Nalvera.AI
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Nalvera.AI
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Version 1.7 · Effective date: 23 October 2026
The data controller for Nalvera is Nalvera BV. Organisations that require a formal Data Processing Agreement (DPA) for their use of Nalvera can request one via our contact page.
Nalvera is a research-focused platform that runs peer-reviewed AI models on medical imaging data, including segmentation, classification, and image generation. The service is funded through paid plans and credit top-ups, which sustain its research, education, and operational costs.
Legal basis: Contract performance (Art. 6(1)(b) GDPR) to provide paid features; Legal obligation (Art. 6(1)(c) GDPR) to retain invoices for accounting and tax purposes.
Your uploaded data and AI outputs are not used for any secondary purpose by default. Your data is processed solely to deliver the requested AI result and is not retained for model training, benchmarking, or publication.
Legal basis: Contract performance (Art. 6(1)(b) GDPR).
On the results page you can flag an individual job as available for research. The opt-in is never pre-selected, applies only to that job, and covers no other upload, past or future. Only for jobs you explicitly flag, you grant Nalvera BV (the Nalvera operator) a worldwide, royalty-free, non-exclusive licence to:
Files of an opted-in job may be retained for these purposes even after you delete the job. You can withdraw your consent at any time by contacting us (Section 11); withdrawal does not affect processing already carried out.
Legal basis: Consent (Art. 6(1)(a) GDPR).
Section 3 covers the imaging data you submit. This section covers everything else we do with your account data, the data each purpose uses, and the legal basis we rely on for it.
| Purpose | Data used | Legal basis |
|---|---|---|
| Creating and operating your account | Email address, password hash, account and verification status, plan | Contract — Art. 6(1)(b) |
| Email verification and essential account messages | Email address, verification and password-reset codes | Contract — Art. 6(1)(b) |
| Running AI models on the data you submit | Imaging files, AI outputs, job metadata (Section 3) | Contract — Art. 6(1)(b) |
| Optional per-job research use of imaging data | The scans and outputs of jobs you individually flag (Section 3) | Consent — Art. 6(1)(a) |
| Security, abuse prevention and account lockout | Login history, IP address, server and technical logs | Legitimate interests — Art. 6(1)(f): keeping the platform and its accounts secure |
| Security and compliance audit trail | Records of administrative and security-relevant actions | Legal obligation — Art. 6(1)(c); legitimate interests — Art. 6(1)(f): meeting our ISO 27001 (A.12.4) obligations |
| Aggregate usage statistics | Country, derived once from your IP address at sign-up | Legitimate interests — Art. 6(1)(f): understanding, in aggregate, where the platform is used |
| Job notification emails | Email address, job status | Consent — Art. 6(1)(a), per event, switched on under Settings → Notifications |
| Deletion reminder emails | Email address, the number of your datasets due for deletion and the earliest deletion date | Consent — Art. 6(1)(a), switched on under Settings → Notifications (off by default) |
| Getting-started email (one email, in your first week) | Email address, account-creation date, verification status, plan, remaining free AI runs, whether any AI task has been run | Legitimate interests — Art. 6(1)(f): helping new account holders start using the service they signed up for (see below) |
| Onboarding and user-experience research | Email address, account-creation date, verification status, whether any job has been submitted, last sign-in | Legitimate interests — Art. 6(1)(f): understanding barriers to account activation and improving Nalvera's onboarding and user experience |
| Newsletter and product announcements | Email address | Consent — Art. 6(1)(a) |
| Taking payment for memberships and credit top-ups | Billing data, transaction history | Contract — Art. 6(1)(b) |
| Keeping invoices and accounting records | Invoices and transaction records | Legal obligation — Art. 6(1)(c) |
Where a purpose above relies on legitimate interests, you have the right to object to that processing at any time under Art. 21 GDPR (Section 6). Where it relies on consent, you can withdraw that consent at any time, without affecting processing already carried out.
We work continuously to improve Nalvera's registration and onboarding experience. Where an account has been created but no job has subsequently been submitted, we may contact the account holder to establish what prevented activation, so that we can remove the obstacle.
Selection criteria. Recipients are determined solely from five account attributes: your email address, the date the account was created, its verification status, whether any job has been submitted on the account, and the date of last sign-in. On that basis:
Frequency. For onboarding research, we send at most two messages over the lifetime of your account: one reminder and one research invitation.
Exclusions. We do not use your imaging data, filenames or any detailed behavioural profiling to determine who is contacted. These messages contain no advertising, offers, discounts, product or feature promotions, or upselling. Information you provide is not used to target marketing, nor for automated decision-making or profiling. Participation is voluntary and has no bearing on your account, your credit balance, or the service you receive.
Handling of responses. Responses are received and reviewed by our staff. They remain associated with your account while the feedback is being addressed, and are erased or irreversibly anonymised within 12 months. Please do not include patient data, health information, or imaging files in your response.
Right to object. Every message sent for this purpose contains a one-click link that discontinues further contact without requiring you to sign in. You may also disable it at any time under Settings → Notifications, or by contacting us (Section 11). Newsletter and research-invitation preferences are managed separately. To stop both, disable each one. Where you object, we retain a minimal record of the objection solely in order to continue giving effect to it.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR). The interest pursued is understanding barriers to account activation and improving Nalvera's onboarding and user experience. We have balanced this against your interests and fundamental rights: the processing is limited to basic account attributes, no imaging or health data is involved, the messages are non-promotional, the volume is capped at two messages for the lifetime of the account, and contact can be discontinued in one click.
