Privacy Notice

Last updated: August 19, 2026

We at Pelles.AI Inc. (“us”, “we”, or “our”) recognize and respect the importance of maintaining the privacy of our customers and their end users. This Privacy Notice describes the types of information we collect from you when you visit our website and/or platform (“Platform”) and/or use our services thereon (such services, together with the Site, the “Services”). This Privacy Notice also explains how we process, transfer, store and disclose the information collected, as well as your ability to control certain uses of the collected information. If not otherwise defined herein, capitalized terms have the meaning given to them in our End User License Agreement (“Terms”). “You” means an individual using the Services.

“Personal Data” means any information that refers, is related to, or is associated with an identified or identifiable individual or as otherwise may be defined by applicable law. This Privacy Notice details which Personal Data we collect when we provide the Services to you.

1. Personal Data We Collect

1.1. In order to use our Services, and/or make a purchase through the Platform you will be required to register and provide us with certain Personal Data, such as end users' name and email address.

1.2. We also collect Personal Data when you make use of the Platform, request information from us, sign up for newsletters or our email lists, complete online forms, or contact us for any other reason. If you use the Services by logging in through a third-party login service, such as Google or Microsoft, we may also receive Personal Data about you as provided by such third-party login service. Please check such third-party's policies in order to understand what information we receive. Examples of the Personal Data that we collect from you when you engage in any of the activities detailed above, may include your name, address, phone number, employer/engaging company, position, role, e-mail address. Such Personal Data may be collected by us through the Platform.

1.3. We also collect any materials including images and/or pictures and/or photos and/or documents you may upload to the Platform, and any content you make available to us by connecting a third-party system (such as your ERP or CRM) to the Services. Such materials may contain Personal Data relating to you or to other individuals, for example your employees or subcontractors. Where you provide such materials, you are responsible for ensuring that you have the rights and any consents necessary to do so, and we process that content in order to provide the Services to you. Where such materials are provided by a business customer in connection with our provision of the Services to that customer, we process the Personal Data they contain solely as a service provider/processor acting on that customer's instructions and in accordance with our data processing agreement with that customer; individuals whose Personal Data appears in such materials (for example, a customer's employees or subcontractors) should direct any requests regarding their Personal Data to that customer directly.

1.4. If you choose to use our SMS/text messaging features, including communicating with the Pelles Agent by text message, we collect your mobile phone number, your consent (opt-in) records, and the content of the text messages you send and receive through the Services.

1.5. In addition, when you use the Platform, we may gather certain information automatically about your computer or mobile device, such as your operating system, your IP address, device ID, general location information (such as city or region) derived from your IP address, as well as your browsing history and any other information regarding your use, viewing, and purchase history on our Platform. We do not collect precise (GPS-level) geolocation from your device.

1.6. You are under no legal obligation to provide us with any such Personal Data. It is your voluntary decision whether to provide us with any Personal Data, but if you refuse to provide such information, we may not be able to register you to the Platform and/or provide you with certain Services.

2. How We Use Your Personal Data

2.1. General. We and any of our trusted third-party subcontractors and service providers use the Personal Data we collect from and about you for any of the following purposes: (1) to provide you with the Services; (2) to respond to your inquiries or requests, contact and communicate with you; (3) to develop new products or services and conduct analyses to improve our current content, products, and Services; (4) to provide you with customized content, targeted offers, and advertising on the Site/App/Platform, on other third-party sites or apps you may visit, or via e-mail, (5) to contact you with informational newsletters and promotional materials relating to our Platform and Services; (6) to review the usage and operations of our Platform and Services; (7) to use your data in an aggregated, non-specific format for analytical purposes (as detailed below); (8) to prevent fraud, protect the security of our Platform and Services, and address any problems with the Platform and/or Services; and (9) to provide customer support.

