Pablo-ai.com (referred to as "we," "us," or "our"), recognizes the importance of protecting your personal information. This Privacy Policy outlines our commitment to safeguarding the privacy of personal information provided to us or collected by us during our interactions with you.

This Privacy Policy complies with the requirements of applicable data protection laws, including the General Data Protection Regulation 2016/679 (GDPR). It also addresses the rights of individuals located in the European Union (EU) and the European Economic Area (EEA).

This Privacy Policy was last updated on 20 August 2024.

### The Information We Collect

**Personal Information**: Personal information is any information or opinion, whether true or not and whether recorded in material form or not, about an individual who is identified or reasonably identifiable.

The types of personal information we may collect about you include:

- **Identity Data**: Your full name, age, profession, and gender.
- **Contact Data**: Your telephone number, address, and email.
- **Financial Data**: Bank account and payment card details (through our third-party payment processor, who stores such information, and we do not have access to it).
- **Transaction Data**: Details about payments to you from us, payments you make to us, and other details of products and services you have purchased from us or we have purchased from you.
- **Technical and Usage Data**: Information when you access our websites or platforms, including your internet protocol (IP) address, login data, browser session and geo-location data, statistics on page views and sessions, device and network information, acquisition sources, search queries, browsing behavior, access and use of our website (including through the use of Internet cookies), and communications with our website.
- **Profile Data**: Your username and password for Pablo-ai.com, profile picture, purchases or orders you have made with us, content you post, send, receive, and share through our platform, information you have shared with our social media platforms, and support requests you have made.
- **Interaction Data**: Information you provide when you participate in any interactive features, including surveys, contests, promotions, activities, or events.
- **Marketing and Communications Data**: Your preferences in receiving marketing from us and third parties and your communication preferences.
- **Professional Data**: Where you are an employee or applying for a role with us, your professional history, including previous positions and professional experience.
- **Sensitive Information**: This subset of personal information is subject to higher protection levels. It includes information about your racial or ethnic origin, political opinions, religion, trade union or professional memberships, philosophical beliefs, sexual orientation or practices, criminal records, health information, or biometric information. We do not actively request sensitive information about you. If we need to collect sensitive information, we will first obtain your consent unless otherwise permitted by law and will only use it as required or authorized by law.

### How We Collect Personal Information

We collect personal information in various ways, including:

- When you provide it directly to us, whether face-to-face, over the phone, via email, or online;
- When you complete a form, such as registering for events or newsletters or responding to surveys;
- When you use any website we operate (including analytics and cookie providers or marketing providers);
- From third parties; or
- From publicly available sources.

### Why We Collect, Hold, Use, and Disclose Personal Information

Purpose of Use/Disclosure	Type of Personal Information
To enable you to access and use our platform, including to provide you with a login.	Identity Data, Contact Data
To contact and communicate with you about our business, including in response to any support requests or other inquiries.	Identity Data, Contact Data, Profile Data
To contact and communicate with you about any inquiries via our website.	Identity Data, Contact Data
For internal record keeping, administrative, invoicing, and billing purposes.	Identity Data, Contact Data, Financial Data, Transaction Data
For analytics, market research, and business development, including to operate and improve our business and associated social media platforms.	Profile Data, Technical and Usage Data
For advertising and marketing, including to send you promotional information about our events and experiences.	Identity Data, Contact Data, Technical and Usage Data, Profile Data, Marketing and Communications Data
To run promotions, competitions, and/or offer additional benefits to you.	Identity Data, Contact Data, Profile Data, Interaction Data, Marketing and Communications Data
If you have applied for employment, to consider your application.	Identity Data, Contact Data, Professional Data
To comply with legal obligations or as required/authorized by law.	Any relevant Personal Information
Sensitive information: We do not actively request sensitive information. If needed, we will first obtain your consent unless otherwise permitted by law.	Sensitive Information

### Our Disclosures of Personal Information to Third Parties

We will only disclose personal information (excluding sensitive information) to third parties when necessary for our business, with your consent, or where permitted by law. This may include:

