The audio of an answer read aloud stays in the app's cache on your iPhone |
| Technical traces of AI turns | 180 days. They will also be deleted as soon as your account or the workspace is deleted |
| Usage counts (per person and day, no content) | Will be kept 13 months. When your account is deleted, the link to you will be removed and the count will stay with the workspace as "unattributed" |
| Web search cache (the words searched) | Will be kept at most one day |
| Sign-in sessions and devices, including the push token | 30 days after the session ends; erased when the account is deleted |
| Requests to approve a sign-in on your phone, and used sign-in steps | 30 days after they expire |
| Sign-in register | 365 days |
| Workspace audit log | 365 days; the record of a former member's past actions stays until its 365 days run out |
| Report cards in administrators' inboxes | Until handled; deleted 30 days after an administrator marks them done or dismisses them |
| Support requests sent from the app | Will be deleted with the workspace; a closed request will be deleted 24 months after it was closed |
| Emails to our support mailbox, including reports | 5 years after we receive them, then deleted |
| Logs and error records | Up to 30 days |
| Receipt of a workspace deletion | 10 years; it contains no workspace content and no personal data of the workspace's members |
| Backups | 30 days, after which deleted data is gone from them. Our disaster-recovery copies of documents and backups will be deleted within 30 days of a deletion; the process that does this is not in place yet, and until it is, those copies have no fixed expiry |
9. How we protect personal data
Data travels encrypted between your iPhone and our service. Passwords are stored only as one-way hashes, and credentials and secrets are encrypted at rest. Each workspace is isolated from the others. Access inside a workspace follows roles, and two-factor sign-in is available. Actions are recorded in an audit log. No system is perfectly secure: if a breach puts your data at risk, we inform the supervisory authority and, where the law requires, you.
10. Your rights
Under the GDPR you have the right to access your personal data and receive a copy, to rectify it, to erase it, to restrict its processing in certain cases, to data portability, to object to processing based on our legitimate interests, and not to be subject to a decision based solely on automated processing.
- Delete your account in the app: Account → Delete my account.
- Withdraw AI sharing in the app: Account → Privacy and AI sharing → Review AI sharing permission.
- Download a copy of your data, on the web: Settings › Profile › Your data › Export my data.
- For anything else, write to privacy@nexaethos.com, preferably from the email address of your account. We may ask you to confirm your identity, for example by an action inside your account. We answer within one month; for complex requests we may extend this by two further months, and if so we tell you why within the first month. Exercising your rights is free, unless a request is manifestly unfounded or excessive.
For workspace content, we pass your request to your organisation and help it answer (section 2).
You can lodge a complaint with a supervisory authority. Ours is the Agencia Española de Protección de Datos (AEPD), C/ Jorge Juan 6, 28001 Madrid, Spain — https://www.aepd.es. You may also complain to the authority of the country where you live or work.
11. Tracking
The app contains no advertising, analytics or tracking tools, and does not track you across other companies' apps or websites.
12. Children
Nexa Agora is intended for adults using the service for business or professional purposes, and is not directed at anyone under 18. If you believe a minor has given us personal data, write to privacy@nexaethos.com and we will delete it.
13. Changes to this policy
We update this policy when our processing changes, and the date at the top changes with it. When a change is material, we tell account holders in the app or by email at least 30 days before it takes effect.
14. Contact
NexaEthos S.L., Calle Santa Juliana 9, 29130 Alhaurín de la Torre (Málaga), Spain — privacy@nexaethos.com