MINDBOLO PRIVACY POLICY

1. OUR ROLE

Our role depends on how personal data is processed.

When you visit our website, enquire about MindBolo, create an account, subscribe to the platform, or communicate with our team, we determine the purposes and means of processing the personal data involved. In these situations, we act as the organisation responsible for that processing under applicable law.

When a business customer uses MindBolo to power an AI assistant on its website or other customer-facing channel, that business generally determines what information is collected from its visitors and why. The business customer is generally the controller of that information, while MindBolo processes it to provide the platform and related services, in accordance with the customer's instructions and applicable agreement.

If you are interacting with an assistant on a business's website, please contact that business for requests about the information it collects and how it uses it. We will assist our customer with relevant requests where required by law and our agreement.

Applicable data protection legislation and the customer's instructions govern processing performed for a customer. The customer's privacy notice explains its own purposes, lawful basis, retention practices, and contact route. MindBolo's platform and security practices govern the service processing we perform on the customer's behalf.

2. INFORMATION WE COLLECT ABOUT YOU

The categories of information we may process depend on your relationship with MindBolo and the features being used.

Category	Examples	Purpose
Contact details	Name, email address, telephone number, business name, job title, and contact preferences.	Account administration, service delivery, support, and communications.
Account and profile data	Login details, account ID, role, preferences, workspace and assistant settings.	Create and secure accounts and provide platform functionality.
Billing and transaction data	Subscription plan, invoice details, billing address, transaction references, payment status, and tax information.	Manage subscriptions, payments, accounting, and legal obligations.
Activity and usage data	Pages visited, feature use, clicks, session events, assistant usage, and interaction patterns.	Operate, troubleshoot, secure, and improve the service.
Technical identifiers	IP address, browser type, device information, operating system, log data, and identifiers associated with a session or account.	Authentication, security, fraud prevention, diagnostics, and platform performance.
Customer content and knowledge data	Website content, FAQs, business documents, presentations, product information, images, and instructions uploaded or submitted to configure an assistant.	Build and operate the customer's assistant and retrieve relevant information for responses.
AI conversation data	Visitor questions, prompts, assistant replies, conversation history, timestamps, feedback, and handover requests.	Generate responses, provide conversation history, support the customer's workflows, and troubleshoot.
Lead and enquiry data	Information submitted through an assistant, such as name, email, phone number, enquiry details, and requested follow-up.	Capture and qualify enquiries and enable the customer to respond.
Communications and feedback	Support requests, emails, feedback, survey responses, bug reports, and other communications.	Customer support, product improvement, and issue resolution.
Aggregated or statistical data	Usage totals, trends, and service metrics that do not identify an individual.	Understand service performance and improve functionality.

Aggregated information may be derived from personal data. Where it no longer identifies, and cannot reasonably be used to identify, an individual, it may be treated as non-personal information under applicable law. If aggregated information is combined with information that identifies an individual, we treat the combined information as personal data.

3. SENSITIVE PERSONAL DATA

MindBolo is designed primarily for business communication, customer support, lead generation, and product or service guidance. You and our business customers should avoid submitting sensitive personal data through an assistant unless it is genuinely necessary for the intended service and the relevant legal requirements and safeguards are in place.

Sensitive personal data may include information relating to a person's health, biometric characteristics, religious or political beliefs, criminal records, or other categories protected by applicable law. Where such information is processed, the responsible organisation must ensure that a lawful basis, any required consent or authorisation, and appropriate safeguards are in place.

MindBolo does not ask End Users to provide sensitive personal data as a general requirement for using an AI assistant. A customer that configures an assistant to request or process such information is responsible for ensuring that the use is lawful and appropriate.

4. LEGAL GROUNDS FOR PROCESSING

We process personal data only where a lawful ground applies under the UAE Personal Data Protection Law or other applicable legislation. Depending on the circumstances, these grounds may include:

• Consent: where an individual has given consent for a specified purpose, and consent is the applicable legal basis.
• Contractual necessity: where processing is necessary to provide a requested service, administer an account, or take steps requested before entering into a contract.
• Legal obligations: where processing is necessary to comply with a legal or regulatory requirement.
• Legitimate or permitted interests: where the applicable law recognises the relevant ground and the processing is appropriate in the circumstances, taking account of individuals' rights.
• Other grounds permitted by applicable law, including circumstances specifically provided for by the UAE legal framework.

Where processing is based on consent, you may withdraw consent subject to applicable law. Withdrawal does not affect processing that took place lawfully before the withdrawal. If a different legal ground applies, other rights or limitations may be relevant.

