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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:

  • Full name
  • Email address
  • Date of birth (to verify age requirements)
  • Username
  • Profile photo
  • Preferred language
  • Location (country/region)

Payment Information:

  • Payment information is processed through Apple's App Store
  • We do not directly collect or store your payment card details
  • We receive transaction confirmations from payment processors

Profile and Preferences:

  • Wine taste preferences and profile data
  • Dietary restrictions or allergies you choose to share
  • Privacy settings and communication preferences

User Content:

  • Photos of wine bottles, labels, wine lists, and shelves
  • Tasting notes and wine reviews
  • Ratings and recommendations
  • Chat messages with Pablo AI
  • Comments and social interactions
  • Wine cellar data and history

2.2 Information Collected Automatically

Usage Data:

  • Features used and time spent on the Service
  • Wines scanned, searched, or viewed
  • Recommendations requested and acted upon
  • Navigation patterns and clicked content
  • Session duration and frequency of use

Device Information:

  • Device type, model, and operating system
  • Unique device identifiers
  • Mobile network information
  • Device settings and preferences
  • App version

Location Information:

  • Approximate location based on IP address
  • Country and region information
  • Precise geolocation (only if you grant permission for location-based features)

Cookies and Similar Technologies:

  • We use cookies, pixels, and similar tracking technologies to collect usage data
  • These technologies help us understand user behavior, maintain sessions, and improve the Service

2.3 Information from Third Parties

Authentication Providers:

  • We use Clerk for authentication, which may provide us with your name, email, and profile information from your chosen authentication method (email, Apple, Google, etc.)

Social Features:

  • If you connect with friends or participate in Wine Circles, we may receive information about your connections and interactions

Public Sources:

  • Wine information, ratings, and reviews from public databases and wine industry sources

3. HOW WE USE YOUR INFORMATION

We use your information for the following purposes:

3.1 Provide and Maintain the Service

  • Create and manage your account
  • Authenticate your identity
  • Process your wine photo scans and provide AI-powered recommendations
  • Generate personalized taste profiles
  • Maintain your wine history and digital cellar
  • Enable social features like public profiles and Wine Circles
  • Process payments and subscriptions
  • Provide customer support

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:

  • Wine Photos: Images you upload are sent to Google Gemini for analysis to identify wines, extract label information, and assess wine characteristics
  • Taste Profile Data: Your taste8 profile (sweetness, body, tannins, acidity, fruitiness, floral, earthy, spicy preferences) is shared with the AI to personalize recommendations
  • Chat Messages: All conversations with Pablo AI are processed by Google Gemini to provide sommelier guidance, answer questions, and make recommendations
  • Wine Data: Information about wines you've scanned, rated, or reviewed may be used to improve recommendation accuracy

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

  • Analyze usage patterns to improve features
  • Train and refine our AI models and algorithms
  • Develop new features and functionality
  • Conduct research and analytics
  • Test and troubleshoot technical issues

3.4 Communications

  • Send you service-related notifications and updates
  • Respond to your inquiries and support requests
  • Send promotional communications (with your consent, where required)
  • Conduct surveys and request feedback
  • Send administrative messages about account or subscription changes

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:

  • Wineries, vineyards, and wine producers
  • Restaurants, wine bars, and hospitality businesses
  • Wine retailers and distributors
  • Market research and analytics partners

Types of data shared for B2B services:

  • Aggregated taste trends and regional preferences
  • Market insights and consumption patterns
  • Wine popularity and recommendation data
  • Note: Where possible, data will be anonymized or aggregated. However, certain B2B features may require sharing of identifiable data with your explicit opt-in consent. You will be clearly informed before opting into any feature that shares identifiable data.

3.6 Legal and Safety

  • Comply with legal obligations and law enforcement requests
  • Enforce our Terms and Conditions
  • Protect the rights, property, and safety of Pablo, our users, and others
  • Prevent fraud, abuse, and security issues
  • Verify age requirements for alcohol-related services

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):

  • Purpose: User authentication and account management
  • Data Shared: Email address, name, authentication credentials
  • Privacy Policy: https://clerk.com/legal/privacy/

Convex (Backend and Database):

  • Purpose: Database hosting, backend API, and real-time data synchronization
  • Data Shared: All user data including account information, wine data, photos, taste profiles, and usage data
  • Privacy Policy: https://www.convex.dev/legal/privacy/

Google Gemini (AI Processing):

  • Purpose: AI-powered wine recognition, recommendations, and conversational assistance
  • Data Shared: Wine photos, taste profile data (taste8), chat messages, and wine-related data
  • Privacy Policy: https://policies.google.com/privacy

Sentry (Error Tracking and Monitoring):

