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Privacy Policy

Last updated: June 13, 2026

This Privacy Policy explains, in line with Articles 13 and 14 GDPR, how Prociro LLC ("Prociro", "we"), operator of the Nybero service, processes personal data — both on this website (nybero.com) and within the SaaS service for WhatsApp marketing automation.

1. Controller

Prociro LLC, operator of Nybero
[Address — see imprint]
Email: [privacy@nybero.com] · via our contact form

2. Controller vs. processor

For account and website data we are the controller. For the end-customer contact data our business customers process through Nybero, we act as a processor (Art. 28 GDPR) on their behalf; the customer is then the controller. We enter into a data processing agreement (DPA) with our customers.

3. Visiting the website & server logs

When you access nybero.com, our hosting provider processes technically necessary data (IP address, date/time, requested resource, referrer, user agent) in server log files. The legal basis is our legitimate interest in secure, stable operation (Art. 6(1)(f) GDPR). Fonts are self-hosted (no Google Fonts CDN), so no data is transferred to third parties for this.

Hosting: [name & location of hosting provider, EU]. A DPA is in place.

4. Contact form

When you use our contact form, we process the data you provide (name, email, optional company, chosen topic, message) and, for abuse prevention, your IP address and user agent. The legal basis is Art. 6(1)(b) GDPR (pre-contractual steps) or (f) (answering your enquiry). Data is stored to handle your request and deleted once resolved, unless statutory retention obligations apply.

5. Bot protection — Cloudflare Turnstile

To protect our forms from automated abuse we use Cloudflare Turnstile (Cloudflare, Inc., USA). Technical information about your device/browser is transmitted to and assessed by Cloudflare. Legal basis: Art. 6(1)(f) GDPR (security). On transfers to the USA, see section 9.

6. Account & use of the service

For registration and use of app.nybero.com we process account and usage data (name, email, password hash, organization/workspace, log and metering data). Legal basis: Art. 6(1)(b) GDPR (contract). For sending email (e.g. account/system messages) we use Resend (Resend, Inc., USA).

7. WhatsApp Business Platform / Meta

Nybero's core function is sending and receiving messages via Meta's WhatsApp Business Platform (Meta Platforms Ireland Ltd. / Meta Platforms, Inc.). Phone numbers and message content are processed. Our business customers must obtain valid opt-in consent from recipients before messaging. Meta's processing is additionally subject to the WhatsApp Business Terms and Meta's privacy policy.

8. Processors we use

  • Hosting — [provider, EU] (server/database operation, EU)
  • Meta Platforms — WhatsApp Business Platform (message delivery)
  • Cloudflare, Inc. — Turnstile bot protection
  • Resend, Inc. — transactional email

We have Art. 28 GDPR agreements with all processors. We share data only as necessary to provide the service. We do not sell personal data.

9. International transfers (USA)

Some providers (Meta, Cloudflare, Resend) are based in or process data in the USA. Transfers rely on the EU Standard Contractual Clauses (Art. 46 GDPR) and, where certified, the EU-US Data Privacy Framework, supplemented by appropriate additional safeguards. A level of protection equivalent to the EU's cannot be guaranteed in every case; we point out this residual risk transparently.

10. Cookies & similar technologies

This website uses only strictly necessary cookies/storage (e.g. as part of bot protection). There is no third-party tracking or analytics. Details in our Cookie Policy.

11. Retention

We retain personal data only as long as necessary for the respective purposes or as required by statutory retention periods (e.g. commercial/tax law). Contact and message data we process for customers is deleted on their instruction and on request (see Data Deletion).

12. Your rights

You have the right to access (Art. 15), rectification (Art. 16), erasure (Art. 17), restriction (Art. 18), data portability (Art. 20), and to object (Art. 21). You may withdraw consent at any time with future effect. You also have the right to lodge a complaint with a supervisory authority. To exercise these rights, please use our contact form (topic "Privacy").

Note: Fields marked […] (address, email, hosting provider) must be completed before going live. This template is not legal advice; review by a lawyer before publication is recommended.