2.2. Statistical Information and Analytics. We and/or our service providers use analytics and marketing tools, including Google Analytics and HubSpot, to collect and analyze information about the use of the Services, such as how often users visit the Site, what pages they visit when they do so, and what other sites and mobile applications they used prior to visiting the Site. By analyzing the information we receive, we may compile statistical information across a variety of platforms and users. This helps us improve our Services by allowing us to identify new trends and customer needs, which in turn allows us to consider new products and services or tailor existing products and services accordingly. You can find more information about how Google collects information and how you can control such use at https://policies.google.com/technologies/partner-sites.

2.3. Google Workspace APIs are not used to develop, improve, or train generalized AI and/or ML models.

2.4. SMS/Text Messaging. If you have opted in to receive text messages from us, we use your mobile phone number to send you SMS messages, including verification codes, account and service notifications, and responses from the Pelles Agent, via our telecommunications service providers (such as Twilio) using a toll-free phone number. See Section 10 (SMS/Text Messaging) below for further details, including how to opt out.

2.5. AI Features and Model Training. We do not use your content, including your documents, prompts, and AI-generated outputs (“Customer Content”), to train or improve AI models that are used to serve other customers, unless you expressly opt in or otherwise provide your explicit authorization. We may process Customer Content as necessary to provide, maintain, secure, support, troubleshoot, and improve the Services and AI features, including through quality assurance, performance monitoring, and abuse prevention, in accordance with this Privacy Notice and applicable law.

2.5.1. Third-Party AI Providers. We use third-party artificial intelligence providers to process Customer Content in order to generate responses for you, for example when you use the Pelles Agent. Such providers act as our service providers as described in Section 3.2.

2.5.2. Dedicated Models. We may offer to train a model dedicated to your organization using your organization's own Customer Content, in order to improve results for you. Any such model, and its outputs, will be used only for your organization and never to serve any other customer. We will do so only with your organization's agreement, which you may withdraw at any time.

3. Sharing the Personal Data We Collect

We share your information, including Personal Data, as follows:

3.1. Affiliates. We share information, including your Personal Data, with our affiliated company, Pelles.AI Ltd. where this is necessary to provide you with our products and Services, and for business management purposes.

3.2. Service Providers and Subcontractors. We disclose information, including Personal Data we collect from and/or about you, to our trusted service providers and subcontractors, who use such information to: (1) help us provide you with the Services; (2) aid in their understanding of how users are using our Services. Such service providers and subcontractors provide us with IT and system administration services, data backup, security, and storage services, data analysis, and communications delivery services (for example, Twilio, which delivers our SMS/text messages).

3.3. International Transfers. We may use subcontractors and service providers who are located in countries other than your own and may send them information we receive (including Personal Data). Where we do so, we take steps designed to ensure that your Personal Data receives a level of protection consistent with this Privacy Notice and applicable law.

3.4. Business Transfers. Your Personal Data may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such case, your Personal Data shall continue being subject to the provisions of this Privacy Notice.

3.5. Law Enforcement Related Disclosure. We may share your Personal Data with third parties: (i) if we believe in good faith that disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms and this Privacy Notice); (ii) as is necessary to comply with any legal and/or regulatory obligation; or (iii) when required by subpoena, court order or the order of another governmental or law enforcement authority.

3.6. Legal Uses. We may use your Personal Data as required or permitted by any applicable law, for example, to comply with audit and other legal requirements.

3.7. Advertising, Analytics, and Marketing Partners. We use third-party advertising, analytics, and marketing services (such as Google and HubSpot) that, subject to your consent as described in Section 7, may set cookies or similar technologies on your device to measure the performance of our advertising campaigns, to understand how you interact with our Site and communications, and to show you relevant ads for our own products and services. In connection with these services, such partners may collect identifiers such as cookie IDs, device identifiers, and IP address. We do not otherwise disclose your Personal Data to advertisers, and you can withdraw your consent at any time through the cookie settings on our Site.

3.8. Other Uses or Transfer of Your Personal Data. If you use our Platform and/or Services with or through a third-party service, site and/or mobile application, we may receive information (including Personal Data) about you from those third parties. Please note that when you use third parties outside of our Platform and/or Services, their own terms and privacy policies will govern your use of those services.

