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Genie9

Nygma Regional Compliance Notices

Last Updated: October 13, 2026

This notice gives region-specific information about how Genie9 LTD (“Genie9”, “we”, “us” or “our”) handles personal data for Nygma — the web app, the Android and iOS apps, and Nygma Chat (together, the “Service”). Read it together with our Privacy Policy.

Your files, file and folder names, thumbnails and chats are encrypted on your device before they reach us, so we cannot read them. The personal data we process is mainly account and service data: your email address and name, the names you give your drives, file sizes and dates, plan and billing records, and IP addresses in server logs.

1. Where Your Data Is Processed

1.1 Our Servers Are in the United States

  • • Genie9 LTD is based in the United Kingdom and is the controller of your personal data.
  • • Our servers are in the United States (Amazon Web Services, us-east-1). We do not offer a choice of data location, and we do not keep your data in the UK or the EU.
  • • Some of our service providers (such as Google, Apple and Stripe) also process data in the United States and other countries.

1.2 Transfer Safeguards

  • • Transfers of personal data from the UK rely on the UK International Data Transfer Addendum, and from the European Economic Area on the EU Standard Contractual Clauses — or on the UK–US data bridge where it applies.
  • • Your files and chats are encrypted on your device before they are transferred, so the copies we store are unreadable to us and to our providers.

2. United Kingdom and European Union (UK GDPR and GDPR)

2.1 Lawful Bases

  • • Contract (Article 6(1)(b)): running your account, storing your encrypted data, delivering chats, sending sign-in codes and handling your subscription
  • • Legitimate interests (Article 6(1)(f)): security, preventing fraud and abuse, the sign-up country check, and server logs
  • • Legal obligation (Article 6(1)(c)): tax and accounting records, responding to lawful requests, and reporting illegal content where the law requires
  • • Consent (Article 6(1)(a)): where we ask for it, for example analytics cookies on our website

2.2 Your Rights

Under the UK GDPR and the GDPR you have the right, as those laws provide, to:

  • • Access the personal data we hold about you
  • • Have inaccurate data corrected
  • • Have your data erased
  • • Restrict how we use your data
  • • Data portability
  • • Object to processing based on legitimate interests
  • • Withdraw consent at any time, where we rely on consent
  • • Not be subject to decisions based solely on automated processing that have legal or similarly significant effects, where this right applies
  • • Complain to a supervisory authority — in the UK the Information Commissioner’s Office (ICO), in the EU the authority where you live or work

2.3 What Encryption Means for Your Requests

  • • We cannot give you your files or chats in readable form, because we cannot decrypt them. You can download your files yourself in the apps.
  • • You can delete your account yourself in the app (Settings → Delete account) or at nygma.genie9.com/delete-account.

2.4 Making a Request

  • • Email privacy@genie9.com or our Data Protection Officer at dpo@genie9.com.
  • • We may need to confirm your identity first, for example by sending a code to your account email.
  • • We answer within the legal deadline: one month, which the law lets us extend by up to two further months for complex or numerous requests. If we extend, we will tell you why.
  • • Requests are usually free. Where a request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse it, as the law allows.

3. United Kingdom: Online Safety Act 2023

3.1 How Nygma Fits

Nygma Chat is a private, invite-only, end-to-end encrypted user-to-user service: people can only message each other after one has accepted the other’s invitation, and there is no directory, search or random matching. Nygma users can also share files through password-protected share links. We cannot see the content of chats or shared files.

3.2 What We Do

  • • We keep a risk assessment for the Service and review it when the Service changes.
  • • You can report illegal or harmful content, and complain about it or about action we took against your content or account, in the app (Report a problem on any chat contact) or by email to abuse@genie9.com. We acknowledge reports and complaints within 48 hours.
  • • When we become aware of illegal content, we act on it with the tools we have — for example by disabling share links and suspending or closing accounts — and report to the authorities where the law requires.
  • • Nygma is for people aged 16 and over.

See our Acceptable Use Policy and Child Safety Standards.

4. California, USA

4.1 California Consumer Privacy Act (CCPA/CPRA)

Where the CCPA applies to us, this section is our notice to California residents.

Categories of personal information we collect:

  • • Identifiers: name, email address, account ID, IP address
  • • Commercial information: plan, subscription and purchase records
  • • Internet activity: server logs, and website and app analytics where enabled
  • • Approximate location: the country worked out from your IP address for the sign-up check

If you share a location in Nygma Chat, it is end-to-end encrypted and we cannot see it.

Your California rights:

  • • Right to know what personal information we collect and how we use it
  • • Right to delete personal information
  • • Right to correct inaccurate personal information
  • • Right to opt out of the sale or sharing of personal information
  • • Right not to be discriminated against for using these rights

To use these rights, email privacy@genie9.com. We will confirm your identity and answer within the time the law allows.

4.2 Sale and Sharing

  • • We do not sell personal information for money.
  • • Inside the signed-in web app and on share-link pages, advertising signals are switched off.
  • • On our other web pages, Google advertising cookies may be used to measure our own advertising, which California law may treat as “sharing”. You can opt out by blocking or deleting these cookies in your browser, or by emailing privacy@genie9.com. See our Cookie Policy.

5. Other Regions

Where the following laws apply to us, you have the rights they give you, including access to and correction of your personal information:

  • • Canada: PIPEDA and similar provincial laws, including Quebec’s Law 25 — regulator: Office of the Privacy Commissioner of Canada
  • • Australia: Privacy Act 1988 and the Australian Privacy Principles — regulator: Office of the Australian Information Commissioner
  • • Brazil: Lei Geral de Proteção de Dados (LGPD) — regulator: Autoridade Nacional de Proteção de Dados
  • • Switzerland: Federal Act on Data Protection — regulator: Federal Data Protection and Information Commissioner
  • • Other countries: the data protection law that applies where you live

To make a request, email privacy@genie9.com. You can also complain to your regulator.

5.1 Data Breaches

If a personal data breach happens, we will notify regulators and the people affected where the law requires.

6. Minimum Age: 16 Everywhere

  • • You must be at least 16 to use Nygma, including Nygma Chat, wherever you live. The Service is not directed to children under 16, and we do not accept parental consent in place of this rule.
  • • We do not knowingly collect personal data from anyone under 16. If we learn that an account belongs to someone under 16, we close it and delete its data, except anything the law requires us to keep.
  • • If you believe someone under 16 is using Nygma, tell us at abuse@genie9.com.

7. Requests From Authorities

  • • We respond to lawful requests from police, courts and regulators where the law requires us to.
  • • We can only provide what we hold in readable form — account and service data such as email address, name, drive names, file sizes and dates, billing records and server logs.
  • • We cannot decrypt your files or chats, because we do not have the keys.

See our Transparency Report.

8. Export Controls and Sanctions

  • • You must not use Nygma where export control or sanctions law prohibits it.
  • • We may block sign-ups or access from any country or region. New sign-ups from some countries are blocked today.
  • • See our Export Control Statement.

9. Cookies

  • • Where the law requires consent (for example in the UK and the EU), we do not set analytics or advertising cookies until you agree.
  • • Essential cookies, such as those that keep you signed in, do not need consent.
  • • See our Cookie Policy.

10. Changes and Translations

  • • We may update this notice at any time and will post the new version here with a new date.
  • • If we publish a translation and it differs from the English version, the English version applies.

11. Contact Information

Controller:

Genie9 LTD

3 Shortlands

London W6 8DA

United Kingdom

Email:

These Regional Compliance Notices were last updated on October 13, 2026. Please check this page for the current version.

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