  • Purpose: Bug tracking, error monitoring, and performance analysis
  • Data Shared: Error logs, device information, user identifiers, and technical diagnostic data
  • Privacy Policy: https://sentry.io/privacy/

Apple App Store (Payments):

4.2 Business Partners (B2B Services)

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

  • Wineries and wine producers
  • Restaurants and hospitality businesses
  • Wine retailers and distributors
  • Market research partners

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

  • Public Profiles: Information you choose to make public (username, profile photo, wine preferences, tasting notes) is visible to other users
  • Wine Circles: Your taste profile data is shared with other members of Wine Circles you join
  • Social Sharing: Content you choose to share publicly can be viewed by other users

4.4 Legal Requirements and Protection

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

  • Legal process (subpoenas, court orders, or legal claims)
  • Government or regulatory requests
  • Enforcement of our Terms and Conditions
  • Protection of rights, property, or safety of Pablo, users, or the public
  • Detection and prevention of fraud, security issues, or technical problems

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:

  • Account Data: Retained while your account is active and for a reasonable period after account closure to comply with legal obligations
  • Wine Photos: Retained while your account is active; you may delete photos at any time
  • Chat History: Retained while your account is active; you may delete conversations at any time
  • Taste Profile Data: Retained while your account is active and used to improve recommendations
  • Usage Data: Aggregated usage data may be retained indefinitely for analytics and service improvement
  • Payment Records: Retained as required by tax and accounting regulations (typically 7 years)

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:

  • Access the personal information we hold about you
  • Request a copy of your personal information in a structured, machine-readable format
  • Request transfer of your data to another service (data portability)

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

6.2 Correction and Update

You have the right to:

  • Correct inaccurate personal information
  • Update or modify your account information

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:

  • Request deletion of your personal information
  • Delete your account and associated data

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:

  • Object to processing of your personal information for certain purposes
  • Opt out of marketing communications
  • Withdraw consent for data processing based on consent

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:

  • Request restriction of processing of your personal information in certain circumstances

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:

  • Understand how automated decisions are made
  • Request human review of automated decisions that significantly affect you

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:

  • Clicking "unsubscribe" links in marketing emails
  • Adjusting notification preferences in account settings
  • Contacting support@getpablo.ai

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:

  • Your browser settings
  • Device settings for mobile identifiers
  • Opting out of interest-based advertising through industry opt-out mechanisms

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:

  • Contract Performance: Processing necessary to provide the Service and fulfill our contract with you
  • Legitimate Interests: Processing necessary for our legitimate business interests (service improvement, fraud prevention, analytics), provided these interests are not overridden by your rights
  • Consent: Processing based on your explicit consent (e.g., marketing communications, optional features)
  • Legal Obligations: Processing necessary to comply with legal requirements

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:

  • Standard Contractual Clauses (SCCs): We use European Commission-approved Standard Contractual Clauses with service providers
  • Adequacy Decisions: We may transfer data to countries deemed adequate by the European Commission
  • Your Consent: In some cases, we obtain your explicit consent for international transfers

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):

  • Identifiers (name, email, user ID)
  • Commercial information (purchase history, wine preferences)
  • Internet activity (usage data, interactions)
  • Geolocation data
  • Visual information (photos you upload)
  • Inferences (taste preferences, recommendations)

8.2 California Privacy Rights

California residents have the right to:

  • Know: Request disclosure of personal information collected, used, and shared
  • Delete: Request deletion of personal information
  • Correct: Request correction of inaccurate personal information
  • Opt-Out: Opt out of sale or sharing of personal information
  • Limit: Limit use of sensitive personal information
  • Non-Discrimination: Not be discriminated against for exercising privacy rights

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:

  • Encryption of data in transit (TLS/SSL)
  • Encryption of sensitive data at rest
  • Access controls and authentication
  • Regular security assessments and monitoring
  • Employee training on data protection
  • Third-party security audits

However, please note:

  • No method of transmission or storage is 100% secure
  • We cannot guarantee absolute security of your information
  • You are responsible for maintaining the confidentiality of your account credentials
  • You should use a strong password and enable two-factor authentication if available

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:

  • This Privacy Policy does not apply to third-party services
  • We are not responsible for the privacy practices of third parties
  • We encourage you to review the privacy policies of any third-party services you visit
  • Third-party services may collect their own data when you interact with them

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:

  • We will post the updated Privacy Policy with a new "Last Updated" date
  • For material changes, we will provide prominent notice through:
    • Email notification to your registered email address
    • In-app notification
    • A notice on our website

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:

  • Privacy inquiries
  • GDPR/Data Protection Officer requests
  • California privacy requests (subject: "California Privacy Request")
  • Data subject access requests

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.