SNOBBOTS.COM PRIVACY POLICY

Last Updated: 07 August 2026

SECTION 1 – Introduction, Scope & Who We Are
1.1 Introduction

This Privacy Policy explains how SNOBBOT SOLUTION – FZCO (“SNOBBOT”, “we”, “our” or “us”) collects, uses, stores, shares and protects personal data in connection with SnobBots.com and the SnobBots artificial intelligence software platform (the “Platform”).

This Privacy Policy applies to personal data processed through the Platform and associated websites, dashboards, applications, integrations and related platform functionality.

SNOBBOT is committed to handling personal data responsibly and in accordance with applicable data protection laws.

1.2 Platform Owner & Operator

SnobBots.com and the SnobBots AI Platform are owned and operated by:

SNOBBOT SOLUTION – FZCO
IFZA Business Park
Dubai Digital Park
Dubai Silicon Oasis
Dubai
United Arab Emirates

Licence Number: 77651
Corporate Tax Registration Number (TRN): 105398497500001
Email: info@snobbots.ae
Platform: snobbots.com

SNOBBOT SOLUTION – FZCO is a company established in Dubai, United Arab Emirates.

The use of the names “SnobBots”, “SnobBots.com” or “SnobBots AI Platform” does not indicate that a separate legal entity operates the Platform.
1.3 Scope

This Privacy Policy applies to personal data relating to:

visitors to SnobBots.com;

registered account holders;

subscribers;

authorised users of customer accounts;

white-label and reseller users where applicable;

individuals communicating with SNOBBOT regarding the Platform;

individuals whose information is submitted to or processed through Platform features; and

end users interacting with AI chatbots, lead-capture functionality or other Platform services deployed by our customers.

Services provided separately through SnobBots.ae may be subject to separate privacy and contractual documentation.
1.4 Our Role as Data Controller

SNOBBOT acts as a data controller where we determine why and how personal data is processed for our own purposes.

This may include personal data processed for:

Platform account administration;

subscriptions and billing;

Platform security;

customer support;

service communications;

Platform analytics;

fraud and abuse prevention;

legal and regulatory compliance; and

operation and improvement of the Platform.
1.5 Our Role as Data Processor

Certain Platform functionality enables customers to collect, upload, connect, generate or otherwise process information through their own use of the Platform.

Depending upon the circumstances, this may include:

chatbot conversations;

website visitor enquiries;

lead information;

customer contact information;

WhatsApp-related communications;

uploaded documents;

website content;

knowledge-base information;

connected data sources; and

other information controlled by the customer.

Where a customer determines the purposes and means of this processing and SNOBBOT processes personal data on that customer’s behalf, the customer will generally act as the controller and SNOBBOT will act as a processor or service provider, subject to applicable law.

Customers are responsible for ensuring that they have an appropriate lawful basis, privacy notices, consents and other permissions required for their use of the Platform.

Additional data-processing terms may apply where required by applicable law or contractual arrangements.
1.6 End Users of Customer Chatbots & Services

If you interact with a chatbot, lead-capture form or other SnobBots-powered functionality deployed on a customer’s website or service, the organisation operating that website or service may be responsible for determining how your personal data is used.

You should therefore also review that organisation’s privacy policy.

SNOBBOT may process the information on behalf of that customer in order to provide the relevant Platform functionality.

1.7 Applicable Data Protection Framework

Depending upon the circumstances and individuals concerned, SNOBBOT may be subject to data protection requirements including the UAE Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data and, where applicable to particular processing activities, the UK GDPR and UK Data Protection Act 2018.

Other privacy or data protection legislation may apply depending upon the location of the customer, individual or relevant processing activity.

Nothing in this Privacy Policy is intended to provide rights that do not apply under the relevant law or to restrict mandatory privacy rights that do apply.
1.8 Artificial Intelligence Processing

The Platform incorporates Artificial Intelligence and automated technologies.

Depending upon the feature being used, information submitted to the Platform may be processed by AI systems to provide functionality including:

chatbot responses;

analysis of website content;

generation of FAQs;

blog generation;

blog-idea generation;

SEO-related content;

website auditing;

information extraction;

summarisation;

classification; and

other AI-powered functionality.

Further information concerning the operation, limitations and responsible use of Artificial Intelligence will be provided within our separate AI Services & Responsible Use Policy.
1.9 Relationship With Other Policies

This Privacy Policy should be read together with the applicable:

com Platform Terms & Conditions;

Cookie Policy;

AI Services & Responsible Use Policy; and

any additional data-processing terms or notices applicable to particular Platform functionality.
SECTION 2 – Personal Data We Collect
2.1 Information You Provide When Creating an Account

When you create or manage a SnobBots account, we may collect information including:

name;

email address;

password or authentication information;

account and profile information;

company or organisation details;

billing information;

subscription information; and

account preferences.