- Our employees, contractors, and/or related entities;
- IT service providers, data storage, web-hosting, and server providers;
- Marketing or advertising providers;
- Professional advisors, bankers, auditors, insurers, and insurance brokers;
- Payment systems operators or processors;
- Our existing or potential agents or business partners;
- Sponsors or promoters of any promotions or competitions we run;
- If we merge with or are acquired by another Pablo-ai.com, or sell all or part of our assets, your personal information may be disclosed to our and any prospective purchaser’s advisors and may be among the transferred assets;
- Courts, tribunals, regulatory authorities, and law enforcement officers, as required or authorized by law, in connection with any legal proceedings, or to establish, exercise, or defend our legal rights;
- Third parties to collect and process data, such as analytics providers and cookies; and
- Any other third parties as required or permitted by law.

**Sensitive Information**: We will only disclose sensitive information with your consent or where permitted by law. This may include the same parties as listed above.

### Overseas Disclosure

We store your personal information in Bulgaria. Where we disclose your personal information to third parties, those third parties may store, transfer, or access personal information outside of Bulgaria. We will only disclose your personal information overseas in accordance with applicable data protection laws.

### Your Rights and Controlling Your Personal Information

**Your Choice**: By providing personal information to us, you understand that we will collect, hold, use, and disclose your personal information in accordance with this Privacy Policy. You do not have to provide personal information to us, but if you do not, it may affect our ability to do business with you.

**Information from Third Parties**: If we receive personal information about you from a third party, we will protect it as set out in this Privacy Policy. If you are a third party providing personal information about someone else, you represent and warrant that you have that person’s consent to provide their personal information to us.

**Restrict and Unsubscribe**: To object to processing for direct marketing or to unsubscribe from our email database, or opt out of communications (including marketing), please contact us using the details below or opt out using the facilities provided in the communication.

**Access**: You may request access to the personal information we hold about you. An administrative fee may apply for providing this information. In some cases, we may be legally permitted to withhold access to your personal information. If we cannot provide access, we will inform you as soon as possible and explain the reasons and any available complaints mechanisms.

**Correction**: If you believe any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us. We will take reasonable steps to correct any information found to be inaccurate, out of date, incomplete, irrelevant, or misleading. In some situations, we may be legally permitted to not correct your personal information. If we cannot correct your information, we will inform you as soon as possible and explain the reasons and any available complaints mechanisms.

**Complaints**: If you wish to make a complaint, please contact us with full details of the complaint. We will promptly investigate and respond in writing with the outcome and any steps we will take. If you are not satisfied with our response, you may contact the relevant data protection authority in Bulgaria.

### Storage and Security

We are committed to ensuring that the personal information we collect is secure. We have put in place suitable physical, electronic, and managerial procedures to safeguard and secure personal information from misuse, interference, loss, unauthorized access, modification, and disclosure.

While we strive to protect your personal information, we cannot guarantee the security of any information transmitted to or from us over the Internet. Such transmissions are at your own risk.

### Cookies

We may use cookies on our website to enhance your experience. Cookies are text files placed in your browser to store your preferences. They do not provide us with your email address or other personally identifiable information. However, cookies recognize you when you return to our website and allow us to display targeted advertisements. You can block cookies by adjusting your browser settings. Blocking cookies may affect your ability to access parts of our website.

### Links to Other Websites

Our website may contain links to other websites. We do not control these websites and are not responsible for the protection and privacy of any personal information you provide while visiting those websites. These websites are not governed by this Privacy Policy.

### Personal Information from Single Sign-On Accounts

If you connect your account with us using a single sign-on account (e.g., Apple, Facebook, Google), we will collect personal information from the provider according to your privacy settings. This may include your name, ID, username, handle, profile picture, gender, age, language, friends or follows list, and any other personal information you choose to share. We use this information to create a profile for you on our platform. If we receive personal information through Facebook, you have the right to request its deletion by contacting us.