3.9. No Sale of Personal Data. We do not sell your Personal Data for monetary consideration. We use analytics and advertising cookies and tags as described in Section 7, and only to the extent you have consented to them; you can change or withdraw that consent at any time through our cookie settings.

3.10. No Sharing of Mobile Information and Text Messaging Consent. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with, sold, rented, or transferred to any third parties.

4. Security

We make efforts to follow generally accepted industry standards to protect the Personal Data submitted to and collected by us, both during transmission and once we receive it. However, no method of transmission over the Internet or method of electronic storage is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. As the security of information depends in part on the security of the computer you use to communicate with us and the security you use to protect user IDs and passwords, please take appropriate measures to protect this information.

5. Your Rights

Subject to applicable law, you may request access to, or a copy of, the Personal Data we hold about you, and request that such Personal Data be corrected, updated, or deleted, by emailing us at [email protected]. We may ask you for information reasonably necessary to verify your identity before acting on a request, and we will respond within the timeframes required by applicable law. We will not discriminate against you for exercising any of your privacy rights. Depending on where you live, you may also have the right to appeal a decision we make regarding your request; you may do so by replying to our response or by contacting us at the same address with the subject line “Privacy Appeal”.

6. Data Retention

6.1. Subject to applicable law, we retain Personal Data as necessary for the purposes set forth above. We may delete information from our systems without notice to you once we deem it is no longer necessary for these purposes.

6.2. In some circumstances, we may store your Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, regulatory, tax, audit, accounting requirements and so that we have an accurate record of your dealings with us in the event of any complaints or challenges, or if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.

6.3. We retain records of your consent to receive text messages, and of any opt-out, for as long as necessary to comply with our legal obligations and to demonstrate that such consent was given or withdrawn.

7. Cookies and Similar Technologies

We use cookies and similar technologies for a number of reasons, including to help personalize your experience. Third parties through which we provide the Services and/or our business partners may be placing and reading cookies on your browser or using web beacons to collect information in the course of advertising being served on different websites. When visiting this Platform, you shall be notified of the use and placement of cookies and other similar technologies on your device as specified herein.

7.1. What are Cookies? A cookie is a small piece of text that is sent to a user's browser or device. The browser provides this piece of text to the device of the originating user when this user returns.

7.1.1. A “session cookie” is temporary and will remain on your device until you leave the Platform.

7.1.2. A “persistent” cookie may be used to help save your settings and customizations across visits. It will remain on your device until you delete it.

7.1.3. We may use the term “cookies” to refer to all technologies that we may use to store data in your browser or device or that collect information or help us identify you in the manner described above, such as web beacons or “pixel tags”.

7.1.4. First-party cookies are placed by us, while third-party cookies may be placed by a third party. We use both first- and third-party cookies.

7.2. How We Use Cookies. We use cookies and similar technologies for a number of reasons, as specified below. The specific names and types of the cookies, web beacons, and other similar technologies we use may change from time to time. However, the cookies we use generally fall into one of the following categories:

Necessary – These cookies are necessary in order to allow the Platform to work correctly. They enable you to access the Platform, move around, and access different services, features, and tools. Examples include remembering previous actions (e.g. entered text) when navigating back to a page in the same session. These cookies cannot be disabled.

Functionality – These cookies remember your settings and preferences and the choices you make (such as language or regional preferences) in order to help us personalize your experience and offer you enhanced functionality and content.

Security – These cookies can help us identify and prevent security risks. They may be used to store your session information to prevent others from changing your password without your login information.

Performance/Analytics – These cookies can help us collect information to help us understand how you use our Platform, for example whether you have viewed messages or specific pages and how long you spent on each page. This helps us improve the performance of our Platform.

Advertising – These cookies are placed in order to deliver content, including ads relevant and meaningful to you and your interests. They may also be used to deliver targeted advertising or to limit the number of times you see an advertisement. This can help us track how efficient advertising campaigns are, both for our own Services and for other websites. Such cookies may track your browsing habits and activity when visiting our Platform and those of third parties.

