Terms of Service

By accessing the website nuinalp.com, creating a Nuinalp Account, and/or subscribing to any services offered by Nuinalp, including paid plans such as Nuinalp VPN, you agree to these Terms of Service, which govern the use of the services and products operated by Nuinalp LTDA, a Brazilian company headquartered at Rua Doutor Lindolfo Mattos Freitas, No. 118, Centro, Tremembé, State of São Paulo, ZIP Code 12120-083, Brazil.

Throughout these Terms, Nuinalp LTDA may be referred to as “Nuinalp,” “we,” “us,” or “our.”

These Terms enter into force upon acceptance and remain valid for as long as the user uses the Services.

1. Definitions

For the purposes of these Terms, the expressions below shall have the following meanings, whether used in the singular or plural:

• “Account” means the individual account created by the user to access Nuinalp Services.
• “Services” means all products, features, applications, websites, and solutions offered by Nuinalp, including, where applicable, VPN services and security and privacy tools.
• “User” means any individual or legal entity that accesses, uses, or creates an Account with Nuinalp.
• “Content” means any data, information, or materials transmitted, processed, or stored by the user through the Services.
• “Personal Data” means any information relating to an identified or identifiable natural person, as defined by applicable law.
• “Subscription” means any paid plan contracted by the user to access specific Service features.
• “Nuinalp” means Nuinalp LTDA, the legal entity responsible for operating the Services.

2. Use of Services and Products

The Services are available only to individuals who are at least 18 (eighteen) years old, or the equivalent legal age in their jurisdiction, and who have legal capacity to enter into this agreement.

The creation or use of Accounts through bots, scripts, or automated methods is prohibited. Accounts identified under such conditions may be suspended or terminated.

The user is fully responsible for all activity carried out through their Account, including access by third parties authorized by the user.

3. Description of the Services

Nuinalp provides digital security and privacy solutions. These Terms apply to all services currently offered and to those that may be made available in the future through the Nuinalp Account.

Nuinalp may add, modify, or discontinue features, respecting the acquired rights of users with active Subscriptions.

4. Authorized Use and Prohibited Activities

You agree not to use the Services for unlawful or prohibited activities. Prohibited activities include, but are not limited to:

• Illegal activities: accessing, sharing, downloading, uploading, or storing any content that violates local or international laws, including child sexual abuse material (CSAM) or piracy.
• Network abuse: conducting denial-of-service (DDoS) attacks, hacking, or interfering with Nuinalp’s or third-party infrastructure.
• Spam: sending unsolicited bulk communications or irrelevant content, typically to a large number of recipients, especially for advertising, phishing, or malware/virus distribution.
• Multiple free accounts: creating multiple free accounts to circumvent usage limits or obtain undue benefits, whether manually or automatically, including mass registrations or operating a large number of free accounts by a single individual or organization.
• Resale: selling, trading, or transferring ownership of an Account to third parties.
• Payments: paying for subscriptions using fraudulent payment methods, such as stolen credit cards.
• Referrals: referring yourself or another Account under your ownership to obtain undue benefits from referral programs.
• Unauthorized access: attempting to access, probe, or connect to computing devices without proper authorization.
• Third-party rights violations: infringing copyrights, trademarks, or other third-party rights.
• Reverse engineering / technical abuse: attempting reverse engineering, vulnerability exploitation, or misuse of Nuinalp’s infrastructure.

Any violation may result in immediate suspension or termination of the Account or the application of appropriate measures, including restriction of specific features or functionalities.

Nuinalp may also suspend or terminate Accounts used for any illegal activities, even if not listed above, particularly to comply with orders from competent authorities.

We reserve the right to limit service capacity for free Accounts whose usage unfairly impacts other users’ experience, such as mass downloads or excessive bandwidth consumption.

If you wish to contest an Account suspension, please contact abuse@nuinalp.com.

Nuinalp does not actively monitor traffic content but may take action upon substantiated reports or legal orders.

5. Inactive Accounts

Nuinalp reserves the right to delete free Accounts that remain inactive for a consecutive period of 12 (twelve) months or more, together with some or all associated data or content, in accordance with this section.

If your free Account remains inactive for 12 (twelve) consecutive months or more, access to the Account and some or all of its data may be permanently deleted. Email notices for Account recovery will be sent 30, 15, 7, 3, and 1 day(s) prior to automatic deletion.

Accounts with an active Subscription are always considered active and will not be affected. However, cancellation of the Subscription and/or reclassification of a paid Account to a free Account, including due to non-payment, will make the Account subject to this policy.

