Draft, pending legal review. This text has been prepared for the website and has not been approved by counsel.
Privacy policy
This policy describes how NivaxTel handles information collected through the website.
Who is responsible
The website at nivaxtel.com is published by Nivax International Inc., IBC registration number 075009, of 105 1st Floor, Waterside, Eden Island, Seychelles. The trading brand is NivaxTel. Whether the company is a “controller”, a “business” or some other legal category depends on the law that applies. That characterisation is to be confirmed.
What this draft covers
It covers the public website: the pages, the enquiry form, human verification, email delivery of an enquiry, and the logs produced by hosting. Call recordings, message content and customer traffic from a wholesale service sit outside this policy. A future service would have its own terms.
Enquiry form
When the form is switched on, a person can send a name, a company, an email address, an optional phone number, a service subject (Voice, SMS, Both or Other) and a message. A hidden field is included so that automated submissions can be ignored. If that field is filled in, the submission is discarded and is not emailed.
The form is disabled unless its mail and verification settings are all present. While it is disabled, visitors are not asked to send those details to another address. The billing address is not a substitute inbox.
Human verification
The form uses Cloudflare Turnstile in Managed mode. The browser loads a script and a frame from Cloudflare’s challenge service, and the server checks the resulting token with Cloudflare before any email is sent. The check includes the visitor’s connecting IP address, as provided by Cloudflare, and a one-time key. A missing, empty, invalid, expired or already-used token is rejected. The token is not kept as a marketing record. Cloudflare’s own handling of that check is described in Cloudflare’s privacy notice. The legal terms of that processing are to be confirmed.
Email delivery
If the checks succeed, the enquiry is sent as plain text through the Resend email service to an address configured for NivaxTel. That recipient is not published on the website and it is not the billing address. The visitor’s email is used as the reply-to address. Resend processes the message in order to deliver it. The places where that delivery is processed, and the contract terms that apply, are to be confirmed.
Hosting and server logs
The site is hosted on Cloudflare Pages. Cloudflare processes requests in order to serve the pages and to protect them. A typical request log can include the IP address, user agent, the address of the page, and the time of the request. NivaxTel does not add an analytics product, an advertising script or a tracking pixel of its own. How long Cloudflare keeps those logs, and in which countries, is to be confirmed.
Abuse limiting
The enquiry endpoint keeps a short-lived count of recent requests in the memory of the server instance that received them, keyed by connecting IP address. The count is used only to slow repeated submissions. It is not a database, it is not shared reliably across the network, and it is lost when that instance stops. Retention of that count is the life of the instance. No longer period is set in this policy.
Billing address
[email protected] is published as the billing contact of Nivax International Inc.. Mail sent there is correspondence about billing. It is not the destination of the enquiry form, and it is not a privacy inbox. A privacy contact is to be confirmed.
Other practices
- It does not sell personal information.
- It does not run advertising or third-party analytics.
- It does not ask for an account or a password.
- No telephone number is published.
How long information is kept
Retention period: to be confirmed. This draft does not state a number of days, months or years as if it were already decided. Until a period is confirmed, enquiries that are actually delivered would sit in the mailbox of the configured recipient, and hosting logs would sit with Cloudflare under Cloudflare’s own practices.
Where processing takes place
Nivax International Inc. is registered in Seychelles. Cloudflare and Resend may process website data in other countries. The list of those countries, and any transfer terms, are to be confirmed.
Legal basis
The legal basis for processing depends on the law that applies to Nivax International Inc. and to the person writing in. That basis is to be confirmed. No specific statutory ground is named here.
Requests from individuals
A data-protection officer has not been designated. A separate privacy mailbox has not been designated. Both are to be confirmed. Access, correction and deletion will be handled once a process exists. The procedure is to be confirmed. Until a privacy contact is confirmed, the company can be reached at its registered office: 105 1st Floor, Waterside, Eden Island, Seychelles.
Children
The website is written for telecommunications businesses. It is not directed at children, and the enquiry form is not intended for them.
Changes
This text is a draft dated for the website build. It will change if counsel revises it or if the form’s processing changes. The page that is published is the current draft.
