1. Who is responsible for your data
The controller of the personal data processed through the service is the Operator that provides you the service — the ISP, telecom operator or company that owns the Nextcloud and VPN servers your app connects to. You will find the Operator's identifying details in your contract with them and, where applicable, in the Operator-specific version of this policy.
Note: as no Operator-specific policy applies, this generic version is in force. Nubolink Solutions SL merely provides the panel and the apps: it does not host or store any end-user data and is in no case responsible for the stored data or the servers; the controller is the Operator.
Software provider: the panel and the apps are developed and owned by Nubolink Solutions SL (Tax ID B13743174, Avinguda Indústria 414, 25001 Lleida). Nubolink Solutions SL does not store any customer data — see section 3.
2. What NuboLink is, and scope of this policy
NuboLink is a management panel and a suite of applications aimed at ISPs and companies, whose sole purpose is to make it easier to use Nextcloud servers (private cloud: files, photos and backups) and WireGuard VPN servers. This policy applies to the apps: NuboDrive (files, photos, sync and backup) and NuboProtect (VPN, security and international eSIM).
The servers the apps connect to do not belong to NuboLink: they belong to the Operator that provides you the service.
3. NuboLink does not store your data
Nubolink Solutions SL only provides the software (the panel and the apps). Accordingly, it:
- does not store customer data: no personal data, files or photos of end users;
- does not own or operate the Nextcloud and VPN servers, which belong to each Operator;
- does not intercept, monitor, record or route the VPN traffic;
- does not access the content hosted on the Operator's Nextcloud servers.
In no case is Nubolink Solutions SL responsible for the data stored through the service or for the servers that data resides on. The Operator, as owner of that infrastructure, is the controller of the personal data processed through it.
4. Data the Operator processes through the service
All of the following data resides on the Operator's infrastructure (or that of the providers the Operator appoints) and is processed under the Operator's responsibility:
| Category | Data | App |
|---|---|---|
| Account | Name, email, phone, language, encrypted access credentials (held on the Operator's systems) | All |
| Files & media | Files, photos and their metadata (stored on the Operator's Nextcloud servers) | NuboDrive |
| VPN connection | VPN/WireGuard configuration and assigned IP (handled on the Operator's servers) | NuboProtect |
| eSIM & payments | Order data, ICCID, destination country; payments processed by third parties (card numbers are not stored) | NuboProtect |
| Technical | Device model, OS, app version, IP address, technical access logs (on the Operator's systems) | All |
| App installation | Installation code: a random identifier of this installation of the app, used to give you the connection (not linked to the device's hardware) | All |
5. VPN — no-logs by design
For safe browsing, the addresses of the websites you open are checked against a public filter of dangerous websites (currently Cloudflare's public resolvers 1.1.1.2 and 1.1.1.3 and, on iPhone, iPad and Mac, depending on the filter level you choose, AdGuard's 94.140.14.14 and 94.140.14.15), without any data from your account.
6. Purposes and Legal Basis
The Operator processes the data for the following purposes:
- Providing the contracted service — performance of a contract (Art. 6.1.b GDPR).
- Device permissions (camera, storage, notifications) — your consent (Art. 6.1.a).
- Security and fraud prevention — legitimate interest (Art. 6.1.f).
- Legal and tax obligations — legal obligation (Art. 6.1.c).
7. Device Permissions
Permissions are used locally on your device:
- Camera: to scan activation QR codes and capture photos (NuboDrive).
- Photos / Storage: to back up and sync your files and images.
- VPN configuration: to establish the NuboProtect secure tunnel.
- Location (NuboProtect, only when you add a trusted Wi-Fi): Android requires it to read the name of the Wi-Fi you are connected to. That name stays on your device; your location is not stored or sent to anyone.
- Notifications: service and security alerts.
8. Recipients
The Operator shares data only with the providers strictly necessary to deliver the service (eSIM connectivity providers and payment gateways such as Stripe, PayPal and Redsys), under the corresponding agreements. Nubolink Solutions SL does not receive or share end-user data.
On Android, the apps use Google ML Kit (through Google Play services) to read QR codes, scan documents and analyse photos on the device. Images and results never leave the device; ML Kit itself sends Google technical usage and diagnostic data (device and installation identifiers) to operate and improve the service, as described at developers.google.com/ml-kit/android-data-disclosure.
9. International Transfers
Any transfer outside the EEA made by the Operator or its providers is covered by adequacy decisions or the European Commission's Standard Contractual Clauses.
10. Retention
The Operator keeps the data while your account is active and afterwards for the periods required by law. VPN technical data is kept only for the minimum time needed to run the connection.
11. Your Rights
You may exercise your rights of access, rectification, erasure, objection, restriction and portability before the Operator (the controller), through the contact channel of your Operator. You may also lodge a complaint with the Spanish Data Protection Agency (AEPD, www.aepd.es). For questions about the software itself, you may contact privacidad@nubolink.cloud.
12. Minors
The services are not directed to children under 14.
13. Security
The software includes measures such as credential encryption and encrypted transport (TLS). The security of the servers and of the data stored on them is the sole responsibility of the Operator.
14. Account and Data Deletion
You may request deletion of your account and data from your Operator at any time.
15. Changes
This policy may be updated; the current version and date are always available at this URL.
16. Contact
Software (Nubolink Solutions SL): privacidad@nubolink.cloud · Data processing: your Operator.