If you create an account and have not yet run an AI task, we send you one email that reminds you of what your account already includes (the free AI runs and the monthly credits of the Guest plan) and how to start, with a link to the platform.
Who and when. It goes only to verified accounts on the free Guest plan that have free AI runs left and have not run an AI task or used the Interactive Studio. It is sent at the first moment at least 24 hours after sign-up that falls in working hours (Monday to Friday, 09:30 to 17:00, Brussels time), and never to an account created more than seven days earlier. It is sent once for the lifetime of the account.
Data used. Your email address, the date the account was created, its verification status, its plan, the number of free AI runs it has left, and whether any AI task has been run on it. No imaging data, filenames or behavioural profiling are used.
Separate from the research messages. This email is about your own account and our service. It is not one of the onboarding-research messages above, does not count towards their limit of two, and does not change it.
Your choice. It is switched on for new accounts, and you can switch it off at any time: with the one-click link in the email itself (or your mail program's own unsubscribe button), under Settings → Notifications, or by contacting us (Section 11). This setting is independent of the newsletter and of the research invitations.
Legal basis: Legitimate interests (Art. 6(1)(f) GDPR): helping people who created an account start using the service they signed up for. We use your email address for this only as the provider of the service you registered for, we tell you about it when you sign up, and every such email lets you object in one click, in line with the rules for electronic messages to existing customers (Art. 13(2) of the ePrivacy Directive, 2002/58/EC).
As an EU data subject you have the following rights.
Under the ePrivacy Directive (as implemented in Belgian law) and GDPR, we must inform you about all cookies and obtain your consent for non-essential ones.
| Name | Type | Purpose | Duration | Category |
|---|---|---|---|---|
nalvera_session |
HTTP Cookie | Required to keep you signed in. Not used for tracking or analytics. | Browser session; the underlying token expires after 1 day | Strictly Necessary |
nalvera_signup |
HTTP Cookie | Set only during sign-up. Lets you finish creating your account by verifying your email in the same browser without re-entering your password. No tracking or analytics function. | 30 minutes, or until you verify your email (whichever comes first) | Strictly Necessary |
nalvera_follow_seen |
localStorage | Records that you have dismissed (or followed) the one-off note about our updates account, so it is not shown again. Stores one flag in your browser. The flag is not used for tracking or transmitted. | Until you clear it | Functional |
nalvera_notice_seen |
localStorage | Records that you have seen the cookie notice so it is not shown on every visit. | Until you clear it | Functional |
nalvera_session only when you log in and only store a
cryptographic hash in the database; the plaintext token is never stored server-side.
Our public pages load Umami (script served from cloud.umami.is;
page-view beacons are sent to gateway.umami.is), a privacy-focused
analytics service, to give us aggregate page-view statistics and aggregate
interaction events — counts of things like “a sign-up button was
clicked”, “an account was created”, or “the contact form was
submitted”, together with a fixed label describing which button or
enquiry category it was. The same kind of counter records how far down a page was
scrolled (in quarters), which FAQ question, tab or menu was opened, which other
website a link led to (its domain), that a file was downloaded, and that a form was
started, sent or rejected (with an error category, never the content).
These are counters: they carry no name, e-mail
address, file name, scan metadata, or anything you typed, and they are not
linked to your account. Each visit is also labelled with whether the browser was
signed in (yes or no) and, when you arrive through a link that carries campaign tags
(such as utm_source) or from another website, with those tags and that
website’s domain; and Umami measures how quickly each page loaded. Before anything
is sent, e-mail addresses, codes and tokens are removed from the page address.
Umami sets no cookies, stores nothing in your browser, and does not build
cross-site profiles or advertising audiences. The data involved is limited
to aggregate usage information such as the page URL, referrer, coarse browser/device class,
page-load timings, and the interaction counters and visit labels described above. Pages that
carry a secret in their URL — account-activation and password-reset links — are
deliberately excluded from analytics entirely.
Your IP address reaches Umami’s servers in transit. According to Umami’s privacy policy, it is
used to derive country-level statistics and is not retained. The statistics never include your imaging data, account data, or anything you upload. See
Umami's privacy policy for details.
cloud.umami.is) for cookieless usage analytics, without advertising networks or cross-site tracking. See Section 7.Imaging data and account data are hosted on servers within the European Economic Area (EEA). Routine transfers outside the EEA are limited to three things: billing data sent to Stripe, which may be processed in the US under the EU-US Data Privacy Framework and Standard Contractual Clauses; the aggregate, cookieless usage statistics processed by our analytics provider Umami (Section 7); and the single sign-up IP lookup described above, which may be answered outside the EEA. None of these include imaging data or uploads. No imaging data is transferred outside the EEA.
X-Content-Type-Options, X-Frame-Options, Referrer-PolicyWe may update this policy to reflect changes in law, our practices, or our services. Material changes will be communicated via email (if you have notifications enabled) and by updating the "Effective date" at the top; where a change is significant we will ask you to review it again the next time you sign in.
This document is a privacy notice: it tells you what we do and why. Creating an account, or continuing to use the platform, means you acknowledge you have received it — it is not itself the legal basis for anything described here. Each purpose stands on the basis named for it in Section 4, and the purposes that require your consent (the newsletter, job notification emails, and the per-job research opt-in) are always asked for separately and can be withdrawn without affecting your account.
For all privacy-related queries, requests to exercise your rights, or to report a concern: