Privacy Policy

Elavare Holdings ("we," "us," or "our") operates The Nyne platform. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our Service. We are committed to protecting your privacy and handling your data with transparency and care.

1. Information We Collect

1.1 Account Information: When you register for The Nyne, we collect:

• Name and email address
• Account credentials (password, stored encrypted)
• Subscription tier and billing information

1.2 Business Information: During onboarding and ongoing use, you provide:

• Business role (agent, team leader, broker/owner)
• Years in business, markets served, brokerage affiliation
• Business metrics (GCI, transaction volume, team size, etc.)
• Goals, vision, strengths, and challenges
• Mission and vision statements

1.3 Usage Data: We automatically collect:

• Queries submitted to the executive board
• Executive responses and EA synthesis
• Session timestamps and frequency of use
• Device and browser information
• IP address and general location

2. How We Use Your Information

We use the information we collect to:

• Provide personalized AI-generated advisory responses tailored to your business
• Generate your mission, vision, and business plan based on your dossier
• Maintain conversation history to provide contextual, relevant advice
• Process subscription payments and manage billing
• Improve the quality and accuracy of our AI models
• Communicate with you about account updates, feature releases, and support
• Detect and prevent fraud, abuse, or security issues

3. Third-Party Services

To provide the Service, we use the following third-party providers:

3.1 Firebase (Google): Authentication and database hosting. Firebase stores your account credentials, dossier data, and conversation history. Firebase is SOC 2 and ISO 27001 certified.

3.2 Stripe: Payment processing for subscriptions. Stripe handles all payment card information. We never store your full credit card details. Stripe is PCI DSS Level 1 certified.

3.3 OpenRouter & AI Providers: Your queries and dossier information are sent to AI model providers (including Anthropic, Google, and DeepSeek) via OpenRouter to generate executive responses. These providers process your data according to their respective privacy policies and do not use your data to train their models without explicit consent.

3.4 Vercel: Hosting and deployment infrastructure. Vercel provides the platform on which The Nyne runs and may have access to server logs containing IP addresses and request metadata.

3.5 Google Calendar and Gmail (optional connections): If you choose to connect your Google account, The Nyne reads your calendar events, and if you enable it, your email, only to provide coaching to you. You authorize this on Google\'s consent screen, you can disconnect at any time from your account settings, and disconnecting removes our access. We store a summary of your upcoming appointments to coach you; we do not sell this information, use it for advertising, or share it with anyone other than the AI providers that generate your coaching, and only for that purpose. The Nyne\'s use and transfer of information received from Google APIs adheres to the Google API Services User Data Policy, including the Limited Use requirements.

4. Data Sharing and Disclosure

We do not sell your personal information or business data to third parties. We only share your information in the following circumstances:

• Service Providers: With the third-party services listed above, solely to provide the Service
• Legal Compliance: When required by law, court order, or government regulation
• Business Transfers: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the acquiring entity
• With Your Consent: When you explicitly authorize us to share specific information

5. Data Retention

We retain your account information and business data while your account is active and after your subscription ends. When your subscription ends, your access to your account and its data is revoked, and we continue to retain the data for backup, archival, product development, legal compliance, and business purposes, including in anonymized or aggregated form. If you subscribe again, you may request restoration of your prior data for a data retrieval fee as described in our Terms of Service. Restoration is at our discretion and is not guaranteed.

6. Your Privacy Rights

You have the following rights regarding your personal information:

• Access: Request a copy of all personal data we hold about you
• Correction: Update or correct inaccurate information through your account settings or by contacting support
• Deletion: Request deletion of your account and all associated data
• Export: Download your dossier, business plan, and conversation history in machine-readable format
• Opt-Out: Unsubscribe from marketing communications (service-related emails cannot be opted out of while your account is active)

To exercise these rights, contact us at support@thenyne.io.

7. Data Security

We implement industry-standard security measures to protect your information, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Firebase Authentication with secure password hashing
• Firestore security rules restricting data access
• Regular security audits and vulnerability assessments
• Restricted employee access to customer data (need-to-know basis only)

While we take reasonable precautions to protect your data, no system is completely secure. We cannot guarantee absolute security of information transmitted over the internet.

8. Cookies and Tracking

The Nyne uses minimal cookies and tracking technologies. Firebase Authentication stores a session cookie to maintain your logged-in state. We do not use third-party advertising cookies or tracking pixels. You can disable cookies in your browser settings, but this may affect the functionality of the Service.

9. Children's Privacy

The Nyne is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a user is under 18, we will terminate the account and delete all associated data.

10. International Data Transfers

Your data may be transferred to and processed in the United States and other countries where our service providers operate. By using The Nyne, you consent to the transfer of your information to countries outside your residence, which may have different data protection laws than your jurisdiction.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via email or through a notice on the platform. Your continued use of the Service after changes take effect constitutes acceptance of the updated policy.

12. Contact Us

If you have questions about this Privacy Policy or how we handle your data, please contact us at:

Email: support@thenyne.io

Company: Elavare Holdings