A free Account is considered active if at least one of the following actions is performed within each 12 (twelve)-month period:

• Logging into the Account via any of our web, desktop, or mobile applications;
• Using one of our products while authenticated, such as connecting to a VPN server.

If you are subject to conditions that prevent login or use of any Service, please contact support at support@nuinalp.com.

Data deletion will comply with legal data retention obligations under applicable law.

6. Nuinalp VPN and “No-Logs” Policy

For the VPN service, Nuinalp adopts a strict no-logs policy. We do not monitor, log, or store browsing history, traffic destinations, data content, or DNS queries.

• Resource usage: we reserve the right to limit capacity for free Accounts whose bandwidth usage is excessive and negatively affects other users’ experience.

The no-logs policy applies to traffic content. Nuinalp may process minimal technical data required for authentication, abuse prevention, and legal compliance, as described in the Privacy Policy.

7. Payments, Refunds, and Cancellations

• Subscriptions: paid plans are automatically renewed at the end of each billing period (monthly, semiannual, or annual), unless canceled by the user.
• Refunds: In accordance with the Brazilian Consumer Protection Code (Law No. 8,078/1990), users are entitled to withdraw and receive a full refund within 7 (seven) days from the initial purchase date, where applicable. For users located outside Brazil, different deadlines may apply according to local legislation, such as the 14 (fourteen)-day period provided in the European Union. As an additional and voluntary commercial policy, Nuinalp offers an extended refund period of up to 45 (forty-five) days for the first purchase of a paid plan, with no mandatory justification required. Refunds will be processed through the same payment platform used for the purchase, in a simple and direct manner. Nuinalp may optionally request the reason for the refund solely for statistical and service improvement purposes, without affecting or conditioning approval of the refund. To preserve service sustainability and prevent abuse, Nuinalp reserves the right to deny refund requests in cases of evident abuse, such as multiple recurring refund requests by the same user, misuse of the refund policy, or violation of these Terms.
• Non-payment: payment failures may result in Account downgrade to the free plan or temporary suspension of Services.

Amounts may include taxes as required by applicable law. Payments may be processed by third-party intermediaries subject to their own terms.

8. Plan Changes and Billing Cycle

Plan Changes (Upgrade or Downgrade)

Users may request a Subscription plan change at any time, whether to a higher-tier plan (upgrade) or lower-tier plan (downgrade), subject to the conditions below.

In the case of an upgrade to a higher-value paid plan, the change will take effect immediately. The unused proportional value already paid for the previous plan will be automatically credited at billing time and deducted from the total cost of the new plan. The user will be charged only the price difference, considering the remaining Subscription period.

Nuinalp does not use internal credit systems for upgrades, always applying direct compensation to the billing amount in a transparent and immediate manner.

In the case of a downgrade, the change will take effect at the end of the current billing cycle. To avoid loss of features or data, the user is responsible for adjusting service usage in advance to the limits of the newly selected plan, including, where applicable, removing features exclusive to paid plans.

Nuinalp will not automatically remove user data, features, or content to adapt Accounts to free or lower-tier plans.

Plan Cancellation

If the user does not wish to renew the Subscription automatically, they must request a downgrade or cancellation before the end of the current plan period. Cancellation does not immediately interrupt access to paid services, which will remain available until the end of the already paid billing cycle, unless otherwise required by law.

Billing Cycle Changes

If the user chooses to change the Subscription billing cycle (e.g., from monthly to annual), the change will take effect at the end of the current billing cycle and apply to the subsequent period.

9. Service Level Agreement (SLA) and Service Availability

Nuinalp commits to using its best efforts to provide stable, secure, and reliable services, targeting a monthly availability of 99.95%, calculated on a calendar-month basis. This commitment represents an operational goal and reflects Nuinalp’s continuous efforts to maintain consistent Service operation, subject to the terms, limitations, and exclusions described in this Service Level Agreement (SLA).

If total Service downtime in a given month exceeds 0.05% of the monthly period, the user may request service credits, which will be applied to the Account and offset against the next billing cycle, whether monthly or annual. Credits will be calculated as follows:

• (i) if monthly availability is below 99.95% and equal to or above 99.0%, the credit will equal 10% of the affected Service’s monthly fee;
• (ii) if monthly availability is below 99.0%, the credit will equal 30% of the affected Service’s monthly fee.