7.3. How to Adjust Your Preferences. Most Web browsers are initially configured to accept cookies, but you can change this setting so your browser either refuses all cookies or informs you when a cookie is being sent. In addition, you are free to delete any existing cookies at any time. Please note that some features of the Services may not function properly when cookies are disabled or removed. For example, if you delete cookies that store your account information or preferences, you will be required to input these each time you visit. You can also review and change your cookie preferences at any time through the cookie settings link available on our Site; non-essential cookies are used only where you have consented to them.

7.4. By changing your device settings, you can prevent your device's ad identifier being used for interest-based advertising, or you can reset your device's ad identifier. Typically, you can find the ad identifier settings under “privacy” or “ads” in your device's settings, although settings may vary from device to device. Adjusting your preferences as described in this section herein does not mean you will no longer receive advertisements; it only means the advertisements that you do see will be less relevant to your interests.

8. Third-Party Applications and Services

All use of third-party applications or services is at your own risk and subject to such third party's terms and privacy policies.

9. Communications

We reserve the right to send you service-related communications, including service announcements and administrative messages, without offering you the opportunity to opt out of receiving them. Should you not wish to receive such communications, you may cancel your user (account). This Section does not apply to SMS/text messages: you may opt out of text messages at any time as described in Section 10 below, and we will honor that request regardless of this Section.

10. SMS/Text Messaging

10.1. Opt-In. We send SMS/text messages, including verification codes, account and service notifications, and responses from the Pelles Agent, only to individuals who have expressly opted in to receive them, for example by providing their mobile phone number and checking the consent box in the Platform. Consent to receive text messages is not a condition of purchasing any goods or services.

10.2. Message Frequency and Rates. Message frequency varies depending on your use of the Services. Message and data rates may apply; any such charges are billed by, and payable to, your mobile carrier.

10.3. Opt-Out and Help. You can opt out of receiving text messages at any time by replying STOP to any message you receive from us, or by removing your phone number in your account settings. After you opt out, you may receive a single message confirming your opt-out. For assistance, reply HELP to any message or contact us at [email protected].

10.4. No Third-Party Sharing. As set forth in Section 3.10 above, no mobile information will be shared with third parties or affiliates for marketing or promotional purposes, and text messaging originator opt-in data and consent will not be shared with any third parties. Your mobile phone number and message content are disclosed only to our telecommunications service providers (such as Twilio) solely to deliver messages you have requested.

11. Children

The Services are not intended for, or directed to, anyone under the age of 18, and we do not knowingly collect Personal Data from anyone under the age of 18. In the event that you become aware that an individual under 18 has provided us with Personal Data, please advise us immediately at [email protected] and we will delete it.

12. Changes to the Privacy Notice

We may update this Privacy Notice from time to time to keep it up to date with legal requirements and the way we operate our business, and we will place any updates on this webpage. Please come back to this page every now and then to make sure you are familiar with the latest version. If we make material changes to this Privacy Notice, we will seek to inform you by notice on our Site or via email.

13. Comments and Questions

If you have any comments or questions about this Privacy Notice or if you wish to exercise any of your legal rights as set out herein, please contact us at [email protected].

Supplemental Privacy Notice for California Residents

Last updated: August 19, 2026

This Supplemental Privacy Notice for California Residents (“CA Supplement”) supplements and forms an integral part of our general privacy notice (“Privacy Notice”). This CA Supplement describes how we collect, share, and store personal information about California residents who use our Site and/or Services, as well as the rights they have with respect to that information. If not otherwise defined herein, capitalized terms have the meaning given to them in our Privacy Notice. Please read the Privacy Notice for additional terms that may apply to you. Any reference to a 12-month period herein shall mean the period within such 12-month period in which the Site or your user has been active (as applicable).

“Personal Information” means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise may be defined by applicable law.

Depending on your usage, we collect different types of information and we and any of our third-party sub-contractors and service providers use the information we collect for different purposes, as specified below. It is your voluntary decision whether to provide us with certain Personal Information, but if you refuse to provide such Personal Information, we may not be able to register you and/or provide you with the Services or part thereof.

