Dabudai

PRIVACY POLICY

Last Updated: January 2026

This Privacy Notice for Dabudai on behalf of Polt House Inc. (“Company,” “we,” “us,” or “our”) explains how and why we collect, store, use, and share (“process”) your personal information when you interact with our website or related services (“Services”), including when you:

• Visit our website at https://dabud.ai or any other website that links to this Privacy Notice
• Use our analytics and AI-based recommendation platform for business and agency visibility tracking
• Communicate with us in connection with sales, support, marketing, or other business activities

If you have any questions or concerns about this Privacy Notice, please review it carefully to understand your rights and choices. We are responsible for determining how and why your information is processed.

If you do not agree with this policy, please refrain from using our Services.

1. INFORMATION WE COLLECT

Personal Information You Provide to Us

In short: We collect personal information that you voluntarily provide.

We collect personal information that you provide directly when you register for our Services, request information, participate in marketing or analytics activities, or communicate with us.

The personal information we collect may include:

• Full name
• Company name
• Email address
• Job title or role
• Phone number — collected to provide account support, onboarding assistance, and, where you have provided consent, to contact you by phone for commercial communications related to our Services.
• Account login credentials (if applicable)
• Client or ICP (Ideal Customer Profile) data that you submit for analysis

Sensitive Information. We do not knowingly collect or process sensitive personal data (such as health, biometric, or financial account data) unless explicitly required and consented to by you.

Payment Data. If you make payments through our Services, we collect information necessary to process your transaction — such as card type, expiration date, and billing address. Payment processing is securely handled by Stripe, PayPal, or WayForPay.

You can review their privacy notices here:

• Stripe Privacy Policy
• PayPal Privacy Policy
• WayForPay Privacy Policy

All personal data provided must be accurate and kept up to date. You agree to promptly notify us of any changes.

Information Automatically Collected

In short: We automatically collect limited technical and usage information when you use the Services.

When you visit or interact with our Services, we automatically collect data that does not directly identify you, such as:

• IP address and approximate geographic location
• Browser type and version
• Device type and operating system
• Language and time zone settings
• Referring URLs and access timestamps
• Interaction and usage logs (e.g., pages visited, buttons clicked)

This information helps us maintain the security and functionality of our Services, perform analytics, and improve user experience.

Like most companies, we also use cookies and similar technologies. For details on our use of cookies, please refer to our separate Cookies Policy.

Types of Automatically Collected Data

• Log and Usage Data: Diagnostic, performance, and usage details automatically recorded by our servers. This includes IP address, browser type, operating system, and actions performed (such as logins, searches, or feature usage).
• Device Data: Information about your device such as its hardware model, operating system, mobile carrier, and browser configuration.
• Location Data: We may collect location-related information derived from your IP address or device settings. You can opt out of sharing location data by adjusting your device settings, but certain features may not function properly.

2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process personal data to provide, improve, and secure our Services, communicate with you, comply with legal obligations, and operate our business responsibly.

We process your personal information for the following purposes, depending on your interactions with the Services:

• To create and manage your account. We use your data to enable registration, authentication, and ongoing maintenance of your user profile.
• To deliver and improve our Services. Your information is used to provide the analytics, insights, and AI-driven recommendations that are part of our platform, and to enhance their accuracy and performance.
• To communicate with you. We use your contact details to respond to inquiries, provide customer support, and deliver essential service notifications or administrative messages.
• To personalize user experience. We may analyze aggregated data to improve our user interface, suggest relevant insights, and optimize system performance.
• To perform analytics and product improvement. Your usage data helps us train, test, and refine our AI models and improve the precision of analytics across client segments.
• To contact you by phone. Where you have provided explicit consent, we may contact you by telephone for account support, onboarding, and commercial communications. You may withdraw this consent at any time by contacting us at cyrilpoltavets@dabud.ai.
• For marketing and communications. With your consent, we may send product updates, newsletters, or marketing materials through email or chat-based communication. You may opt out at any time.
• For security and fraud prevention. We process certain data to monitor suspicious activity, protect against unauthorized access, and ensure compliance with applicable laws.
• To comply with legal and regulatory obligations. We may process or retain data where necessary to fulfill our obligations under applicable law, taxation, or compliance frameworks.
• To protect vital interests. In rare cases, we may process data to protect the safety or vital interests of a person.

We will only process your information for additional purposes with your explicit consent.

