PRIVACY POLICY

Introduction

This privacy policy (“Privacy Policy”) applies to the personal information that CoBe1 processes in connection with CoBe1 related services (the “Services”), that link to or reference this Privacy Policy. The Services enable you to create and interact with chatbots.

Data Controller: The Services are provided and controlled by EYM DIGITAL OÜ (registrikood 17195611), with its registered address in Estonia (“we” or “us”). If you have any questions about how we use your personal data, please contact [email protected] or click the “Contact us” column on the website.

Please be informed that the processing rules for personal information collected from end users when accessing downstream systems or applications developed by developers using our open platform services are not covered by this privacy policy. The developer operating the application, as the controller of the personal information processing activity, should disclose the relevant personal information protection policies to the end users.

What Information We Collect

We collect your information in three ways: Information You Provide, Automatically Collected Information, and Information from Other Sources. More detail is provided below.

Information You Provide

When you create an account, input content, contact us directly, or otherwise use the Services, you may provide some or all the following information:

• Account information. We collect information that you provide when you set up an account, such as your date of birth (where applicable), username (where applicable), email address and/or telephone number, and password.
• User Input. When you use our Services, we may collect your text input, prompt, uploaded files, feedback, chat history, or other content that you provide to our model and Services (“Prompts” or "Inputs"). We generate responses (“Outputs”) based on your Inputs.
• Information When You Contact Us. When you contact us, we collect the information you send us, such as proof of identity or age, contact details, feedback or inquiries about your use of the Services or information about possible violations of our Terms of Use (our “Terms”) or other policies.

Automatically Collected Information

We automatically collect certain information from you when you use the Services, including internet or other network activity information such as your IP address, unique device identifiers, and cookies.

• Device and Network Information. We collect certain device and network connection information when you access the Services. This information includes your device model, operating system, IP address, device identifiers and system language. We also collect service-related, diagnostic, and performance information, including crash reports and performance logs. We automatically assign you a device ID and user ID. Where you log-in from multiple devices, we use information such as your device ID and user ID to identify your activity across devices to give you a seamless log-in experience and for security purposes.
• Log Information. We collect information regarding your use of the Services, such as the features you use and the actions you take.
• Location Information. We automatically collect information about your approximate location based on IP address for security reasons, for example to protect your account by detecting unusual login activity.
• Cookies & Similar Technologies. We use cookies and similar tracking technologies to operate and provide the Service. For example, we use cookies to remember your language preferences, and for security purposes. We will obtain your consent to our use of cookies where required by law. To learn more about our use of cookies, please see our Cookies Policy.
• Payment Information. When you use paid services for prepayment, we collect your payment order and transaction information to provide services such as order placement, payment, customer service, and after-sales support.

To avoid any doubt, Cookies & Similar Technologies and Payment Information are not applicable to CoBe1 App.

Information from Other Sources

We may receive the information described in this Privacy Policy from other sources, such as:

• Log-in, Sign-up, or Linked Services. Where available, if you choose to sign-up or log-in to the Services using a third-party service such as Apple or Google, or link your account to a third-party service, we may collect information from the service, such as access token.
• Security Information. We receive information from our trusted partners, such as security partners, to protect against fraud, abuse, and other security threats to our Services.
• Public Information. We may obtain publicly available information via Internet sources in order to train our models and provide services.

How We Use Your Information

We use your information to operate, provide, develop, and improve the Services, including for the following purposes.

• To provide, administer and maintain the Services and to enforce our terms, conditions and policies. Such as creating the accounts, delivering a fast and convenient logging-in experience, enabling you to chat with CoBe1 and provide user support.
• To improve and develop the Services and to train and improve our technology, such as our machine learning models and algorithms. Including by monitoring interactions and usage across your devices, analyzing how people are using them, and training and improving our technology.
• To communicate with you, including to notify you about changes to the Platform, provide customer support to you and send you other service-related messages.
• To promote the safety, security, and stability of the Platform, such as by preventing and detecting abuse, fraud, and illegal activity on the Platform and by conducting troubleshooting, data analysis, testing, and research.
• To comply with our legal obligations, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life.

If you refuse to allow us to process the data in the manner described above, you may provide feedback through [email protected].

How We Share Your Information

Service Providers

We engage service providers that help us provide, support, and develop the Services and understand how they are used. We share Information You Provide, Automatically Collected Information, and Information From Other Sources with these service providers as necessary to enable them to provide their services. For example:

• We use communication service providers to send notifications and/or communications to you.
• We integrate third-party APIs (such as Bing) to provide search services, and we will share your input to provide these services.
• We use analytics services providers to analyze data.
• We use support and safety monitoring services providers to assist us in ensuring the safety of our services.

Pursuant to our instructions, these parties will access, process, or store Personal Data only while performing their duties to us.

Our Corporate Group

The services are supported by certain entities within our corporate group. These entities process the Information You Provide, and Automatically Collected Information for us, as necessary to provide certain functions, such as storage, content delivery, security, research and development, analytics, customer and technical support.

Others

We share your information in other limited scenarios as follows:

Corporate Transactions. Your information may be disclosed to third parties in connection with a corporate transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.

Legal Obligations and Rights. We may access, preserve, and share the information described in “What Information We Collect” with law enforcement agencies, public authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:

• comply with applicable law, legal process or government requests, as consistent with internationally recognized standards,
• protect the rights, property, and safety of our users, copyright holders, and others, including protecting life or preventing imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk,
• investigate potential violations of and enforce our Terms, Guidelines, or any other applicable terms, policies, or standards, or
• detect, investigate, prevent, or address misleading activity, copyright infringement, or other illegal activity.