This CA Supplement will cover the following topics:

Categories of Personal Information We Collect
How We Share Your Personal Information
Your Rights - How to Access and Limit Our Use of Certain Personal Information
How to Contact Us

1. Categories of Personal Information We Collect

In the past twelve months, we have collected the following categories of Personal Information from users of our Site and/or Services. This Personal Information is used for the purposes described in the Privacy Notice.

1.1. Registration Information. In order to use our Services, you will be required to register and provide us with the following identifiers directly: your name, email address, address, employer/engaging company, position, role, and phone number. If you use the Services by logging in through a third-party login/account registration service (such as Google or Microsoft), we also receive certain identifiers about you indirectlyas provided by such third-party service, as determined by such third party's policies and your preferences.

1.2. Payment Information. If you purchase a subscription or other paid Services, you may be directed to a third-party payment processor in order to make payments to us, in which case, we receive certain identifiers from such payment processor, such as the last four digits of your credit card number. We do not collect or store full payment card numbers.

1.3. Contact Information. If you contact us, we collect certain identifiers directly from you, such as your name, email address, and the content of your message.

1.4. Device/Network Information. When you use the Site or Services, we will collect information about your device automatically, including non-Personal Information such as your operating system and browser type, identifiers such as your IP address or device ID, and internet and other electronic network activity such as your browsing history and usage data.

1.5. Product/Usage Information. We collect commercial information regarding your subscription to and use of the Services, including your plan, the features you use, and the applicable pricing. We collect this information automatically.

2. How We Share Your Personal Information

2.1. Sharing for Business Purposes. In the past 12 months, we may have disclosed the following categories of Personal Information for the following business or purpose in the preceding 12 months: we may have shared your personal identifiers and internet or other electronic network activity with data analytics providers, operating systems, and other third parties that assist us in providing you with the Services, including providing us with IT and system administration services, data backup, security, and storage services, and providing data analytics services, and to help us serve advertisements and provide other marketing services, as well as with our affiliates as necessary to provide you with services. No mobile information is shared with third parties or affiliates for marketing or promotional purposes; text messaging originator opt-in data and consent are excluded from all of the above and are not shared with any third parties.

2.2. Additional Sharing Activities.

2.2.1. Affiliates. We share information, including your Personal Information, with our affiliated company, Pelles.AI Ltd., where this is necessary to provide you with the Site and Services, and for the purpose of management of our business.

2.2.2. Business Transfers: Your Personal Information may be disclosed as part of, or during negotiations of, any merger, sale of company assets or acquisition (including in cases of liquidation). In such a case, your Personal Information shall continue being subject to the provisions of this CA Supplement.

2.2.3. Law Enforcement Related Disclosure: We may share your Personal Information with third parties: (i) if we believe in good faith that such disclosure is appropriate to protect our or a third party's rights, property or safety (including the enforcement of the Terms, the Privacy Notice, and this CA Supplement); (ii) when required by law, regulation subpoena, court order or other law enforcement related issues, agencies and/or authorities; or (iii) as is necessary to comply with any legal and/or regulatory obligation.

2.2.4. Other Uses or Transfer of Your Personal Information: If you use our Services together with or through a third-party service, site and/or mobile application, we may receive information (including Personal Information) about you from those third parties. Please note that when you use third parties outside of our Site or Services, their own terms and privacy policies will govern your use of those services.

3. Your Rights - How to Access and Limit Our Use of Certain Personal Information

Subject to certain exemptions, you have certain rights in relation to the Personal Information that we have collected about you, as detailed below. In accordance with applicable law, we may ask for reasonable evidence to verify your identity before we comply with certain of your requests, as detailed below.

3.1. Your Rights

3.1.1. Right to Know and Access. You have the right to request that we disclose to you any or all of the following in respect of the 12-month period preceding your request:

The specific Personal Information we have collected about you.
The categories of Personal Information we have collected about you.
The categories of sources from which we collected the Personal Information about you.
The categories of third parties to whom we disclose Personal Information about you.
The categories of Personal Information about you we have sold and the categories of third parties to whom we have sold such Personal Information.
The categories of Personal Information about you we have disclosed for a business purpose and the categories of third parties to whom we have disclosed such Personal Information.
Our business or commercial purpose(s) for collecting or selling your Personal Information.

