Privacy policy

Last Updated: October 20, 2025

Introduction

This Privacy Notice explains how Nuwa Labs, Inc. ("Nuwa," "we," "our," or "us") collects, uses, discloses, and otherwise processes personal data in connection with the Nuwa Pen hardware, the Nuwa+ App, our websites (including nuwapen.com), and all related services (collectively, the "Services").

This Privacy Notice is not a contract and does not create any legal rights or obligations not otherwise provided by law. By interacting with our Services, you acknowledge that you have read and understood this Privacy Notice.

1. Personal Data We Collect

The categories of personal data we collect depend on how you interact with our Services. We collect information you provide to us, information collected automatically, and information from other sources.

Information You Provide to Us

  • Contact Information: Your name, email address, phone number, and shipping/billing addresses.
  • Account Information: Your account credentials (username and password), language preference, dominant hand (left/right-handed), country, and other profile settings.
  • Payment Information: When you make a purchase, our third-party payment processors collect your payment card information and billing details. Nuwa does not directly store your full payment card number.
  • Communications and Support Information: The content of your communications with us, such as feedback or inquiries sent to our support team.

Information Collected Automatically

When you use our Services, we and our partners automatically collect certain information about your devices and your interaction with our Services.

  • From the Nuwa Pen Hardware:

    We collect two categories of information directly from the hardware:

    • Digital Ink Representation: To render a precise and fluid digital version of your unique handwriting, the pen captures a comprehensive set of data. This includes the optical and positional information that defines the appearance and shape of your strokes, as well as the dynamic motion data (such as pressure, tilt, and acceleration) that captures the character of your writing.
    • Hardware Performance Analytics: To ensure your pen is functioning optimally, we collect diagnostic and operational data about the hardware itself. This includes information such as battery status, firmware version, memory usage, performance metrics, and error logs.
  • From the Nuwa+ App and Cloud Service:
    • User Content: Your Handwriting Data, final transcribed text, and other content you create, which we store to provide syncing, backup, and other features.
    • Usage Metadata: Data associated with your content and activity, such as creation date, time, last modified date, and potentially location data if you enable this feature.
    • Application Analytics: Information about your interaction with the App, such as features used, session duration, and performance data, to help us improve the user experience.
  • From our Website and Services:
    • Device and Network Information: Your IP address, browser type, operating system, unique device identifiers, and information about the network you are using.
    • Usage Information: Information about how you navigate our website and interact with our marketing communications. This may include recording user behavior, such as mouse movements, clicks, and scrolling, to improve our website design.

Information from Other Sources

  • Third-Party Services: If you choose to log in using a third-party service (such as Google or Apple), we receive information from that service as permitted by your privacy settings with that service, such as your name and email address.
  • Our Partners: We may receive information from partners who assist us with marketing or promotional services to measure the performance of our campaigns.
  • Inferences: We may generate inferences about your interests or preferences based on your interaction with our Services to help us provide a more personalized experience.

2. How We Use Your Personal Data and Our Legal Bases

We use the personal data we collect for the purposes described below. For each purpose, we have identified the legal basis for the processing under regulations like the GDPR.

  • To Provide and Maintain the Services: To fulfill your orders, process payments, sync your notes across devices, provide cloud storage, and perform transcription. Legal Basis: Performance of a contract with you.
  • For Service Improvement and AI Model Training: With your explicit, opt-in consent, we use anonymized Handwriting Data to train and improve our proprietary handwriting recognition models. We may also share this anonymized data with our third-party AI partners for the same purpose. You can manage this consent in your account settings at any time. We will not use your data for this purpose without your permission. Legal Basis: Your explicit consent.
  • For Research, Development, and Personalization: To analyze usage trends, inform our product roadmap, and personalize your experience. This helps us understand what features are most useful and how to improve our Services. Legal Basis: Our legitimate interests in improving and developing our Services.
  • To Communicate With You: To provide customer support and send important transactional communications (e.g., order confirmations, security alerts, and policy updates). We may also send marketing communications in accordance with your preferences. Legal Basis: Performance of a contract and our legitimate interests for transactional messages; your consent for marketing messages.
  • For Security, Fraud Prevention, and Legal Compliance: To protect our users and our Services, prevent fraud, enforce our Terms of Service, and comply with legal obligations. Legal Basis: Legal obligations and our legitimate interests in protecting our company and users.
  • Aggregated Analytics: We may use aggregated, de-identified data for business intelligence, industry analysis, or marketing purposes. This data does not identify you personally. Legal Basis: Our legitimate interests in conducting our business.