2.1 Telephone Communications & TCPA Compliance (U.S. Users)

By providing your phone number and checking the consent box during registration, you expressly consent to receive telephone calls from Dabudai at the number provided. Calls may be made for account support, onboarding, and commercial communications. This consent is not a condition of purchase or use of our Services.

You may opt out of telephone communications at any time by:

• Informing the caller directly during a call;
• Emailing us at cyrilpoltavets@dabud.ai with the subject line "Do Not Call";
• We will honor your request within 10 business days.

We maintain an internal Do-Not-Call list and do not call numbers registered on the U.S. National Do Not Call Registry for unsolicited marketing purposes.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In short: We process your personal information only when we have a lawful basis to do so — such as your consent, our contractual obligations, our legitimate business interests, or compliance with legal requirements.

If you are located in the European Union (EU) or United Kingdom (UK)

Under the General Data Protection Regulation (GDPR) and UK GDPR, we rely on the following legal bases:

• Performance of a Contract. Processing your information is necessary to perform our obligations under a contract with you, such as providing access to our analytics platform, or to take steps at your request prior to entering into a contract.
• Consent. Where you have provided explicit consent (e.g., for marketing communications, newsletters, or cookies), we process your data accordingly. You may withdraw consent at any time by contacting us at cyrilpoltavets@dabud.ai.
• Legitimate Interests. We may process information to improve our products, maintain cybersecurity, detect fraud, and ensure proper administration of the Services — provided these interests do not override your fundamental rights and freedoms.
• Legal Obligations. We may process data when necessary to comply with our legal obligations — for instance, tax reporting, regulatory compliance, or responding to lawful government requests.
• Vital Interests. In exceptional circumstances, we may process information to protect an individual’s life, health, or safety.

If you are located in Canada

We process your information based on your express or implied consent, as permitted under Canadian privacy law. You may withdraw your consent at any time.

In limited cases, we may process information without consent when permitted by law — for example:

• When collection is clearly in an individual’s interest and consent cannot be obtained promptly;
• To prevent or investigate fraud or security incidents;
• For the purposes of legitimate business transactions;
• To comply with subpoenas, court orders, or law enforcement requests;
• When the data is publicly available as defined under applicable Canadian privacy regulations;
• For research, statistical, or journalistic purposes, subject to applicable safeguards.

We ensure that any such processing is consistent with privacy principles and limited to what is necessary for the lawful purpose.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We share personal information only when necessary for business operations, legal compliance, or with your consent.

We may share your information in the following circumstances:

• Service Providers and Business Partners. We share information with trusted third parties who perform services on our behalf, such as hosting, analytics, payment processing, AI infrastructure, and customer support. These partners process your data only as instructed and are contractually obligated to maintain confidentiality and adequate security.

Our main service providers include:

• Hosting & Infrastructure: Vercel (application hosting), Google Cloud (EU-based data centers in Germany and the Netherlands).
• Payments: Stripe, PayPal, WayForPay.
• Analytics: Google Analytics.
• AI and Machine Learning Integrations: OpenAI, Google Gemini, Anthropic, and Google Vertex AI.

These partners may process limited data to power AI-based analytics, recommendations, and service functionality — in compliance with data protection laws and applicable data processing agreements.

• Business Transfers. In the event of a merger, acquisition, restructuring, or sale of assets, your personal information may be transferred as part of that transaction. We will notify affected users before any change in ownership or control of your data.
• Legal Obligations. We may disclose your personal data when required by law, regulation, court order, or governmental authority, or to protect our rights, users, and systems from misuse, fraud, or illegal activity.
• Consent-Based Sharing. We may share certain information with your explicit consent — for example, when integrating your account with third-party analytics or CRM tools you authorize.

Use of Client Data for Model Improvement

To continuously improve the accuracy, performance, and quality of our analytics and AI-driven recommendations, Dabudai on behalf of Polt House Inc. may use anonymized or aggregated data derived from client interactions within our Services.

Such data may be used to train, validate, or fine-tune our proprietary machine-learning models solely for the purpose of improving our algorithms, analytics accuracy, and service reliability.

This processing is conducted in accordance with applicable data-protection laws, including the GDPR and CCPA, and follows strict safeguards:

• No identifiable personal information or confidential business content is used unless explicit consent has been obtained.
• Data used for model improvement is anonymized, aggregated, and de-identified before processing.
• We do not allow third-party AI providers to use client data for their own model training.

You may opt out of this use at any time by contacting us at cyrilpoltavets@dabud.ai.

The purpose of this data processing is to enhance the precision, stability, and effectiveness of our Services for all users.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: Yes. We use cookies and similar technologies to operate our Services, perform analytics, and enhance user experience.

