PRIVACY POLICY

Last Updated: December 7, 2025

1. INTRODUCTION

PABLO AI, Inc. ("Pablo," "we," "us," or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Pablo mobile application and related services (collectively, the "Service").

Please read this Privacy Policy carefully. By accessing or using the Service, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and our Terms and Conditions. If you do not agree with this Privacy Policy, please do not use the Service.

2. INFORMATION WE COLLECT

We collect information that you provide directly, information collected automatically, and information from third-party sources.

2.1 Personal Information You Provide

Account Information:

Payment Information:

Profile and Preferences:

User Content:

2.2 Information Collected Automatically

Usage Data:

Device Information:

Location Information:

Cookies and Similar Technologies:

2.3 Information from Third Parties

Authentication Providers:

Social Features:

Public Sources:

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

3.1 Provide and Maintain the Service

3.2 AI Processing and Personalization

Google Gemini LLM Processing:
We share the following information with Google's Gemini AI models to power Pablo's core functionality:

Google processes this data in accordance with their privacy policy and terms of service. We use Google's Gemini Flash and Pro models for vision and text processing.

3.3 Improve and Develop the Service

3.4 Communications

3.5 Business Operations and B2B Services

Pablo Intelligence Platform:
We may use aggregated and, when possible, anonymized data to provide insights to business partners, including:

Types of data shared for B2B services:

3.6 Legal and Safety

4. HOW WE SHARE YOUR INFORMATION

We share your information with the following categories of recipients:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

Clerk (Authentication):

Convex (Backend and Database):

Google Gemini (AI Processing):

Sentry (Error Tracking and Monitoring):

Apple App Store (Payments):

4.2 Business Partners (B2B Services)

With your consent or as permitted by law, we may share data with:

Data shared for B2B purposes will be aggregated and anonymized where possible. We will obtain your explicit consent before sharing identifiable data with business partners.

4.3 Social Features

4.4 Legal Requirements and Protection

We may disclose your information if required to do so by law or in response to:

4.5 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you via email and/or prominent notice on the Service of any change in ownership or use of your personal information.

4.6 With Your Consent

We may share your information with third parties when you give us explicit consent to do so.

5. DATA RETENTION

We retain your personal information for as long as necessary to provide the Service and fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Retention Periods:

When we no longer need your personal information, we will securely delete or anonymize it.

6. YOUR RIGHTS AND CHOICES

Depending on your location, you may have certain rights regarding your personal information.

6.1 Access and Portability

You have the right to:

How to exercise: Contact us at support@getpablo.ai with a data access request.

6.2 Correction and Update

You have the right to:

How to exercise: Update your information through account settings or contact support@getpablo.ai.

6.3 Deletion (Right to be Forgotten)

You have the right to:

How to exercise: Delete your account through account settings or contact support@getpablo.ai. Note that some information may be retained as required by law or for legitimate business purposes.

6.4 Object to Processing

You have the right to:

How to exercise: Adjust privacy settings, use unsubscribe links in emails, or contact support@getpablo.ai.

6.5 Restrict Processing

You have the right to:

How to exercise: Contact support@getpablo.ai with details of your restriction request.

6.6 Automated Decision-Making

Our AI-powered recommendations constitute automated decision-making. You have the right to:

How to exercise: Contact support@getpablo.ai for information about our AI decision-making processes.

6.7 Marketing Communications

You may opt out of marketing communications by:

Note: You cannot opt out of service-related communications (e.g., account verification, transaction confirmations, technical updates).

6.8 Cookie Preferences

You may manage cookie preferences through:

Note: Disabling certain cookies may limit functionality of the Service.

7. SPECIAL INFORMATION FOR EUROPEAN USERS (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR).

7.1 Legal Basis for Processing

We process your personal information based on the following legal grounds:

7.2 International Data Transfers

We are based in the United States. Your personal information may be transferred to, stored, and processed in the United States and other countries where our service providers operate.

When we transfer personal information outside the EEA, UK, or Switzerland, we ensure appropriate safeguards are in place, including:

7.3 Data Protection Officer

For GDPR-related inquiries, you may contact our Data Protection Officer at:
Email: support@getpablo.ai

7.4 Supervisory Authority

You have the right to lodge a complaint with a supervisory authority in your country of residence, place of work, or where an alleged infringement of GDPR occurred.

7.5 Age Requirements under GDPR

The Service is not intended for children under 16 in the EEA/UK. If we discover we have collected personal information from a child under 16 without parental consent, we will delete that information promptly.

8. CALIFORNIA RESIDENTS (CCPA/CPRA)

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

8.1 Categories of Information Collected

We collect the following categories of personal information (refer to Section 2 for details):

8.2 California Privacy Rights

California residents have the right to:

8.3 Do Not Sell or Share

We do not "sell" personal information in the traditional sense. However, sharing data with third parties for analytics or advertising may constitute "sharing" under California law.

To opt out: Email support@getpablo.ai with "California Do Not Share" in the subject line.

8.4 Shine the Light

California residents may request information about disclosure of personal information to third parties for their direct marketing purposes. Email support@getpablo.ai with "California Shine the Light Request."

8.5 Authorized Agents

You may designate an authorized agent to make requests on your behalf. We may require verification of the agent's authority.

9. CHILDREN'S PRIVACY

The Service is not intended for individuals under the legal drinking age in their jurisdiction. We do not knowingly collect personal information from children under the age of 21 (or the applicable legal drinking age).

If you are under the legal drinking age, do not use the Service or provide any personal information.

If we discover that we have collected personal information from a child under the legal drinking age without proper verification, we will delete that information promptly. If you believe we have collected information from a child, please contact us at support@getpablo.ai.

10. DATA SECURITY

We implement reasonable technical, administrative, and physical security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction.

Security measures include:

However, please note:

If we become aware of a data breach that affects your personal information, we will notify you and relevant authorities as required by applicable law.

11. THIRD-PARTY SERVICES AND LINKS

The Service may contain links to third-party websites, applications, or services that are not operated or controlled by Pablo.

Important notes:

Third-party services we integrate with:

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors.

Notice of changes:

Your continued use of the Service after the effective date of the updated Privacy Policy constitutes acceptance of the changes. If you do not agree to the updated Privacy Policy, you must stop using the Service and may delete your account.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

13. CONTACT US

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

PABLO AI, Inc.

Email:
support@getpablo.ai

For specific requests, please include the request type in your subject line:

Mailing Address:
PABLO AI, Inc.
Attn: Privacy Department
1111b S Governors Ave STE 48042
Dover, DE 19904
United States

Website: https://getpablo.app

14. ADDITIONAL INFORMATION

14.1 Language

This Privacy Policy is provided in English. In case of discrepancies between translations, the English version shall prevail.

14.2 Accessibility

We are committed to making this Privacy Policy accessible. If you have difficulty accessing this Privacy Policy, please contact support@getpablo.ai.

14.3 Accountability

We are committed to accountability and compliance with applicable privacy laws. We maintain documentation of our data processing activities and conduct regular privacy assessments.

By using the Pablo Service, you acknowledge that you have read, understood, and agree to this Privacy Policy.

For California residents: You may have additional rights under California law. See Section 8 for details.

For European residents: You have rights under the GDPR. See Section 7 for details.