Where registration or authentication is provided through a third-party service, such as Google sign-in, we may receive information made available by that provider in accordance with your settings and the provider’s applicable terms.
2.2 Subscription, Billing & Transaction Data

Where you purchase or manage a Platform subscription, plan, credits or other paid functionality, we may process information relating to:

subscription plan;

billing status;

transaction history;

invoices;

payment status;

credits purchased or consumed;

auto-purchase or recharge settings;

billing contact details; and

other information necessary to administer your account.

Payment card information may be processed directly by our payment service providers. SNOBBOT does not necessarily receive or store complete payment card details where payment processing is handled by an independent payment provider.
2.3 Platform Usage & Activity Data

We may collect information about how registered users interact with the Platform, including:

login and account activity;

Platform features used;

chatbot configuration;

training activity;

AI content-generation activity;

website-audit activity;

conversations;

leads;

analytics activity;

usage history;

token, character, message or credit consumption;

feature limits;

exports;

system events; and

other activity associated with the account.

This information may be used to operate the Platform, calculate usage, administer plan limits, provide analytics, maintain security and improve Platform performance.
2.4 Website Training & Knowledge-Base Data

The Platform enables customers to provide information used to configure or train chatbot knowledge sources.

Depending upon the functionality used, this may include:

publicly accessible website content;

website URLs;

crawled or scanned webpages;

uploaded files and documents;

text supplied by the customer;

FAQs;

business information;

product or service information; and

other knowledge-base content.

Customers are responsible for ensuring that they have the necessary rights and lawful authority to submit, upload, connect or authorise the processing of this information.

Where such materials contain personal data, that personal data may be processed as part of providing the Platform Services.
2.5 Website Crawling & Scanning

Where a customer instructs the Platform to scan or process a website, the Platform may retrieve and analyse information available from the website for the requested functionality.

This may be used for purposes including:

chatbot knowledge creation;

website training;

content analysis;

SEO functionality; and

website auditing.

Customers must only instruct the Platform to access or process websites and content where they are authorised to do so and must comply with applicable law and third-party rights.
2.6 Chatbot Conversations

When an individual interacts with a SnobBots-powered chatbot deployed by a customer, information may be collected through that conversation.

Depending upon what the individual chooses to provide, this may include:

questions;

messages;

enquiries;

conversation history;

names;

contact information;

business information; and

other information entered into the chatbot.

The customer deploying the chatbot may be able to access and review conversation histories through its Platform account.

Where SNOBBOT processes chatbot conversation data on behalf of a customer, the customer will generally determine the purposes for which that information is collected and used.
2.7 Lead Capture

The Platform includes functionality enabling customers to capture leads and enquiries.

Lead information may include:

name;

email address;

telephone or contact details;

enquiry information;

conversation information;

date and time of interaction; and

other information voluntarily supplied by the individual.

Customers using lead-capture functionality are responsible for ensuring that appropriate privacy information and, where necessary, consent mechanisms are provided to individuals.
2.8 WhatsApp & Messaging Integrations

Where a customer connects or uses WhatsApp or another supported messaging service with the Platform, information associated with communications may be processed to provide the integration.

Depending upon the configuration, this may include:

telephone numbers;

contact identifiers;

messages;

conversation information;

timestamps;

delivery or interaction information; and

other data made available through the relevant integration.

The use of WhatsApp and other external messaging services is also subject to the privacy practices and terms of the relevant third-party provider.
2.9 AI Prompts, Inputs & Generated Outputs

When Platform AI functionality is used, we may process:

prompts;

instructions;

uploaded content;

source information;

contextual information;

generated responses; and

other inputs and outputs required to provide the requested AI functionality.

This may apply to features including chatbots, SEO generation, FAQ generation, blog generation, blog-idea generation, website auditing and other AI-powered tools.

Users should avoid submitting unnecessary sensitive or confidential personal information into AI prompts or content-generation tools.
2.10 SEO & Content-Generation Data

Where customers use Platform content-generation functionality, we may process information such as:

topics;

keywords;

website information;

business information;

prompts;

requested content types;

generated FAQs;

generated blog content;

blog ideas; and

related AI-generated outputs.

