1. Introduction

This Privacy Policy describes how Fifty Two Summits LLC, doing business as Wellbots AI (“Wellbots AI”, “Company”, “we”, “us”, or “our”), collects, uses, processes, discloses, and protects your personal information when you use our website located at wellbots.ai (“Website”) and our artificial intelligence-based services, including customer-facing chatbots and internal AI agents and processes (collectively, the “Service”). This policy also covers how we handle Service Data (as defined in our Terms of Service) provided by our business clients.

By accessing or using our Website or Service, you agree to the terms of this Privacy Policy and our Terms of Service. We may update this policy from time to time, and the latest version will be posted on our Website with the updated effective date. Your continued use of the Website or Service after any changes indicates your acceptance of the revised policy.

2. Personal Information We Collect

We collect information to provide and improve our Service. The types of personal information we collect depend on how you interact with our Website and Service and may include:

Information You Provide Directly:

• Account Information: When you create an Account, we collect information such as your name, email address, phone number, company name, business entity name, VAT number, and login credentials (if not using third-party sign-in).
• Billing Information: If you subscribe to our Service, we collect payment information, including credit/debit card details, billing address, and other necessary payment processing information.
• Communication Information: Records of your communications with us, such as customer support inquiries, feedback, and other correspondence.
• Content: Information or materials you post, upload, or submit directly through the Website interface or Service features (excluding Service Data).

Information Collected Automatically:

• Usage Data: Information about how you access and use the Website and Service, including your activity on the platform, features used, time spent, and pages visited.
• Device and Browser Information: Information about the device and browser you use, such as IP address, device type, operating system, browser type, unique device identifiers, and mobile network information.
• Log Data: Server logs that automatically record information when you use our Website or Service, such as IP address, browser type, referring pages, pages visited, and timestamps.
• Cookies and Tracking Technologies: We use cookies and similar tracking technologies (like pixels and web beacons) to collect information about your browsing behavior, remember your preferences, and for analytics and advertising purposes. You can manage your cookie preferences through your browser settings.

3. Service Data (Data Processed for Business Clients)

When our business clients use the Service (e.g., implementing a chatbot on their website), they may input or provide access to data related to their customers or operations ("Service Data").

• Wellbots AI's Role: In processing Service Data, Wellbots AI acts as a service provider or data processor on behalf of our business clients, who are the data controllers.
• Our Use of Service Data: We process Service Data solely to provide and maintain the Service for our clients, including configuring, training, and operating the specific AI chatbots or agents for their intended use.
• Client's Responsibility: Our clients are responsible for the legality of the Service Data they provide to us and for obtaining any necessary consents from individuals whose data is included in the Service Data, in accordance with applicable privacy laws.
• No Independent Use: We do not use Service Data to train or improve our general AI models unless explicitly agreed upon in a separate agreement with the client. Any use of Service Data for aggregated, anonymized analytics or service improvement that does not identify our clients or their end-users will be in accordance with this Privacy Policy.

4. How We Use Your Personal Information

We use the personal information we collect for various business purposes, including:

• Providing and Maintaining the Service: To operate, maintain, and provide the features and functionality of the Website and Service.
• Managing Your Account: To create and manage your account, process subscriptions and payments, and provide customer support.
• Communication: To send you service-related notifications, updates, security alerts, and administrative messages. With your consent (where required), to send you marketing and promotional communications.
• Improving and Developing the Service: To understand how the Website and Service are used, analyze trends, and improve existing features and develop new products and services.
• Personalization: To personalize your experience on the Website and Service.
• Security and Fraud Prevention: To detect, prevent, and address technical issues, security incidents, and fraudulent or illegal activity.
• Compliance and Legal Obligations: To comply with applicable laws, regulations, legal processes, and enforce our Terms of Service.
• Analytics: To monitor and analyze usage of the Service (as detailed in Section 13 of our Terms of Service regarding Google Analytics and Mixpanel).

5. Legal Bases for Processing (Applicable to GDPR/Similar Laws)

If you are located in a jurisdiction that requires a legal basis for processing personal data (such as the European Union or United Kingdom under GDPR), our legal bases depend on the context:

• Performance of a Contract: To fulfill our obligations under the Terms of Service and provide the Service you requested.
• Legitimate Interests: For our legitimate business interests, such as improving our Service, marketing (where not requiring consent), fraud prevention, and security, provided these interests are not overridden by your data protection rights.
• Consent: Where required by law, we process your personal data based on your consent, such as for sending marketing communications. You can withdraw your consent at any time.
• Legal Obligation: To comply with legal obligations, such as responding to legal requests or enforcing our terms.

6. How We Share Your Personal Information

We may share your personal information with third parties in the following circumstances:

• With Service Providers: We share information with third-party vendors and service providers who perform services on our behalf, such as payment processing, hosting, analytics (e.g., Google Analytics, Mixpanel), customer support, and marketing assistance. These service providers are authorized to use your personal information only as necessary to provide these services to us.
• With Business Clients: We process Service Data as a processor for our business clients. The handling of this data is governed by our agreement with the client and their own privacy policy.
• Affiliates: We may share information with our affiliated entities for business purposes.
• Business Transfers: In connection with or during negotiation of any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
• Legal Requirements: We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court order or a request from law enforcement).
• Protection of Rights: To enforce our Terms of Service, protect our rights, privacy, safety, or property, and that of our users or the public.
• With Your Consent: We may share your information with third parties when we have your explicit consent to do so.

7. Data Security

We implement reasonable technical and organizational measures designed to protect your personal information from unauthorized access, use, alteration, and disclosure. However, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

8. Data Retention

We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

9. Your Data Protection Rights

Depending on your location and applicable law (such as CCPA for California residents or GDPR for EU/UK residents), you may have certain rights regarding your personal information. These rights may include:

• Right to Access: Request access to the personal information we hold about you.
• Right to Rectification: Request correction of inaccurate or incomplete personal information.
• Right to Erasure: Request deletion of your personal information, subject to certain legal exceptions.
• Right to Object: Object to the processing of your personal information in certain circumstances.
• Right to Restriction: Request the restriction of processing of your personal information in certain circumstances.
• Right to Data Portability: Request a copy of your personal information in a structured, commonly used, machine-readable format.
• Right to Withdraw Consent: Withdraw your consent at any time where we rely on consent to process your personal information.
• Right to Opt-Out of Sale/Sharing: If applicable under laws like the CCPA, the right to opt-out of the "sale" or "sharing" of your personal information. Wellbots AI does not "sell" personal information in the traditional sense. However, certain data sharing (e.g., for targeted advertising) may be considered "sharing" under the CCPA. We will provide mechanisms to exercise this right if applicable.

To exercise any of these rights, please contact us using the contact details provided in the "Contact Us" section below. We may need to verify your identity before fulfilling your request.

For Service Data processed on behalf of our business clients, any requests regarding data contained within the Service Data should be directed to the respective business client (the data controller). We will cooperate with our clients to fulfill such requests as required by applicable law.

10. Children's Privacy

Our Service is not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us, and we will take steps to remove such information from our systems.

11. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Modified" date at the top. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

12. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

By email: info@wellbots.ai

By mail:

Fifty Two Summits LLC DBA Wellbots AI

4913 Canelo Ct SE

Rio Rancho, NM 87124

United States