Your privacy is important to us. This Privacy Policy explains how Sulba, Inc. ("Company," "we," "our," or "us") collects, uses, stores, shares, and protects information when you use our website, applications, APIs, and AI-powered software platform (collectively, the "Services"). By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Information We Collect

We collect information that you provide directly to us, information that we collect automatically when you use our Services, and information that we receive from third parties. The information we collect depends on how you interact with our platform and the features you choose to use.

When you create an account, purchase a subscription or tokens, contact customer support, or otherwise communicate with us, you may provide personal information such as your name, phone number, email address, company name, title, username, password, reasons for using our Services, and account profile details.

Our AI-powered Services allow you to upload or submit queries, documents, prompts, questions, files, and other information in order to generate responses, documents, and analyses (“User Content”). We may collect and temporarily store the User Content you submit, the files you upload, your conversations with our AI services, the responses generated for you, and any feedback you choose to provide regarding those responses. Unless otherwise stated in a separate written agreement, this information may be processed solely for the purpose of generating responses and operating the Services. We do not use your prompts, uploaded content, conversations, or generated outputs to train our own artificial intelligence models unless you have expressly opted in.

When you use our Services, we also automatically collect certain technical information about your device and your interactions with the platform. This information may include your IP address, browser type, operating system, device information, User-Agent string, session identifiers, cookie identifiers, usage logs, error reports, pages visited, time spent using the Services, and other diagnostic information. This information helps us maintain the security, reliability, and performance of our platform.

2. Cookies and Similar Technologies

We use cookies and similar technologies to authenticate users, maintain secure sessions, remember user preferences, improve platform functionality, analyze usage trends, detect fraudulent activity, and enhance security. Some cookies are necessary for the Services to function properly, while others help us understand how users interact with our platform. You may configure your browser to refuse or delete cookies; however, doing so may prevent certain features of the Services from functioning correctly.

3. How We Use Information

We use the information we collect to provide, operate, maintain, improve, and protect our Services. This includes creating and managing user accounts, authenticating users, processing subscription or token payments, generating AI-powered responses, responding to customer support requests, communicating with users about their accounts, detecting and preventing fraud and abuse, monitoring system performance, improving platform functionality, enforcing our Terms of Service, complying with legal obligations, and sending administrative notices and marketing communications where permitted by applicable law.

4. AI Processing

Our Services utilize artificial intelligence technologies developed by us and, in some cases, trusted third-party AI providers. When you submit prompts or upload content, that information is processed to generate the requested responses. We may temporarily retain prompts and generated outputs for operational purposes, including maintaining service quality, troubleshooting technical issues, investigating misuse, improving reliability, and complying with legal obligations. Unless you have explicitly opted in or otherwise agreed in writing, we do not use your prompts, uploaded content, conversations, or generated outputs to train our own AI models.

5. Payment Information

If you purchase a subscription, tokens, or other paid Services, payment information is processed securely through third-party payment processors. We do not store complete payment card numbers on our own servers. We receive only the information necessary to confirm payment, manage subscriptions/payment for tokens, and provide customer support. Currently, we are using Stripe as our payment processor. By using our Services, you agree to be bound by Stripe’s Terms and Conditions and Privacy Policy.

6. Third-Party Service Providers

We work with carefully selected third-party service providers that assist us in operating the Services. These providers may perform functions such as cloud hosting, payment processing, authentication, AI model processing, customer support, analytics, email delivery, error monitoring, and infrastructure management. These service providers are permitted to access personal information only as necessary to perform services on our behalf and are contractually required to protect the confidentiality and security of that information.

7. Data Retention

We retain personal information only for as long as necessary to provide the Services, maintain your account, comply with legal obligations, resolve disputes, enforce our agreements, and protect our legitimate business interests. When information is no longer required for these purposes, we will securely delete or anonymize it in accordance with our data retention practices and applicable law. Currently, our platform is hosted and operated using Microsoft Azure. You can review Microsoft Azure's Legal Information and Data Protection resources for information about the agreements, privacy commitments, and data-protection terms that may apply to Azure services. Microsoft also provides a Microsoft Privacy Statement explaining how Microsoft processes personal data. Where the GDPR applies, we process personal data only where an appropriate legal basis exists.

8. Data Security

We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. These safeguards include encryption in transit, access controls, authentication systems, security monitoring, and routine software updates. Although we take reasonable measures to protect your information, no method of transmitting or storing data over the Internet can be guaranteed to be completely secure.

9. Sharing of Information

We do not sell your personal information. We may disclose personal information to trusted service providers that assist us in operating our business, when required by law or legal process, to protect the rights, property, or safety of our users or others, in connection with a merger, acquisition, financing, or sale of assets, or with your consent. We may also share aggregated or de-identified information that cannot reasonably be used to identify any individual.

10. Your Privacy Rights

Depending on your jurisdiction, you may have the right to access, correct, update, delete, or export your personal information, as well as the right to object to or restrict certain processing activities or withdraw consent where applicable. Requests to exercise these rights may be submitted by contacting us at legal@sulbasolutions.com. We may request additional information to verify your identity before fulfilling your request.

11. International Data Transfers

Your personal information may be transferred to, stored in, or processed in countries other than the country in which you reside. Where required by applicable law, we implement appropriate safeguards to protect personal information transferred across international borders.

12. Children's Privacy

Our Services are not intended for individuals under the age of 13, or the minimum age required under applicable law. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete that information promptly.

13. California Privacy Rights

California residents may have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, including the rights to know, access, correct, delete, and obtain a copy of their personal information, as well as other rights provided under applicable California law. We do not sell or share personal information for cross-context behavioral advertising as those terms are defined by applicable law.

14. GDPR Privacy Rights

Where the GDPR applies, you may have certain rights concerning your personal data. These rights may include the right to access your personal data, the right to correct inaccurate or incomplete information, the right to request deletion of your personal data, the right to request restriction of processing, the right to object to certain processing activities, the right to data portability, and the right to withdraw consent where processing is based on consent.

You may also have the right not to be subject to a decision based solely on automated processing where the applicable legal requirements are satisfied. These rights are subject to certain exceptions and limitations established by applicable law.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or business operations. If we make material changes, we will update the "Last Updated" date at the beginning of this Privacy Policy and provide additional notice where required by applicable law.

16. Contact Us

If you have any questions about this Privacy Policy or our privacy practices, or if you wish to exercise your privacy rights, please contact us at legal@sulbasolutions.com or through the contact information provided on our website.

The entity responsible for this Privacy Policy is:

Sulba, Inc.
2350 E Germann Rd, Suite 30-22
Chandler, AZ 85286
United States of America
Email: legal@sulbasolutions.com

If required by applicable law, our Data Protection Officer or privacy representative can be contacted at:

Data Protection Officer / Privacy Representative
Email: legal@sulbasolutions.com
Address:
2350 E Germann Rd, Suite 30-22
Chandler, AZ 85286
United States of America

17. Right to File Complaint

If you believe that we have processed your personal data unlawfully or have otherwise violated applicable data-protection requirements, you may contact us so that we can investigate and attempt to resolve your concern.

You also have the right to lodge a complaint with a data-protection supervisory authority. If you are located in the European Union or European Economic Area, you may generally contact the supervisory authority in the country where you reside, work, or where you believe an infringement occurred.