We use cookies, pixels, tags, and other tracking technologies to help the Services function securely and efficiently. These technologies allow us to:

• Maintain platform stability and prevent fraud;
• Save your preferences and login sessions;
• Improve navigation, performance, and analytics;
• Understand user behavior to refine our product and content;
• Support limited marketing and retargeting (only where legally permitted).

We also allow select third-party providers to use their tracking technologies for analytics and performance optimization purposes — primarily Google Analytics.

Google Analytics

We use Google Analytics to collect aggregated data about how users interact with our Services. This helps us understand traffic patterns, performance, and engagement metrics.

We may use the following Google Analytics features:

• Remarketing with Google Analytics
• Demographics and Interests Reporting
• Google Display Network Impression Reporting

You can opt out of Google Analytics tracking using the following resources:

• Google Analytics Opt-Out Tool
• Google Ads Settings
• Network Advertising Initiative Opt-Out

For details on how Google processes data, visit the Google Privacy & Terms page.

A detailed explanation of our cookie usage, retention periods, and management options is provided in our separate Cookies Policy.

6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In short: Yes. Our Services include features and tools powered by artificial intelligence (AI), machine learning (ML), and related automated technologies (“AI Products”). These capabilities are designed to enhance user experience, generate insights, and deliver intelligent recommendations for our business clients.

Use of AI Technologies

Our AI-powered features may analyze business data, public digital information, or other materials you submit to generate analytics, performance reports, or strategy recommendations.

We provide these capabilities through trusted third-party AI service providers (“AI Service Providers”), including but not limited to:

• OpenAI
• Google Gemini
• Anthropic
• Google Vertex AI

In some cases, limited personal or business data you provide (such as inputs, queries, or structured content) may be securely transmitted to these providers to enable AI functionality.

All data processing is conducted in accordance with this Privacy Policy, applicable data protection laws, and our contractual agreements with each AI provider. We ensure that AI Service Providers process data solely for the purpose of delivering requested functionality and not for independent model training, marketing, or profiling, unless explicitly allowed by you.

Our AI Products and Their Purposes

Our AI-driven solutions are designed to help companies and agencies improve their visibility, performance, and positioning across AI-powered search and analytics environments.

These include, but are not limited to:

• AI-assisted data analytics and visualization
• Recommendation and insights engines
• Text and content analysis
• Predictive analytics and forecasting
• AI-based visibility tracking for brands and companies
• Natural language understanding and search augmentation
• Automated reporting and strategy support tools

All data processed through these tools remains subject to strict security controls and anonymization measures where possible.

How We Process Your Data Using AI

All personal and business data processed by AI components is handled according to our Privacy Policy, our Data Processing Agreements, and the Limited Use frameworks of each AI Service Provider. This ensures high standards of security, confidentiality, and data minimization.

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We retain personal data only as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer period is required by law.

We store your personal information for as long as it is necessary to provide and improve our Services, comply with legal obligations, resolve disputes, and enforce our agreements.

Unless otherwise required by law (for example, for tax, accounting, or compliance purposes), we will not retain your personal information for more than twelve (12) months after the termination or deactivation of your account.

Once the retention period expires, we will either delete or anonymize the data. If deletion is not immediately possible (for example, due to backup systems), your information will be securely stored and isolated from further processing until permanent deletion becomes feasible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We apply a combination of organizational, technical, and procedural safeguards to secure your personal data.

We maintain reasonable and appropriate administrative, technical, and physical security measures to protect your information from unauthorized access, loss, alteration, or misuse.

These include encrypted data storage, secure data transfer (HTTPS, SSL/TLS), access controls, firewalls, and continuous monitoring of our systems hosted on servers located in Germany and the Netherlands.

However, no method of electronic storage or transmission is completely secure. While we do our best to protect your personal data, we cannot guarantee absolute security. You acknowledge that the transmission of information over the Internet is at your own risk, and you should only access our Services through secure networks and trusted devices.

9. DO WE COLLECT INFORMATION FROM MINORS?

In short: No. Our Services are strictly intended for users aged 18 and older.

We do not knowingly collect, solicit, or process data from individuals under the age of 18 (or the legal equivalent age in your jurisdiction).

By using our Services, you confirm that you are at least 18 years old or that you are the parent or legal guardian of a minor who is authorized to use the Services under your supervision. If we discover that personal information from users under the age of 18 has been collected, we will promptly deactivate the account and delete the data. If you believe that a minor has provided us with personal information, please contact us immediately at cyrilpoltavets@dabud.ai, and we will take appropriate steps to remove such data.