### Use of Google API Services

We use Google’s API Services to collect non-identifiable analytics data. Our use of Google API Services adheres to the Google API Services User Data Policy, including the Limited Use requirements. We limit our use of personal information to providing or improving our business. We only transfer personal information to others if necessary for these purposes or as required by law. We do not use or transfer personal information for serving ads. We have safeguards in place to protect your personal information obtained through Google APIs.

### Amendments

We may update this Privacy Policy at any time by posting the amended Privacy Policy on our website. Please check our website regularly to stay informed of any changes.

For any questions or notices, please contact us at:

Pablo-ai.com

Email: privacy@pablo-ai.com

### APPENDIX 1: ADDITIONAL RIGHTS AND INFORMATION FOR INDIVIDUALS LOCATED IN THE EU OR UK

Under the GDPR, individuals in the EU and UK have additional rights regarding their personal information, often referred to as personal data. This Appendix outlines these rights and provides information on how we process personal data for individuals in the EU and UK. Please read this Privacy Policy and Appendix carefully and contact us if you have any questions.

#### What Personal Information Is Relevant?

This Appendix applies to the personal information outlined in the Privacy Policy above, including any Sensitive Information (referred to as "special categories of data" under the GDPR).

#### Purposes and Legal Bases for Processing

We collect and process personal information about you only where we have legal bases for doing so under applicable laws. Below is a table describing all the ways we plan to use your personal information and the legal bases we rely on. We also identify our legitimate interests where appropriate. We may process your personal information for more than one lawful ground depending on the specific purpose.

Purpose of Use/Disclosure	Type of Data	Legal Basis for Processing
To enable you to access and use our platform, including to provide you with a login.	Identity Data, Contact Data	Performance of a contract with you
To contact and communicate with you about our business, including in response to any support requests or other inquiries.	Identity Data, Contact Data, Profile Data	Performance of a contract with you
To contact and communicate with you about any inquiries via our website.	Identity Data, Contact Data	Legitimate interests: to provide the best client experience by answering all your questions
For internal record keeping, administrative, invoicing, and billing purposes.	Identity Data, Contact Data, Financial Data, Transaction Data	Performance of a contract with you, Compliance with a legal obligation, Legitimate interests: to recover debts and notify you of changes to our terms
For analytics, market research, and business development, including to operate and improve our business and associated social media platforms.	Profile Data, Technical and Usage Data	Legitimate interests: to keep our website updated, develop our business, and inform our marketing strategy
For advertising and marketing, including to send you promotional information about our events and experiences.	Identity Data, Contact Data, Technical and Usage Data, Profile Data, Marketing and Communications Data	Legitimate interests: to develop and grow our business
To run promotions, competitions, and/or offer additional benefits to you.	Identity Data, Contact Data, Profile Data, Interaction Data, Marketing and Communications Data	Legitimate interests: to engage with and grow our business
If you have applied for employment, to consider your application.	Identity Data, Contact Data, Professional Data	Legitimate interests: to consider your employment application
To comply with legal obligations or as required/authorized by law.	Any relevant data	Compliance with a legal obligation

If you have consented to our use of data for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing already carried out. Where we rely on legitimate interests for processing, you have the right to object, though this may affect our ability to do business with you.

### Data Transfers

The privacy protections in the countries to which we transfer data may be less comprehensive than those in the country where you initially provided the information. We will protect your personal information in accordance with this Privacy Policy and applicable data protection laws, including:

- Only transferring your personal information to countries deemed to provide adequate protection under applicable laws; or
- Including standard contractual clauses in our agreements with third parties overseas.

### Data Retention

We will retain your personal information only as long as necessary to fulfill the purposes for which it was collected, including legal, regulatory, tax, accounting, or reporting requirements. We may retain your personal information for a longer period if necessary for legal purposes.

To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal information, potential risks of harm from unauthorized use or disclosure, the purposes for processing, and applicable legal requirements.

### Extra Rights for EU and UK Individuals

You may request details of the personal information we hold about you and how we process it (a "data subject request"). You may also have the right to have your personal information rectified or deleted, restrict processing, object to decisions based on automated processing, stop unauthorized transfers, and in some cases, transfer your personal information to another organization.