Privacy Policy

1. Data Controller

NexGen LLC
Democracia str. 46 A
Burgas 8000, Bulgaria
Email: info@nex-gen.eu

We do not have a Data Protection Officer (DPO).

2. Personal Data We Collect

2.1 Website

We do not collect personal data through the Website by means of forms or registrations. The Website is informational.

Cookies and Analytics

We use Google Analytics for non-identifying usage statistics (page views, device type, approximate location, browser, session duration). Google Analytics processes data under its own terms; we do not combine analytics data with any personal identifiers.

2.2 Mobile App — LifeLink Mobile

The App does not collect or transmit personal data. The App requests the following device permissions for functionality only:

• Camera access
• Microphone access

The App uses Firebase Cloud Messaging (FCM) to deliver push notifications. FCM may process device identifiers for message delivery; we do not collect additional personal data from this service.

Accounts: If you request a user account, we will store your email address only for account management and will remove it upon your request.

3. Purposes and Legal Basis

We process data for the limited purposes below and rely on the corresponding legal bases under the GDPR:

• Cookies & Analytics: Consent obtained via the cookie banner.
• App functionality: Processing necessary for the operation of the app (permissions granted by the user).
• Account management: Performance of a task requested by the data subject (account creation and support).
• Hosting & infrastructure: Legitimate interests in operating the Website and App infrastructure.

4. Data Sharing and Transfers

We do not sell or otherwise share personal data for third-party marketing. Third-party subprocessors we use include:

• Superhosting.bg — hosting provider
• Google (Firebase & Google Analytics) — analytics and push notifications

We do not transfer personal data outside the EU/EEA. If this changes, we will implement appropriate safeguards (e.g. standard contractual clauses).

5. Data Retention

We retain personal data only when strictly necessary:

• User account email addresses: retained until deletion request by the user or account termination.
• App permissions: retained locally on your device until you change them or uninstall the app.

6. Security

We apply reasonable technical and organizational measures to protect personal data including HTTPS, secure hosting, and access controls. Although we currently do not have a formal breach response plan, we will notify affected users and supervisory authorities in accordance with GDPR if a breach occurs.

7. Your Rights

You have rights under the GDPR, including:

• Access to your personal data
• Rectification
• Erasure (right to be forgotten)
• Restriction of processing
• Data portability
• Object to processing
• Withdraw consent where processing is based on consent

To exercise these rights, contact: info@nex-gen.eu. We will respond within one month unless extended for complex requests under the GDPR.

8. Children

We do not knowingly collect information from children under 16. If you believe we have collected such information, please contact us to request deletion.

9. Changes to this Policy

We may update this Privacy Policy. Material changes will be communicated by email to registered account holders and via notice on the Website.

10. Contact

Questions or requests: info@nex-gen.eu