Nygma Export Control Statement
Last Updated: October 13, 2026
Nygma — the web app, the Android and iOS apps and Nygma Chat (the “Service”) — is provided by Genie9 LTD (“Genie9”, “we”, “us” or “our”), a company registered in England and Wales with company number 08669198.
The Service uses encryption. Encryption products can be subject to export control and sanctions laws in the United Kingdom, the United States, the European Union and elsewhere. This statement explains how we view the Service, what you must not do, and what we may do. It forms part of our Terms of Service. It is not legal advice.
1. Encryption in Nygma
- • Drives: files, file and folder names, thumbnails and file metadata are encrypted on your device with AES-256-GCM (all plans) or ChaCha20-Poly1305 (Professional plans and above). Keys are derived with PBKDF2-SHA256 and HKDF.
- • Nygma Chat: messages and attachments are end-to-end encrypted, using X25519 and ML-KEM-768 for key agreement and ChaCha20-Poly1305 or XChaCha20-Poly1305 for encryption.
- • In transit: connections use TLS (HTTPS).
- • All of these are standard, published algorithms. Users cannot change the encryption the Service uses.
2. How We Classify the Service
2.1 A Mass-Market Encryption Product
The Service is a consumer product that anyone can download from public app stores or use on the web, and that people install and use without help from us. We therefore treat it as a mass-market encryption item.
2.2 United States
Under the US Export Administration Regulations, we consider the Service to be mass-market encryption software (ECCN 5D992.c, under 15 C.F.R. § 740.17(b)(1)). Mass-market encryption items can generally be exported without a licence, but not to embargoed destinations or to prohibited persons.
2.3 United Kingdom and European Union
Under the Cryptography Note (Note 3 to Category 5, Part 2) of the UK Strategic Export Control Lists and of the EU Dual-Use Regulation (EU) 2021/821, mass-market items that meet the Note are not controlled as encryption items. UK and EU sanctions still apply.
2.4 Our View Only
This classification is our own assessment and may change if the Service or the law changes. We do not promise that it is correct for your situation, or that you may lawfully use, export or import the Service where you are.
3. Where and By Whom Nygma Must Not Be Used
3.1 Embargoed and Sanctioned Places
You must not use, download, export, re-export or transfer the Service:
- • In or to any country or region subject to a US embargo or comprehensive US sanctions (for example Cuba, Iran and North Korea)
- • In breach of UK sanctions or, where they apply to you, EU sanctions
- • Where the law of your country prohibits or restricts the import or use of encryption without a licence you do not have
These lists change. Current information is published by the US Treasury (OFAC), the US Commerce Department (BIS) and the UK Government (Office of Financial Sanctions Implementation and the UK Sanctions List).
3.2 Restricted Persons
You must not use the Service if you are, or act for, or are owned or controlled by, a person on a restricted-party list, including:
- • The US Treasury’s Specially Designated Nationals (SDN) list
- • The US Commerce Department’s Entity List and Denied Persons List
- • The UK Sanctions List
- • The EU consolidated list of financial sanctions
3.3 Prohibited End Uses
You must not use the Service in connection with nuclear, chemical or biological weapons, missiles, or any other end use that export control law prohibits.
4. What We May Do
- • We may block or restrict sign-ups or access from any country or region, IP address or person, at any time and without notice, for legal, sanctions, security or business reasons. New sign-ups from some countries are blocked today; the country is worked out from the IP address on our own servers.
- • We may suspend or close any account we believe breaks this statement, without a refund, to the extent the law allows.
- • We may cooperate with export control and sanctions authorities and respond to their lawful requests.
- • We do not promise to detect or block every restricted place or person. If we do not block you, that does not mean your use is lawful.
5. Your Responsibilities
By using the Service, you confirm that none of section 3 applies to you. You are responsible for:
- • Complying with the export control, sanctions and encryption laws that apply to you, including when you travel
- • Not giving access to the Service, or to content you share through it, to restricted persons or places
- • Not using a VPN, proxy or false information to get around our restrictions
6. Changes
Export control and sanctions laws change often. We may update this statement, and the places where the Service is available, at any time. We will post the new version on this page with a new date.
7. Contact Information
Export control and sanctions questions:
Email: legal@genie9.com
Postal address:
Genie9 LTD
3 Shortlands
London W6 8DA
United Kingdom
This Export Control Statement was last updated on October 13, 2026. Export control and sanctions laws are complex and change often; ask a qualified lawyer about your own situation.