5. HOW WE USE YOUR DATA IF YOU ARE A MINDBOLO CUSTOMER

If you register for or use MindBolo on behalf of yourself or a business, we may process account and related personal data for the following purposes:

Purpose	Personal data categories	Legal ground or reason
Account creation and administration	Contact details, account and profile data, technical identifiers.	Contractual necessity and account administration.
User authentication and access control	Account data, contact details, technical identifiers.	Contractual necessity and platform security.
Subscription and billing administration	Contact details, billing and transaction data.	Contractual necessity and legal or accounting obligations.
Customer support and troubleshooting	Contact details, account data, support communications, technical logs.	Service delivery, contractual necessity, and applicable permitted grounds.
Onboarding and product demonstrations	Contact details, account data, usage data, feedback.	Requested pre-contractual steps, service delivery, or consent where required.
Service notifications	Contact details and account status.	Service administration and contractual necessity.
Product updates and marketing	Contact details, communication preferences, and relevant account information.	Consent or another basis permitted by applicable marketing and privacy rules.
Platform security and error management	Technical identifiers, account activity, logs, and relevant communications.	Security, prevention of misuse, and legal obligations where applicable.
Product development and service insights	Usage data, technical data, feedback, and aggregated metrics.	Service improvement on an appropriate lawful basis.
Surveys and feedback	Contact details, responses, and preferences.	Consent or another applicable lawful basis.
Legal and regulatory compliance	Relevant account, transaction, and communication records.	Compliance with legal obligations and establishment or defence of claims.

When acting as a processor

Where a customer uses MindBolo to process information about its own website visitors or leads, we process that information for the customer's purposes and according to its instructions. The customer is responsible for its privacy notice, lawful basis, collection choices, and responses to individual requests. We provide assistance as required by the applicable agreement and law.

6. HOW WE USE DATA ABOUT END USERS OF OUR CUSTOMERS

If you interact with an AI assistant powered by MindBolo, the business operating that assistant generally determines the purposes of the interaction. Depending on the assistant's configuration, the platform may process:

Purpose	Information that may be processed	Role and responsibility
Answering questions and providing support	Messages, prompts, relevant knowledge content, generated responses, and technical interaction data.	MindBolo processes information to provide the assistant; the customer determines the service purpose.
Product or service guidance	Questions, stated preferences, product or service information, and assistant responses.	The customer determines the recommendations and use case; MindBolo provides the technical service.
Lead capture and qualification	Contact details and enquiry information submitted by the visitor.	The customer determines what is requested and how leads are followed up.
Conversation history and analytics	Conversation records, timestamps, usage events, and feedback, where enabled.	The customer controls access and use within its account, subject to the platform's features and agreement.
Human handover or booking direction	The visitor's request and any information needed to direct the interaction to a customer-selected channel or booking page.	The customer configures the handover destination and handles subsequent communications.

For information collected by a customer through its assistant, contact the customer directly and review its privacy notice. MindBolo will not determine the customer's independent purposes merely because the customer uses our platform.

7. HOW WE USE YOUR DATA IF YOU ARE A PROSPECT OR LEAD

If you have expressed interest in MindBolo but have not become a customer, we may process information you provide to respond to your enquiry and, where permitted, to explain our services.

Purpose	Personal data categories	Legal ground or reason
Responding to enquiries	Contact details, enquiry content, communications.	Respond to your request or take pre-contractual steps.
Lead management	Contact details, business information, enquiry history, and relevant interactions.	Manage prospective customer relationships on an appropriate lawful basis.
Product demonstrations and onboarding discussions	Contact details, preferences, requested use case, and meeting-related information.	Respond to requests and support pre-contractual discussions.
Marketing communications	Contact details and communication preferences.	Consent or another basis permitted by applicable law.
Feedback and research	Survey responses, feedback, and contact details if provided.	Consent or another applicable lawful basis.

You can opt out of promotional communications at any time using the unsubscribe option where available or by contacting us through mindbolo.com. Opting out of marketing does not prevent essential service or enquiry-related communications.

8. HOW WE USE YOUR DATA IF YOU VISIT OUR WEBSITE

When you visit mindbolo.com, we may process information to operate the website, respond to requests, protect the site, and understand how visitors use it.

Purpose	Personal data categories	Reason
Website operation and hosting	Technical identifiers, access logs, and information submitted through website forms.	Make the website available and secure.
Website security	IP address, device and browser data, access events, and security logs.	Detect misuse, protect systems, and investigate incidents.
Website performance and diagnostics	Usage events, technical data, error information.	Identify issues and improve reliability.
Website analytics	Browsing and interaction data, where analytics tools or similar technologies are enabled.	Understand website use, subject to applicable consent requirements.
Responding to contact requests	Contact details and the content of your enquiry.	Respond to the request and maintain relevant communication records.

