Privacy Policy

Privacy Policy

Last updated: [current date]

1. Introduction

Paloma's AI Academy ("we," "us," or "our") operates the website https://palomasacademy.ai and provides AI training and consulting services. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you visit our website, purchase our products or services, subscribe to our communications, or otherwise interact with us.

We are committed to protecting your privacy and handling your personal data transparently and in compliance with applicable data protection laws, including the General Data Protection Regulation (GDPR) for visitors in the European Union and United Kingdom, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) for California residents, the CAN-SPAM Act for email marketing, the Telephone Consumer Protection Act (TCPA) for SMS and telephone communications, and the Children's Online Privacy Protection Act (COPPA).

By using our services or providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our practices, please do not use our services or provide us with your information.

2. Information We Collect

We collect several types of information from and about users of our services:

Identity and Contact Data: When you fill out forms on our website, register for courses, request information, or purchase services, we collect your name, email address, and phone number. We may also collect your company name, job title, and other professional information you choose to provide.

Automatically Collected Data: When you visit our website, we automatically collect certain technical information, including your IP address, device type and identifiers, operating system, browser type and version, approximate geographic location (country and city level based on IP address), referring website, pages viewed, time spent on pages, links clicked, and other usage data. This information helps us understand how visitors use our site and improve our services.

Cookies and Analytics Data: We use cookies, web beacons, and similar tracking technologies to collect information about your browsing behavior and preferences. This includes session cookies (which expire when you close your browser) and persistent cookies (which remain on your device). We use analytics services to track website performance, user engagement, and traffic sources. For detailed information about our use of cookies, please see our Cookie Policy.

Payment Information: When you make a purchase, payment information (credit card numbers, billing address) is collected and processed directly by our third-party payment processor. We do not store complete payment card numbers on our servers. We may receive and store transaction identifiers, payment status, and billing contact information from our payment processor.

Content and Communications: We collect any information you submit through contact forms, support requests, course assignments, feedback surveys, comments, testimonials, or direct communications with us via email, SMS, or other channels. If you participate in our training programs, we may collect information about your progress, completion status, and performance.

3. How We Use Your Information

We use the personal information we collect for the following purposes:

Deliver Products and Services: To provide you with the AI training courses, consulting services, and other products you have purchased or requested; to create and manage your account; to deliver course materials, resources, and communications related to your enrollment; and to fulfill our contractual obligations to you.

Process Payments: To process transactions, verify payment information, prevent fraud, and maintain accurate financial records. Payment processing is handled by our third-party payment processor in accordance with payment card industry standards.

Send Communications: To send you transactional emails and SMS messages related to your purchases, account activity, course enrollment, and service updates. With your consent, we also send marketing emails and SMS messages about new courses, special offers, educational content, and other information we believe may interest you. You can opt out of marketing communications at any time as described in Section 6 below.

Provide Support: To respond to your inquiries, provide customer service, troubleshoot technical issues, and assist you with our services.

Analytics and Improvement: To analyze how our website and services are used, identify trends and patterns, measure the effectiveness of our marketing campaigns, develop new features and offerings, and improve the overall user experience.

Security and Fraud Prevention: To protect our website, services, and users from unauthorized access, security threats, fraudulent activity, and other harmful or illegal conduct; to verify identity and detect suspicious activity; and to enforce our Terms of Service and other policies.

Legal Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests; to respond to subpoenas, court orders, or other legal demands; and to protect our legal rights and interests.

4. Legal Bases for Processing

For visitors in the European Union and United Kingdom, we process your personal data based on the following legal grounds under the GDPR:

Consent: When you provide explicit consent for us to process your personal data for specific purposes, such as sending you marketing communications or using certain cookies. You have the right to withdraw your consent at any time.

Performance of a Contract: When processing is necessary to fulfill our contractual obligations to you, such as delivering the courses or services you have purchased, processing your payment, or providing customer support.

Legitimate Interests: When we have a legitimate business interest in processing your data, such as improving our services, conducting analytics, preventing fraud and security threats, and managing our business operations. We balance our legitimate interests against your privacy rights and only process data when our interests are not overridden by your fundamental rights and freedoms.

Legal Obligation: When we are required to process your data to comply with applicable laws, regulations, court orders, or other legal obligations.

5. How We Share Your Information

We share your personal information only in the following circumstances:

Service Providers and Processors: We engage trusted third-party service providers to perform functions on our behalf, including payment processing, email delivery and marketing automation, SMS messaging services, website hosting and cloud storage, customer relationship management, analytics and data analysis, and technical support. These service providers have access to your personal information only to the extent necessary to perform their functions and are contractually obligated to protect your data and use it only for the purposes we specify. We conduct due diligence on our service providers to ensure they maintain appropriate security and privacy practices.