3.1.2. Right to Delete. Subject to certain exceptions, you have the right to request that we and any of our service providers delete your Personal Information.

3.1.3. Right to Correct. If you find that any of the information we've collected about you is inaccurate, you have the right to correct such information.

3.1.4. Right to Opt-Out of the Sale of or Sharing Personal Information. As described in Section 3.3 below and subject to the caveats therein, we do not sell your Personal Information, but we do ‘share’ it to a limited extent for advertising. You can tell us to stop sharing at any time, and if we ever sell, to stop that too. We may deny any request to opt-out of the sale or sharing of Personal Information that we deem in our good-faith, reasonable and documented belief is fraudulent.

3.1.5. Right to Non-Discrimination for Exercising your Consumer Privacy Rights. You have the right not to be discriminated against for exercising any of your consumer privacy rights, such as, not being denied any goods or services or charged different prices or rates.

3.1.6. Right to Limit our Use of Your Personal Information. To the extent we collect any sensitive Personal Information about you, you have the right to instruct us to limit our use of such Personal Information only for the purpose of providing you with our services and certain business operation purposes.

3.2. How to Exercise your California Privacy Rights

3.2.1. Contact Information. To exercise any of the rights detailed above, please submit a verifiable request to us by contacting us at [email protected]. You may only request to exercise your right of access twice within a 12-month period.

3.2.2. Submitting a Verifiable Request: In order to exercise your right to know or right to delete you must submit a request containing sufficient information that allows us to reasonably verify you are the person about whom we collected the applicable Personal Information or an authorized agent of such person, which may include details relating to your account. Any requests made through your password protected account will be verified through our existing authentication procedures for such account.

3.2.3. Submitting Requests through an Authorized Agent: An authorized agent may exercise requests on your behalf. In order to exercise your right to know or right to delete through an agent, we may ask for reasonable evidence to verify your identity and the agent's identity, and written authorization permitting the agent to act on your behalf before complying with your request. In order to submit a request to opt-out of the sale of your Personal Information through an agent, we may ask for written authorization permitting the authorized agent to act on your behalf before complying with your request. We reserve the right to deny the request of any agent that does not provide proof that they have been authorized to act on behalf of the applicable consumer in accordance with applicable law.

3.3. Do Not Sell or Share My Personal Information

3.3.1. We do not sell your Personal Information for monetary consideration. We do, however, “share” your Personal Information, as that term is defined under the CCPA/CPRA, with our advertising partners such as Google for purposes of cross-context behavioral advertising, as described in Section 3.7 of the Privacy Notice and Section 2.1 above. We use analytics and advertising cookies and tags, as described in Section 7 of the Privacy Notice, only to the extent you have consented to them, and you can change or withdraw that consent at any time through our cookie settings. You may also opt out of this sharing at any time as described in Section 3.3.2 below.

3.3.2. If you nonetheless wish to direct us not to sell or share your Personal Information, as described in Section 3.1.4 above, please email us at [email protected]with the subject line “Do Not Sell or Share My Personal Information”, or submit a request through an authorized agent as described in Section 3.2.3. We will respond to your request within the timeframes required by applicable law.

4. Retention

4.1. We retain your Personal Information as long as necessary to fulfill each of the purposes we described above. Once your Personal Information is no longer necessary for these purposes, we delete it in accordance with our retention practices and applicable law.

4.2. When deciding how long to store Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized access, the purposes for which the Personal Information was collected, as well as applicable legal requirements. Please note that we may delete information from our systems without notifying you first. Retention by any of our service providers or subcontractors may vary in accordance with each business's retention policy.

5. Children

We do not knowingly sell the Personal Information of California residents under 16 years of age.

6. How to Contact Us

If you have any comments or questions about this CA Supplement or our privacy practices, or if you wish to exercise any of your legal rights as set out herein, please contact us at [email protected].