10. WHAT ARE YOUR PRIVACY RIGHTS?

In short: Depending on where you live, you may have the right to access, correct, delete, or restrict the processing of your personal information.

If you are a resident of the European Economic Area (EEA), United Kingdom (UK), Switzerland, Canada, or certain U.S. states (such as California, Virginia, or Colorado), you are entitled to specific privacy rights under applicable laws.

These rights may include the ability to:

• Request access to the personal information we hold about you;
• Request correction or deletion of your data;
• Restrict or object to our processing of your information;
• Request data portability (receive your data in a structured, commonly used format);
• Withdraw consent at any time when processing is based on consent;
• Request human review of any automated decisions that produce legal or significant effects.

You can exercise these rights by contacting us at cyrilpoltavets@dabud.ai.

We will respond to all valid requests in accordance with applicable data-protection laws.

If you are located in the EEA or UK and believe that we are processing your personal information unlawfully, you have the right to lodge a complaint with your local Data Protection Authority (DPA) or the UK Information Commissioner’s Office (ICO).

Withdrawing Consent

If you previously consented to the processing of your personal information (for example, for marketing purposes), you may withdraw your consent at any time by emailing us at cyrilpoltavets@dabud.ai. This will not affect the lawfulness of processing prior to your withdrawal.

Opting Out of Marketing

You can unsubscribe from our marketing or promotional emails by clicking the “Unsubscribe” link in our emails or by contacting us directly. We may still send you essential service-related or transactional communications necessary for the use of your account.

To opt out of telephone calls, email us at cyrilpoltavets@dabud.ai with the subject line "Do Not Call." We will honor your request within 10 business days.

Account Information

To review, update, or delete your account, please contact us at cyrilpoltavets@dabud.ai. Upon your request, we will deactivate or delete your account and remove your data from active systems. Some data may be retained for legitimate business or legal purposes (for example, to prevent fraud or resolve disputes).

Cookies and Similar Technologies

You can manage or disable cookies in your browser settings. Please note that disabling cookies may affect the functionality or availability of certain features of the Services. For more details, refer to our Cookie Policy.

11. CONTROLS FOR DO-NOT-TRACK FEATURES

In short: We currently do not respond to Do-Not-Track (“DNT”) signals.

Most web browsers and some mobile operating systems and applications include a Do-Not-Track (DNT) feature or setting that you can activate to express your preference not to have your online browsing activities tracked or collected.

At present, there is no uniform standard that governs how websites should respond to these signals. Therefore, our Services do not currently respond to DNT browser signals or any other automatic communication mechanisms that indicate a user’s choice not to be tracked.

If a new standard for recognizing and responding to DNT signals is adopted in the future, we will update this Privacy Policy to reflect our compliance with that standard. In accordance with California law, we are required to disclose our practices regarding DNT signals. Since no industry standard currently exists, we do not respond to DNT signals at this time.

12. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In short: Yes. Residents of certain U.S. states have specific rights regarding their personal data.

If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have rights under state privacy laws concerning access to, correction of, and deletion of your personal data.

These rights may vary depending on your jurisdiction but typically include:

• The right to know what personal data we collect and how we use it;
• The right to request access to, correction of, or deletion of your personal information;
• The right to receive a copy of your personal data in a portable format;
• The right to opt out of the sale, sharing, or targeted advertising based on your data;
• The right to withdraw consent for data processing, where applicable;
• The right to be free from discrimination for exercising any of your privacy rights.

You may exercise these rights by contacting us at cyrilpoltavets@dabud.ai. We may request additional information to verify your identity before processing your request, as required by law.

Categories of Personal Information We Collect

In the past twelve (12) months, we have collected the following categories of personal information from users and clients:

Additional Collection Context

We may also collect personal information outside of the categories listed above when you interact with us directly or indirectly, including but not limited to:

• When you contact our customer support team for assistance;
• When you participate in feedback programs, surveys, or marketing initiatives;
• When you engage with us during the onboarding process, through AI-based tools, or while receiving technical support;
• When you communicate with us by email, chat, phone, or mail;
• When we process your information to facilitate the delivery of our Services or to respond to inquiries and support requests.

These interactions may involve limited personal information, such as your name, contact details, and communication records, which are processed solely to improve user experience and provide the requested support or service.

Data Retention by Category

We retain personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by applicable law. Unless otherwise specified, all personal data will be deleted within twelve (12) months following the termination or closure of the user’s account.