With Your Consent

Depending on where you live, we may share personal information with the proper authorization or to provide the Services you have requested or authorized. For example, if you choose to log in to our Services using a social network account or share information from our Services to a social media service, we will share that information with those Platforms.

Third-party content. The Services may contain links to policies, functionality, or content maintained by third parties not controlled by us. We are not responsible for and make no representations regarding such policies, functionality, or content or any other practices or operations of such third parties.

Your Rights

Depending on where you live, you may have certain rights with respect to your personal information, such as the right to know how we collect and use your personal information. You may also have the right to access, change, oppose, request a copy of your authorization, file complaints before the competent authorities withdraw your consent, or limit our collection and use of your personal information as well as to request that we delete it, and potentially others. In certain circumstances, you can also ask us to provide additional information about our collection and use of your personal information. Please note that your exercise of certain rights may impact your ability to use some or all CoBe1 Services' features and functionalities.

If you have registered for an account, you may also access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.

Please contact us by using the contact information provided in this Privacy Policy if you would like to exercise any of your rights. We will respond to your request consistently with applicable law and subject to proper verification.

Your Choices

You can control and access some of your personal information directly through settings. For example, you can manage your chat history. Should you choose to do so, you may also delete your chat history via your settings.

If you choose to delete your account, you will not be able to reactivate your account or retrieve any of the content or information in connection with your account.

A note about accuracy: Services like CoBe1 generate responses by reading a user’s request and, in response, predicting the words most likely to appear next. In some cases, the words most likely to appear next may not be the most factually accurate. For this reason, you should not rely on the factual accuracy of output from our models. If you notice that output contains factually inaccurate information about you and you would like to request a correction or removal of the information, you can submit these requests through [email protected] and we will consider your request based on applicable law and the technical capabilities of our models.

The Security of Your Information

The security of your information is important to us. We maintain commercially reasonable technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods. However, no Internet or email transmission is ever fully secure or error free. In particular, emails sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Services or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.

How Long Do We Keep Your Information

We retain information for as long as necessary to provide our Services and for the other purposes set out in this Privacy Policy. We also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing our Services and enhancing their safety, security and stability), and for the exercise or defense of legal claims.

The retention periods will be different depending on the amount, type and sensitivity of information, the purposes for which we use the information and any legal requirements, etc. For example, when we process your information to provide you with the Services, we keep this information for as long as you have an account. This information includes your account information, input and payment information. If you violate any of our terms, policies or guidlines, we may keep your information as necessary to process the violation.

When the personal data collected is no longer required by us, we and our service providers will perform the necessary procedures for destroying, deleting, erasing, or converting it into an anonymous form as permitted or required under applicable laws.

Where We Store Your Information

The personal information we collect from you may be stored on a server located outside of the country where you live. We store the information we collect in secure servers located in Cloud infrastructure .

Where required, we will use appropriate safeguards for transferring personal information outside of certain countries, including for one or more of the purposes as set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws.

Information relating to children under 14

Our Services are not aimed at children under the age of 14. We do not actively collect personal information from children under the age of 14. If we notice or receive feedback that we have collected any of their personal information without prior consent from a guardian, we will attempt to delete the information as soon as possible. If you believe that we processed personal information about or collected from a child under the age of 14, please contact us at [email protected].

If you are 14 or older but under 18, you should read and agree to this privacy policy together with your parents or other guardians before using our Services.

Privacy Policy Updates

We may update this Privacy Policy from time to time as required by law. When we update the Privacy Policy, we will notify you by updating the “Last Updated” date at the top of the new Privacy Policy, posting the new Privacy Policy, or by providing any other notice required by applicable law. We recommend that you review the Privacy Policy each time you access our Services to stay informed of our privacy practices.

Contact Us

Questions, comments and requests regarding this policy should be addressed to [email protected] or click “Contact us” column on the website to address regarding your other comments to [email protected].

Supplemental Terms - Jurisdiction-Specific

European Economic Area (“EEA”), Switzerland, and UK

If you are using the Services in the EEA, Switzerland or the UK (the “European Region”), the following additional terms apply:

Legal bases for processing.

We use your personal data only as permitted by law. Our legal bases for processing your personal data described in this Policy are described in the table below.

Please be aware that we collect your personal data for the purposes set out on the table above. You may choose not to provide some of the personal data fields, but this may affect the services you are able to use from us.

Data storage

Please be aware that our servers are in the cloud infrastructure. When you access our services, your personal data may be processed and stored in our servers in the People’s Republic of China. This may be a direct provision of your personal data to us or a transfer that we or a third-party make.

Your rights

You have the following rights:

• The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained.
• The right to request proper rectification or erasure of your personal data or restriction of the processing of your personal data.
• Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible (data portability);
• Where the processing of your personal data is based on your consent, the right to withdraw your consent at any time (withdrawal will not impact the lawfulness of data processing activities that have taken place before such withdrawal).
• The right not to be subject to any automatic individual decisions, including profiling, which produce legal effects on you or similarly significantly affects you unless we have your consent, this is authorized by European Union or Member State law, or this is necessary for the performance of a contract.
• The right to object to processing if we are processing your personal data based on our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing.
• You have the right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defense of a legal claim, or (d) you have objected to the processing and you are awaiting the outcome of that objection request.
• The right to object to processing your personal data for direct marketing purposes; and
• The right to lodge complaints before your local data protection authority.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Please send an email to us if you would like to exercise any of your rights at [email protected].