Legal and Safety Disclosures: We may disclose your information when we believe in good faith that disclosure is necessary to comply with applicable laws, regulations, legal processes, or governmental requests; to enforce our Terms of Service or other agreements; to protect the rights, property, or safety of Paloma's AI Academy, our users, or the public; to detect, prevent, or address fraud, security issues, or technical problems; or to respond to claims that content violates the rights of third parties.

Business Transfers: If we are involved in a merger, acquisition, asset sale, bankruptcy, or other business transaction, your personal information may be transferred or disclosed as part of that transaction. We will notify you via email or prominent notice on our website before your information is transferred and becomes subject to a different privacy policy.

Sale of Personal Information: We do not sell your personal information to third parties for monetary consideration. We do not share your personal information for cross-context behavioral advertising. California residents have the right to opt out of the sale or sharing of personal information, and we honor "Do Not Sell or Share My Personal Information" requests as described in Section 10 below.

6. Marketing Communications and Your Choices

Email Marketing: If you have provided your email address and consented to receive marketing communications, we may send you promotional emails about our courses, services, educational content, special offers, and other information we believe may be of interest to you. Every marketing email we send includes a clear and conspicuous unsubscribe link that allows you to opt out of future marketing emails. You can also unsubscribe by contacting us at hello@palomasacademy.ai. We will process your unsubscribe request promptly, typically within 10 business days as required by the CAN-SPAM Act. Please note that even if you opt out of marketing emails, we will still send you transactional and service-related emails about your account, purchases, and other non-promotional matters.

SMS Marketing: Before sending you marketing text messages, we obtain your prior express written consent as required by the Telephone Consumer Protection Act (TCPA). You can opt out of SMS marketing at any time by replying STOP to any marketing text message you receive from us. You can also reply HELP for assistance or contact us at hello@palomasacademy.ai or +48694437075. Message and data rates may apply depending on your mobile carrier. We will honor your opt-out request immediately and will not send you further marketing messages unless you opt back in.

Consent and Preferences: You can manage your communication preferences and update your consent choices by logging into your account (if applicable) or by contacting us directly. Withdrawing consent for marketing communications does not affect the lawfulness of processing based on consent before its withdrawal.

7. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar tracking technologies to collect information about your browsing activity, remember your preferences, authenticate your sessions, and analyze how our website is used. Cookies are small text files stored on your device that allow us to recognize you on subsequent visits.

We use both first-party cookies (set by us) and third-party cookies (set by our service providers, such as analytics and advertising platforms). Some cookies are essential for the website to function properly, while others are used for analytics, personalization, and marketing purposes.

For detailed information about the specific cookies we use, their purposes, duration, and how to manage your cookie preferences, please refer to our separate Cookie Policy available on our website. You can control cookies through your browser settings, but please note that disabling certain cookies may limit your ability to use some features of our website.

8. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, provide our services, comply with our legal obligations, resolve disputes, enforce our agreements, and maintain accurate business and financial records.

Specifically, we retain account and transaction data for the duration of your relationship with us and for a reasonable period thereafter to address any issues, claims, or legal requirements. We retain marketing communication data until you unsubscribe or request deletion. We retain analytics and usage data in aggregated or anonymized form for longer periods to analyze trends and improve our services. We retain data required for tax, accounting, and legal compliance purposes for the periods mandated by applicable laws, typically between three and seven years depending on the jurisdiction and record type.

When personal information is no longer needed, we securely delete or anonymize it in accordance with our data retention and destruction policies. You may request deletion of your personal data as described in Section 10 below, subject to our legal obligations and legitimate interests in retaining certain information.

9. Data Security

We implement reasonable technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures include encryption of data in transit using SSL/TLS protocols, secure storage of data with access controls and authentication, regular security assessments and updates, employee training on data protection and confidentiality, and contractual protections with our service providers.

However, no method of transmission over the internet or electronic storage is completely secure. While we strive to protect your personal information using industry-standard practices, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity that occurs under your account. Please notify us immediately at hello@palomasacademy.ai if you suspect any unauthorized access to your account or any security breach.

10. Your Privacy Rights

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

GDPR Rights (EU and UK Residents): If you are located in the European Union or United Kingdom, you have the following rights under the GDPR:

• Right of Access: You can request a copy of the personal data we hold about you and information about how we process it.
• Right to Rectification: You can request that we correct inaccurate or incomplete personal data.
• Right to Erasure (Right to be Forgotten): You can request that we delete your personal data in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected or when you withdraw consent.
• Right to Restriction of Processing: You can request that we limit how we use your personal data in certain situations, such as when you contest the accuracy of the data or object to processing.
• Right to Data Portability: You can request a copy of your personal data in a structured, commonly used, and machine-readable format and have it transmitted to another controller where technically feasible.
• Right to Object: You can object to processing based on legitimate interests or for direct marketing purposes. We will stop processing unless we have compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw your consent at any time without affecting the lawfulness of processing before withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with your local data protection authority if you believe we have violated your privacy rights.

