1. Data Controller
NuGo ("we", "our", or "us") is the data controller responsible for your personal data. NuGo is developed by Dr Deirdre Ryan, Clinical Psychologist. For any privacy-related queries, please contact us at privacy@nugoapp.com.
2. What Data We Collect
- Profile Information: Parent/carer name, email address, child's name, age, and any information you choose to add to the Child Passport.
- Documents: Any files you upload to the Lock Box feature (assessments, reports, certificates).
- Waiting List Data: Service provider names, dates, and notes you add to track appointments.
- Usage Data: Only if you consent — anonymous app usage patterns to help us improve the app.
3. How We Use Your Data
- To provide and maintain the NuGo app services
- To store your documents securely in the Lock Box
- To send you reminders you have set (with your permission)
- To improve our services (only with your explicit consent)
4. Legal Basis for Processing
- Contract: Processing necessary to provide the app services you've requested.
- Consent: For analytics and crash reports, which you can enable or disable at any time.
- Legitimate Interest: To improve app security and prevent fraud.
5. Data Storage & Security
Your data is primarily stored locally on your device. When you use cloud features (such as secure document sharing), data is encrypted and stored on secure servers within the European Economic Area (EEA). We implement industry-standard security measures including:
- End-to-end encryption for shared documents
- Password protection for secure links
- Automatic expiry of shared links
- Biometric authentication options
6. Your Rights Under GDPR
- Right to Access: Request a copy of all data we hold about you via the Data Export feature.
- Right to Rectification: Update or correct your personal information at any time in Settings.
- Right to Erasure: Delete all your data using the "Delete All Data" option in Settings, or delete your account entirely (see our Account Deletion page).
- Right to Restrict Processing: Disable analytics and crash reports in Settings.
- Right to Data Portability: Export your data in JSON or CSV format.
- Right to Object: Object to processing based on legitimate interests.
7. Children's Privacy
NuGo is designed for parents, carers, and educators to support children with neurodevelopmental needs. We do not knowingly collect personal data directly from children. All child-related information is entered and managed by their parent or guardian, who maintains full control over this data.
8. Data Sharing
We do not sell, trade, or rent your personal data to third parties. We may share data only:
- When you explicitly choose to share (e.g., secure document links)
- With service providers who assist in app operation (under strict data processing agreements)
- When required by law or to protect legal rights
9. Data Retention
We retain your personal data only for as long as necessary to provide our services. Local data remains on your device until you delete it. Cloud-stored data is retained until you request deletion or close your account. Shared document links expire automatically based on your chosen settings.
10. Cookies & Tracking
NuGo does not use cookies for tracking. We only use essential local storage to save your preferences and app data on your device. Analytics, if enabled, use privacy-respecting methods that do not track individual users across websites or apps.
11. Changes to This Policy
We may update this privacy policy from time to time. We will notify you of any material changes through the app and update the "Last Updated" date. Continued use of the app after changes constitutes acceptance of the updated policy.
12. Contact & Complaints
If you have questions about this privacy policy or wish to exercise your rights, please contact us at privacy@nugoapp.com.
If you believe your data protection rights have been violated, you have the right to lodge a complaint with your local Data Protection Authority. In Ireland, this is the Data Protection Commission (www.dataprotection.ie).
By using NuGo, you acknowledge that you have read and understood this Privacy Policy.