Cookies

Mindbolo uses a strictly necessary session cookie to maintain secure sessions and provide requested functionality. This cookie is not used for advertising or to build an advertising profile.

You can also manage or disable cookies through your browser settings. Disabling the session cookie may affect website functionality.

9. HOW PERSONAL DATA IS COLLECTED

Direct interactions

You may provide personal data when you create an account, subscribe to a service, complete a form, request a demonstration, contact support, respond to a survey, or otherwise communicate with us. This may include contact details, account information, billing information, and the content of your communications.

Automated technologies and interactions

As you use the website, dashboard, or assistant, certain technical and usage information may be collected automatically. This can include device and browser details, IP address, log events, pages or features used, and interaction timestamps. The extent of collection depends on the features and technologies actually enabled.

Customer-provided and publicly available information

Business customers may provide website content, product details, documents, FAQs, and other materials to configure their assistants. Customers are responsible for having the rights and authority needed to provide those materials. Where a customer directs an assistant to use publicly available business information, that use remains subject to applicable law and the customer's instructions.

10. SHARING AND DISCLOSURE OF PERSONAL DATA

We do not sell customer conversation data or information submitted through customer assistants as an independent data product. We may disclose personal data where necessary to provide the Services, comply with law, protect the platform, or act on your instructions.

• To the business customer operating an assistant, and to users that customer has authorised to access relevant account or conversation information.
• To service providers that support the operation, security, hosting, AI processing, communications, billing, or maintenance of the Services, where such providers are used and their access is necessary.
• To professional advisers or auditors where necessary and subject to appropriate confidentiality protections.
• To courts, regulators, law enforcement, or other authorities where disclosure is legally required or otherwise permitted.
• In connection with a corporate transaction, restructuring, or transfer of business assets, subject to applicable law and appropriate safeguards.
• To another recipient where you have requested or authorised the disclosure.

Where we engage a processor, we use appropriate contractual terms and safeguards as required by applicable law. The specific providers and their data-handling arrangements may change as the Services develop.

11. INTERNATIONAL TRANSFERS

MindBolo is operated from the United Arab Emirates. Personal data may be processed in the UAE or in other countries depending on the technical infrastructure and service arrangements used to provide the platform, including the location of systems, support access, and AI processing.

Where personal data is transferred outside the UAE, we will apply the requirements of the UAE Personal Data Protection Law and any other applicable rules. Depending on the circumstances, this may involve an approved transfer mechanism, appropriate contractual or organisational safeguards, an applicable adequacy determination, or another legal condition for transfer.

The location of a company's headquarters does not by itself determine where all data is stored or accessed. We do not promise that all data is stored exclusively in the UAE.

12. HANDLING PERSONAL DATA IN AI CONVERSATIONS

Business customers should not ask End Users to provide personal, financial, or sensitive information through an assistant unless it is necessary for the intended service and lawful safeguards are in place. Customers should clearly inform visitors when an AI assistant is being used and explain what personal data may be collected and for what purposes. Customers should configure the assistant to request only relevant information and should avoid collecting unnecessary sensitive information. Conversation records and lead details may be accessible to authorised users of the customer's account, depending on the features and permissions enabled. AI-generated responses can be inaccurate or incomplete. Customers should review assistant instructions, knowledge sources, and outputs for their intended use. Customers remain responsible for decisions and follow-up actions they take based on assistant conversations or lead information.

MindBolo's handling of prompts, uploaded content, and conversation data for model training or general product development depends on the applicable product configuration, service terms, and processing arrangements. We do not make a blanket claim in this Policy that such information is or is not used for model training in every circumstance.

13. DATA SECURITY

We use technical and organisational measures intended to protect personal data from accidental loss, unauthorised access, alteration, disclosure, or destruction. Security measures are selected in light of the nature of the information and the risks associated with processing.

Access to personal data is limited to authorised people who need it for legitimate service, support, security, or operational purposes. Account access and permissions are managed to reduce the risk of unauthorised use. Data in transit and stored data are protected using security measures appropriate to the systems and processing involved. Security events and technical logs may be reviewed to detect misuse, investigate issues, and maintain service integrity. Incident response procedures are used to assess and address suspected personal data breaches. Personnel and service providers with access to personal data are subject to appropriate confidentiality and security requirements.

No internet-based service can guarantee absolute security. You should use a strong, unique password where applicable, protect your login credentials, and notify us promptly if you suspect unauthorised access to your account.

Access to customer conversation data may be necessary for authorised support, troubleshooting, security, or misuse investigations, subject to applicable access controls and contractual requirements.