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

• Right to Know: You can request that we disclose what personal information we collect, use, disclose, and sell about you, including the categories and specific pieces of information, the sources from which it was collected, the purposes for collection, and the categories of third parties with whom we share it.
• Right to Delete: You can request that we delete the personal information we have collected from you, subject to certain exceptions such as when we need the information to complete a transaction, comply with legal obligations, or exercise our legal rights.
• Right to Correct: You can request that we correct inaccurate personal information we maintain about you.
• Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale of your personal information or the sharing of your personal information for cross-context behavioral advertising. As stated in Section 5, we do not sell or share your personal information for these purposes.
• Right to Limit Use of Sensitive Personal Information: You can request that we limit our use of sensitive personal information to purposes necessary to provide our services. We do not use or disclose sensitive personal information for purposes other than those permitted under the CPRA.
• Right to Non-Discrimination: You have the right to not receive discriminatory treatment for exercising your privacy rights. We will not deny you services, charge different prices, provide different quality of service, or suggest you will receive different treatment for exercising your rights.

Submitting a Request: To exercise any of these rights, please contact us at hello@palomasacademy.ai or +48694437075. Please provide sufficient information to allow us to verify your identity and locate your data in our systems. We may request additional information to confirm your identity and protect against fraudulent requests. We will respond to verified requests within the timeframes required by applicable law, typically 30 days for GDPR requests and 45 days for CCPA requests, with the possibility of extension if necessary.

You may designate an authorized agent to submit requests on your behalf, provided the agent has written permission to act on your behalf and you verify your identity directly with us.

11. International Data Transfers

Paloma's AI Academy operates from Poland, and we may transfer, store, and process your personal information in Poland and other countries where we or our service providers operate. These countries may have data protection laws that differ from those in your country of residence.

For visitors in the European Union and United Kingdom, when we transfer personal data outside the European Economic Area or UK to countries that have not been deemed to provide an adequate level of data protection, we implement appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, adequacy decisions, or other legally recognized transfer mechanisms to ensure your data receives an adequate level of protection.

By using our services and providing your personal information, you acknowledge and consent to the transfer of your data to countries outside your country of residence, including countries that may not provide the same level of data protection as your home country.

12. Children's Privacy

Our services are not directed to, and we do not knowingly collect personal information from, children under the age of 13 (or under 16 for visitors in the European Union and United Kingdom). If we learn that we have collected personal information from a child under these ages without verifiable parental consent, we will delete that information as quickly as possible.

If you are a parent or guardian and believe your child has provided us with personal information without your consent, please contact us immediately at hello@palomasacademy.ai so we can take appropriate action to remove the information from our systems.

13. Third-Party Links and Services

Our website may contain links to third-party websites, applications, services, or resources that are not owned or controlled by Paloma's AI Academy. This Privacy Policy applies only to our services and does not cover the privacy practices of third parties.

We are not responsible for the privacy policies, practices, or content of third-party websites or services. When you click on a third-party link or interact with a third-party service, you are subject to that third party's privacy policy and terms of service. We encourage you to read the privacy policies of any third-party websites or services you visit or use.

If we display testimonials, endorsements, or reviews on our website or in our marketing materials, we will clearly disclose any material connection between us and the person providing the testimonial, in accordance with Federal Trade Commission guidelines (16 CFR Part 255). This includes disclosing if the person received compensation, free products, or other benefits in exchange for their testimonial.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, services, legal requirements, or for other operational, legal, or regulatory reasons. When we make material changes, we will notify you by updating the "Last updated" date at the top of this policy and, where appropriate, by sending you an email notification or displaying a prominent notice on our website.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal information. Your continued use of our services after we post changes constitutes your acceptance of the updated Privacy Policy.

If we make changes that materially reduce your rights or significantly change how we handle your personal information, we will obtain your consent where required by applicable law before applying the changes to data we collected under a previous version of the policy.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our privacy practices, or if you wish to exercise your privacy rights, please contact us:

Paloma's AI Academy Dorota Mleczko Email: hello@palomasacademy.ai Phone: +48694437075 Website: https://palomasacademy.ai

For data protection inquiries or to exercise your GDPR or CCPA rights, you may also contact us at the email address above. We will respond to your inquiry or request as promptly as possible and within the timeframes required by applicable law.

If you are located in the European Union or United Kingdom and are not satisfied with our response, you have the right to lodge a complaint with your local data protection supervisory authority.