• Category A (Identifiers): This includes contact details and other identifying information. Such data is retained while the user maintains an active account and is deleted within twelve (12) months after the account is closed.
• Category B (Personal Information under the California Records Statute): This includes personal and contact information processed to provide our Services. It is retained during the period of active account use and deleted within twelve (12) months after account termination.
• Category C (Protected Characteristics): We generally do not collect this type of information. However, if ever processed, it will be deleted within twelve (12) months following the end of the business relationship or service termination.
• Category F (Internet or Network Activity): This includes browsing, usage, and analytics data. It is retained while the user has an active account for the purposes of analytics and system security and deleted within twelve (12) months after account termination.
• Category H (Audio, Electronic, or Similar Information): This includes communications or materials provided through support interactions. It is retained only as long as necessary for support or verification purposes and deleted within twelve (12) months after the issue has been resolved or the account has been closed.

All data scheduled for deletion is first securely isolated from active systems and permanently removed using industry-standard data destruction procedures. If immediate deletion is not possible (for example, due to technical backups or legal retention requirements), the information will remain securely stored and inaccessible for any further processing until it can be permanently deleted.

How to Exercise Your Rights

To exercise your privacy rights, you may submit a data subject access request (DSAR) by emailing us at cyrilpoltavets@dabud.ai or by using the contact information provided in the section “How Can You Contact Us About This Notice?” at the end of this Privacy Policy.

We will respond to your request in accordance with applicable privacy laws, including the GDPR, CCPA, and other state or federal privacy regulations.

If your browser supports Global Privacy Control (GPC) signals and you choose to enable them, we will honor your opt-out preferences automatically where legally required.

Under certain U.S. state privacy laws, you may also designate an authorized agent to make a request on your behalf. If you do so, we may require the agent to provide written proof of authorization in compliance with applicable legal standards.

Request Verification

Upon receiving your request, we may need to verify your identity to ensure that we are responding to the correct individual. We will use the information you provide only to verify your identity or authority to make the request. If we cannot verify your identity based on information already maintained by us, we may request additional details for this purpose. When requests are made through an authorized agent, we may ask the agent to present a signed authorization letter from you confirming that they are permitted to act on your behalf. We may also contact you directly to confirm authorization before processing the agent’s request.

Appeals

If we decline to take action on your request, you have the right to appeal our decision under certain U.S. state privacy laws. You can submit an appeal by emailing cyrilpoltavets@dabud.ai with the subject line “Privacy Appeal.” We will respond to your appeal in writing, explaining our decision and any actions taken. If your appeal is denied, you may have the right to contact your state’s Attorney General to file a complaint.

California “Shine the Light” Law

Under California Civil Code Section 1798.83 (the “Shine the Light” law), California residents may request, once per year and free of charge, information about categories of personal information (if any) that we have disclosed to third parties for their direct marketing purposes, as well as the names and addresses of such third parties.

If you are a California resident and wish to make such a request, please send it in writing to:

Dabudai on behalf of Polt House Inc. 1007 N Orange St, 4th Floor, Suite #3162 Wilmington, Delaware 19801, United States

13. DO WE MAKE UPDATES TO THIS NOTICE?

In short: Yes, we update this Privacy Policy as necessary to remain compliant with applicable data protection laws and operational standards.

We may revise this Privacy Policy from time to time to reflect changes in our practices, technology, or legal obligations. The updated version will be indicated by an updated “Last Revised” date at the top of this page. If we make material changes, we will notify you either by prominently posting an update on our website or by sending you a direct communication (for example, via email). We encourage you to review this Privacy Policy periodically to stay informed about how we protect and process your personal information.

14. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have any questions, concerns, or comments about this Privacy Policy or how your personal data is processed, you may contact our Data Protection Officer (DPO) or reach out to us directly at:

Dabudai on behalf of Polt House Inc. 1007 N Orange St, 4th Floor, Suite #3162 Wilmington, Delaware 19801, United States

15. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

You have the right to request access to the personal data we hold about you, request correction of inaccuracies, or request deletion of your personal data where applicable. You may also have the right to withdraw your consent to processing or to request restriction of processing in accordance with data protection laws. To submit a data subject access request (DSAR), please contact us via email at cyrilpoltavets@dabud.ai. We will review and respond to your request in accordance with applicable privacy regulations (including GDPR, CCPA, and other relevant frameworks). In some cases, we may retain certain data as required by law, to prevent fraud, resolve disputes, or enforce our agreements. Once these obligations end, your data will be securely deleted or anonymized.