For SLA purposes, the following events shall not be considered downtime, including but not limited to:

(a) failures or interruptions caused by factors beyond Nuinalp’s reasonable control; (b) issues resulting from actions or omissions by the user or third parties; (c) failures related to third-party equipment, networks, or services used by the user, including internet providers or external infrastructure; (d) suspensions or interruptions carried out in compliance with these Terms; and (e) scheduled maintenance periods, provided reasonable advance notice is given.

The user acknowledges that certain Nuinalp Services may depend partially or entirely on third-party infrastructure, connectivity, storage, or other providers. In such cases, unavailability or performance degradation caused by these third parties does not constitute an SLA breach, provided Nuinalp has taken reasonable measures to mitigate the impact.

This SLA does not constitute an absolute guarantee of continuous or uninterrupted availability but defines the objective parameters of Nuinalp’s commitment and the limits of its liability regarding Service availability.

10. Limitation of Liability

The Services are provided “as is.” While we strive for the highest level of security, Nuinalp does not guarantee that the Services will be uninterrupted or error-free.

• Loss of access: in services using end-to-end encryption or zero-knowledge architecture, Nuinalp does not have access to user passwords. If a password is lost, data recovery will not be possible.
• Damages: to the maximum extent permitted by law, Nuinalp shall not be liable for indirect or incidental damages or data loss resulting from the use of the Services. Nuinalp’s total liability shall not exceed the amount paid by the user in the last 12 (twelve) months.

Nothing in these Terms excludes or limits consumer rights provided under the Brazilian Consumer Protection Code.

11. Intellectual Property

All Nuinalp logos, code, trademarks, and designs are the exclusive property of the company. Use of the Services does not grant the user any intellectual property rights over these assets.

Use of Nuinalp trademarks, logos, or trade names without prior express authorization is prohibited.

“Nuinalp,” Nuinalp logos, and other trade names are trademarks or registered trademarks of Nuinalp LTDA.

12. Changes to the Terms

We reserve the right to amend these Terms at any time. Material changes will be communicated via email or website notice at least 30 (thirty) days in advance.

Changes that negatively impact paid plans will only take effect after the end of the current billing period.

13. Governing Law and Jurisdiction

These Terms are governed by and interpreted in accordance with the laws of the Federative Republic of Brazil.

For users residing in Brazil, the courts of the District of Tremembé, State of São Paulo, are elected, without prejudice to the consumer’s right to file claims in their domicile, as provided by the Consumer Protection Code.

For users residing outside Brazil, disputes shall be governed by private international law rules, and, to the extent permitted by applicable law, the courts of Tremembé, SP, Brazil, shall have jurisdiction, without prejudice to any mandatory jurisdiction provided by the user’s local law.

The parties shall use their best efforts to resolve disputes amicably before resorting to judicial measures.

14. Language

These Terms of Service are originally drafted in Portuguese (Brazil). If Nuinalp provides translated versions, such translations are for informational purposes only. In the event of any discrepancy, the English version shall prevail for all legal purposes.

15. Communications

By creating an Account or using the Services, the user agrees to receive necessary communications related to Account and Service operation, including security notices, technical notifications, Service or Terms changes, billing information, Account recovery, and legal communications.

Promotional or marketing communications, where applicable, will be sent only with the user’s consent, with the option to opt out at any time.

Nuinalp may use electronic means, such as email or in-platform notifications, as valid forms of communication. It is the user’s responsibility to keep contact information up to date.

16. Privacy and Personal Data

Nuinalp processes personal data in compliance with the Brazilian General Data Protection Law (Law No. 13,709/2018 – LGPD) and, where applicable, the European Union General Data Protection Regulation (GDPR).

Processing occurs exclusively for legitimate, specific, and necessary purposes related to Service provision, including Account creation and management, authentication, billing, support, platform security, fraud prevention, and legal compliance.

Nuinalp does not access, monitor, or analyze VPN-protected traffic content or encrypted data in services using end-to-end encryption. Minimal technical and administrative data may be processed as described in the Privacy Policy.

17. General Provisions

These Terms do not affect any statutory or legal consumer rights.

Headings are for organizational purposes only and do not affect interpretation.

Nuinalp’s failure to enforce any provision shall not constitute a waiver of rights.

Nuinalp may assign or transfer these Terms, in whole or in part, and delegate rights and obligations, including to service providers or partners, provided consumer rights and applicable legal obligations are preserved.

These Terms constitute the entire agreement between the user and Nuinalp, superseding all prior oral or written understandings, communications, or agreements relating to their subject matter.