3. How We Disclose Your Personal Data

We do not sell your personal data. We may disclose your personal data to the following categories of third parties to provide and improve our Services:

  • Service Providers: We share data with third-party vendors who perform services on our behalf. These vendors are contractually obligated to protect your data and can only use it to perform the services we have engaged them for. These categories include:
    • Cloud Hosting and Storage Providers
    • Payment Processors
    • Fulfillment and Shipping Partners
    • Customer Support Platform Providers
    • Analytics and Marketing Service Providers
  • Third-Party AI Providers: If you use our AI features, we share relevant User Content (like text from your notes) with our AI partners (which may include companies like OpenAI, Anthropic, and Google) to provide those features. This list of partners is subject to change as we evolve our technology.
  • Affiliates: We may share information within our corporate family, such as with our subsidiary entities, for operational, support, and development purposes.
  • Business Transactions: In connection with a merger, acquisition, financing, or sale of company assets, your data may be transferred to the successor or acquiring entity.
  • Legal and Safety Obligations: To comply with lawful requests from public authorities, such as law enforcement, or to protect our legal rights, property, or the safety of our users or others.

4. Cookies and Other Technologies

Our websites and services may use "cookies," web beacons, and other similar technologies to operate and improve our Services, understand user behavior, and measure the effectiveness of our communications.

  • Strictly Necessary Cookies: These are required for the operation of our website, such as keeping you logged in or maintaining your shopping cart.
  • Performance and Analytics Cookies: These cookies help us understand how visitors interact with our services by collecting information anonymously. This allows us to assess performance and improve our offerings.
  • Marketing Cookies: These may be used to track your activity across websites to help us deliver advertising that is more relevant to you.

Your Choices: You can manage your cookie preferences through your web browser settings. Most browsers allow you to block or delete cookies. Please note that if you disable cookies, certain features of our Services may not function correctly. You can also opt out of targeted advertising by visiting the opt-out pages of the Digital Advertising Alliance or the Network Advertising Initiative.

5. Your Privacy Rights and Choices

We empower you with choices and rights regarding your personal data:

  • Data Export: You can request an export of your notes by contacting us. We currently support PDF, TXT, and SVG formats.
  • Account Deletion: You can request the permanent deletion of your account and associated User Content. To do so, please email team@nuwapen.com from the address linked to your account with the subject line “Account Deletion Request.” We will delete your data from active systems within 30 days and from our backups within 90 days, though we may retain certain transactional records for a longer period (e.g., up to 7 years under Dutch law) to comply with legal and accounting obligations. Once deleted, your data cannot be recovered.
  • Opt-Out of AI Training: You can grant or revoke your consent for your anonymized data to be used for AI model training at any time within your Nuwa+ App account settings.
  • Communication Preferences: You can unsubscribe from marketing emails by clicking the "unsubscribe" link in any email we send you.

6. Security and Retention

We are committed to protecting your personal data. We implement robust administrative, technical, and physical security measures, including industry-standard encryption for your data both in transit and at rest. However, no system is perfectly secure, and we cannot guarantee absolute security.

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, including providing the Services, complying with our legal obligations, resolving disputes, and enforcing our agreements. When you request account deletion, we follow the deletion timeline described above.

7. International Data Transfers

Nuwa Labs, Inc. is based in the United States, and we use service providers that operate globally. Your personal data may be transferred to and processed in the United States and other countries outside of where you live. For data transferred from regions like the European Economic Area (EEA), we rely on approved legal mechanisms, such as the Standard Contractual Clauses, to ensure an adequate level of data protection.

8. Children's Data

Our Services are not directed to children. We do not knowingly collect personal data from individuals under 13 years of age (or a higher age threshold where applicable under local law). If we become aware that we have collected a child's personal data without verifiable parental consent, we will take steps to delete it promptly.

9. Region-Specific Disclosures

For Residents of the EEA, UK, and Switzerland:

You have the right to: access, rectify, erase, and port your personal data; restrict or object to our processing of your data; and lodge a complaint with a data protection authority. Our Data Protection Officer can be reached at privacy@nuwapen.com.

For Residents of California and other US States with applicable privacy laws:

You have rights including the Right to Know, the Right to Delete, and the Right to Correct your personal information. You also have the Right to Opt-Out of the "Sale" or "Sharing" of your personal information for targeted advertising. We do not sell your personal information for monetary compensation. To exercise your rights, please contact us.

10. Updates to This Privacy Notice

We may update this Privacy Notice from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. We will notify you of material changes by posting the new notice on our website and updating the "Last Updated" date.

11. Contact Us

If you have any questions about this Privacy Notice or wish to exercise your rights, please contact us at: privacy@nuwapen.com