Privacy Policy (Privacy of Service)

Last Updated: 19.01.2026

1. Introduction

Neonvil ("we," "us," or "our") values the privacy and security of our clients and their users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you engage our services or visit our digital platforms.

Important Legal Notice: Neonvil operates as a community of independent entrepreneurs. For the purposes of the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Data Controller of your personal data is the specific Service Owner (Individual Entrepreneur) with whom you have signed a B2B Agreement.

2. Information We Collect

We collect information strictly necessary to provide our software development and consulting services.

2.1 Client Data (B2B)

When you engage Neonvil for a project (MVP, POC, Audit), we collect:

Business Contact Information: Names, email addresses, phone numbers, and billing addresses of client representatives.
Billing Data: VAT numbers, bank account details, and transaction history.
Project Specifications: Technical requirements, documentation, and access credentials necessary to build your product.

2.2 End-User Data (Processed on Behalf of Client)

If we develop or maintain software for you, we may act as a Data Processor for the end-user data collected by your application (e.g., your customers' emails or logs).

Processing Agreement: The handling of this data is governed strictly by the specific Data Processing Addendum (DPA) included in your B2B Agreement.
No Ownership: Neonvil claims no ownership over the end-user data processed by the software we build for you.

3. How We Use Your Information

We utilize your data based on the following legal grounds:

Contractual Necessity: To fulfill the obligations defined in our B2B Agreement (e.g., communicating project updates, delivering code, issuing invoices).
Legal Obligation: To comply with tax laws, accounting regulations, and audit requirements in the Slovak Republic and Portugal.
Legitimate Interest: To maintain the security of our infrastructure, prevent fraud, and enforce our Terms of Service.

We do not sell your data. We adhere to a strict transparency policy regarding who accesses your data.

4.1 Authorized Subcontractors

As outlined in our General Explanation and Terms of Service, the Service Owner may engage trusted subcontractors (e.g., developers, QA engineers) to assist in project delivery.

Strict Vetting: Every subcontractor with access to Client Data has undergone a background check.
Binding NDAs: All subcontractors are bound by strict Non-Disclosure Agreements.
Liability: The Service Owner remains fully liable for the data protection practices of their subcontractors.

4.2 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency).

5. Data Security

We implement enterprise-grade security measures to protect your data, as detailed in our Tech Stack documentation:

Encryption: Data is encrypted in transit (SSL/TLS) and at rest where applicable.
Access Control: We utilize strict Role-Based Access Control (RBAC). Only personnel directly working on your project have access to your environment.
Infrastructure: Our internal systems rely on secure, ISO-certified providers (AWS, Azure, Google Cloud).

6. International Data Transfers

Neonvil operates primarily within the European Economic Area (EEA). If a project requires data transfer to a subcontractor outside the EEA, we ensure protection through:

Adequacy Decisions: Transferring to countries deemed secure by the EU Commission.
Standard Contractual Clauses (SCCs): Implementing EU-approved legal contracts that guarantee GDPR standards.

Under the GDPR, you have the following rights regarding your personal data:

Right of Access: Request a copy of the personal data we hold about you.
Right to Rectification: Request correction of inaccurate data.
Right to Erasure: Request deletion of your data ("Right to be Forgotten"), subject to our legal retention obligations (e.g., tax records).
Right to Restriction: Request that we limit the processing of your data.
Right to Portability: Receive your data in a structured, commonly used format.

To exercise these rights, please contact the Service Owner directly via the email provided in your B2B Agreement, or contact the Community Leader below.

8. Data Retention

We retain personal data only as long as necessary:

Project Data: Retained for the duration of the project + warranty period.
Financial Records: Retained for 10 years as required by Slovak and Portuguese tax laws.
Legal Defense: Retained as necessary to defend against potential legal claims.

9. Contact Information

For any privacy-related inquiries, complaints, or to exercise your GDPR rights, please contact the Community Leader:

Volodymyr Gutorov

Role: Community Leader / Data Protection Contact
Email: v.gutorov@neonvil.com
Registered Address: Slovak Republic, IČO: 56 579 764 VAT: SK3122074505

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