14. DATA RETENTION

We retain personal data only for as long as reasonably necessary for the purposes for which it was collected, including to provide the Services, meet legal and accounting requirements, resolve disputes, enforce agreements, and protect the platform.

When determining a retention period, we consider:

• The type, amount, and sensitivity of the personal data.
• The purpose for which the information is processed and whether that purpose can be achieved by other means.
• The risks associated with continued retention, loss, or unauthorised access.
• Applicable legal, regulatory, tax, and accounting requirements.
• The terms and instructions agreed with a customer where MindBolo acts as a processor.

For data processed on behalf of a customer, retention and deletion are generally governed by the customer's instructions and the applicable agreement. When data is no longer required, it will be deleted, anonymised, or securely isolated as appropriate, subject to legal obligations and technical backup cycles.

Some information may remain in backups for a limited period after deletion from active systems. Backup copies are subject to the applicable backup lifecycle and are not intended for ordinary use.

15. AUTOMATED PROCESSING AND PROFILING

MindBolo uses AI technology to generate responses based on messages, customer-provided content, instructions, and the AI systems used to deliver the service. Customers may also use platform features to categorise or score leads, depending on their configuration.

The business customer is responsible for determining whether its use of automated processing or profiling produces decisions that have legal or similarly significant effects on individuals, and for meeting any transparency, review, objection, or human-intervention requirements that apply.

AI-generated information should not be treated as a guaranteed factual determination. Customers should apply appropriate human review when the context or potential impact requires it.

16. YOUR LEGAL RIGHTS

Subject to the UAE Personal Data Protection Law and other applicable legislation, you may have rights concerning your personal data. These may include the right to:

• Request access to personal data and information about how it is processed.
• Request correction of inaccurate or incomplete personal data.
• Request erasure or destruction of personal data in circumstances provided by law.
• Request restriction or cessation of processing where the legal conditions are met.
• Request transfer of personal data in a structured and usable format where a right to portability applies.
• Withdraw consent where processing is based on consent.
• Object to certain processing where the law provides that right.
• Submit a complaint to the competent authority in accordance with applicable procedures.

These rights may be subject to legal conditions, exceptions, the rights of others, and the role of the organisation responsible for the processing. We may need to verify your identity or ask for additional information before responding.

If MindBolo processes your data for a business customer, please contact that customer first. The customer generally controls the purposes and means of that processing. We will provide assistance to the customer where required by law and our agreement.

For requests relating to MindBolo's own processing, contact us through mindbolo.com and clearly describe your request. We will respond within the period required by applicable law. There is no fee for ordinary requests unless applicable law permits a reasonable fee or refusal in cases of manifestly unfounded or excessive requests.

17. CHILDREN AND MINORS

MindBolo is a business-oriented service and is not designed for children to create or manage accounts independently. A customer's assistant may nevertheless be accessible to a broad audience, which could include minors.

Customers are responsible for assessing whether their assistant is suitable for children, providing age-appropriate information, obtaining parental consent where required, and applying any safeguards required by law.

If you believe a child has provided personal data directly to MindBolo in a way that is not appropriate, please contact us through mindbolo.com so that we can review the circumstances.

18. CUSTOMER RESPONSIBILITIES

Businesses using MindBolo are responsible for their own use of personal data and should:

• Provide End Users with a clear and accessible privacy notice describing the assistant and the business's data practices.
• Identify a lawful basis for collecting and using personal data and obtain consent where required.
• Ensure they have the rights and authority to upload content and personal data to the platform.
• Configure assistants to collect only information that is relevant to the stated purpose.
• Set appropriate account permissions and retention practices.
• Review AI outputs and ensure that the assistant is appropriate for the intended audience and use case.
• Respond to privacy requests for which they are responsible and seek MindBolo's assistance where needed.
• Comply with applicable privacy, marketing, consumer-protection, and sector-specific requirements.

19. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our Services, processing activities, legal requirements, or operational practices. The updated version will be published on mindbolo.com with a revised "Last updated" date.

Where required by law, or where a change materially affects how personal data is processed, we will provide additional notice or obtain consent as appropriate. We encourage you to review this Policy periodically.

20. CONTACT INFORMATION

If you have questions, concerns, or a request relating to this Privacy Policy or personal data processed by MindBolo, please contact us through our website:

Website: https://mindbolo.com

MindBolo is an AI assistant platform by GetDigital.ae (Jawad Karim Marketing Services), operated from the United Arab Emirates.

21. UAE DATA PROTECTION FRAMEWORK

This Privacy Policy is intended to reflect the UAE federal personal data protection framework, including Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data, as applicable to MindBolo's activities.

Nothing in this Policy limits rights that cannot lawfully be limited or excludes obligations imposed by applicable law.