Privacy policy

Last updated: September 23, 2026

1. Data controller

Controller: ETER ORIGIN CORP.
Registered address: 30 North Gould Street, Suite R, Sheridan, Wyoming 82801, United States.
Operating office: 7508 Gathering Dr., Suite 1, Celebration, FL 34747, United States.
Contact: through the contact form, by post to the operating office, or at the email address listed in the Legal notice.

This policy explains how we process the personal data of people who visit nulbix.com or contact us, in accordance with Regulation (EU) 2016/679 (GDPR) and Spanish Organic Law 3/2018 on the Protection of Personal Data and Guarantee of Digital Rights (LOPDGDD).

2. What data we process

We process the data you provide when you write to us through the contact form: name, email address, name of your clinic or company (optional) and the content of your message. Form messages are stored on our website and emailed to us so that we can reply. This website has no registration forms and no analytics or advertising tools.

3. Why we process your data and on what legal basis

To answer your questions and information requests: legal basis, taking steps at your request prior to entering into a contract (art. 6.1.b GDPR) and our legitimate interest in replying to those who write to us (art. 6.1.f GDPR).
To send you commercial information about Nulbix: only with your consent (art. 6.1.a GDPR), which you can withdraw at any time.
To provide the service to our clients and manage the contract, billing and support: legal basis, performance of the contract (art. 6.1.b GDPR) and compliance with legal obligations (art. 6.1.c GDPR).

4. Patient data within the Nulbix service

When a clinic subscribes to Nulbix, ETER ORIGIN CORP. processes the data of that clinic’s patients or customers (for example, name, phone number, messages and appointments) solely on behalf of the clinic and following its instructions, as a data processor (art. 28 GDPR), under the data processing agreement signed with it.

In that case, the clinic is the data controller. Patients can exercise their rights with the clinic; if they contact us instead, we will forward their request to the clinic.

5. How long we keep the data

Enquiries and sales contacts: for a maximum of 2 years from the last contact.
Clients: for the duration of the contract and, afterwards, for the legal limitation periods and the periods required to keep accounting and tax records, up to a maximum of 10 years.

6. Who we share the data with

We do not sell or share personal data with third parties, except where required by law. To provide our services we rely on technology providers (web hosting, email, cloud infrastructure and payment processing) acting as data processors, under contract and with appropriate safeguards.

7. International transfers

ETER ORIGIN CORP. is established in the United States, so your data may be processed outside the European Economic Area. These transfers are carried out with the safeguards provided for in Chapter V of the GDPR —such as the standard contractual clauses approved by the European Commission or the recipient’s participation in the EU-U.S. Data Privacy Framework— or, where applicable, under article 49.1.b and 49.1.c GDPR, because they are necessary for the performance of a contract or of pre-contractual steps taken at your request.

8. Your rights

You can exercise your rights of access, rectification, erasure, restriction of processing, objection and portability, and withdraw your consent, by writing to us through the contact form or by post to the operating office, and stating which right you wish to exercise. If needed to verify your identity, we may ask you for an identification document.

If you believe we have not processed your data correctly, you can lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) or with the supervisory authority of your country.

9. Security

We apply appropriate technical and organizational measures to protect personal data against loss, unauthorized access or alteration, including encryption of communications with this website (HTTPS).

10. Changes to this policy

We may update this policy to reflect legal changes or changes to our services. The version in force is the one published on this page, with its update date.