This information is processed to provide the functionality requested by the user.
2.11 Website Audit Data

Where the Website Audit functionality is used, the Platform may process information relating to the website submitted for analysis.

This may include:

website URLs;

publicly accessible webpage content;

metadata;

technical website information;

content structure; and

audit results generated by the Platform.

If website content contains personal data, that information may incidentally be processed during the audit.
2.12 Analytics Data

The Platform may collect and present analytics relating to the customer’s use of Platform functionality.

Depending upon the relevant feature, this may include information concerning:

chatbot interactions;

conversation volumes;

leads;

usage;

content generation;

website audits;

messages;

training data;

credits;

user activity; and

other Platform performance or account metrics.

Some analytics information may be available for customers to view or export.
2.13 White-Label & Reseller Data

Where white-label, reseller or customer-management functionality is available, we may process information relating to:

reseller accounts;

reseller customers;

customer plans;

branding and configuration;

custom domains;

account relationships;

subscriptions;

customer billing configuration; and

associated Platform activity.

The respective privacy responsibilities of SNOBBOT, the reseller and the reseller’s customer may depend upon how the relevant service is configured and who determines the purposes and means of processing.
2.14 Customer Support & Communications

Where you contact SNOBBOT, we may collect:

your name;

email address;

account information;

correspondence;

support requests;

technical information;

screenshots or files you provide; and

information necessary to investigate and resolve your enquiry.
2.15 Technical & Device Data

When you access SnobBots.com or the Platform, we may automatically receive technical information including:

IP address;

browser type;

device information;

operating system;

session information;

login information;

timestamps;

diagnostic information;

error information; and

security-related events.
2.16 Cookies & Similar Technologies

SnobBots.com may use cookies and similar technologies for purposes including:

authentication;

session management;

security;

remembering preferences;

Platform functionality;

analytics; and

other purposes described in our Cookie Policy.

Where consent is legally required for non-essential cookies or similar technologies, appropriate consent mechanisms will be used.
2.17 Information From Third Parties

We may receive information from third parties used in connection with the Platform, including:

authentication providers;

payment providers;

AI providers;

messaging providers;

analytics providers;

hosting and infrastructure providers;

integrations selected by the customer; and

white-label or reseller relationships.

The information received will depend upon the relevant service and integration.
2.18 Sensitive Personal Data

The Platform is not intended to require users to provide sensitive personal data unless such processing is appropriate for the relevant use case and permitted by applicable law.

Users and customers should not unnecessarily submit information concerning matters such as health, biometrics, government identification, financial credentials or other highly sensitive information through AI prompts, chatbot training materials or other Platform features.

Where a customer’s intended use requires sensitive personal data, the customer is responsible for ensuring that appropriate legal, technical and organisational safeguards are in place.
2.19 Information We Do Not Intentionally Require

SNOBBOT does not require customers to provide more personal data than is reasonably necessary to use the relevant Platform functionality.

Customers should apply data-minimisation principles when:

training chatbots;

uploading files;

configuring knowledge bases;

collecting leads;

using WhatsApp integrations;

submitting AI prompts; and

connecting external data sources.
SECTION 3 – How & Why We Use Personal Data
3.1 Operating the Platform

We may process personal data where necessary to provide, operate, administer and maintain SnobBots.com and the SnobBots AI Platform.

This includes processing necessary to:

create and manage accounts;

authenticate users;

provide access to Platform features;

manage subscriptions and plans;

administer usage allowances, credits, tokens, characters and messages;

provide chatbot functionality;

process training and knowledge-base information;

provide lead-capture functionality;

operate WhatsApp and other integrations;

generate AI-powered content;

perform website audits;

provide analytics;

maintain account settings; and

deliver other functionality requested by the user.
3.2 Account Administration & Authentication

We process account information to:

register users;

verify accounts;

authenticate logins;

manage account permissions;

maintain user sessions;

recover accounts;

prevent unauthorised access; and

communicate important account information.

Where third-party authentication is used, relevant information may be exchanged with the authentication provider as necessary to provide that functionality.
3.3 Subscriptions, Billing & Payments

We may process personal data to:

administer subscriptions;

process purchases;

manage plan changes;

administer credits and usage allowances;

operate auto-purchase or recharge functionality;

generate invoices;

verify payment status;

maintain transaction records;

prevent payment fraud; and

resolve billing enquiries.

Payment processing may be performed by independent payment providers.
3.4 Providing AI Functionality

Information submitted through Platform AI features may be processed to generate the requested output or perform the requested task.

This may include processing for:

chatbot responses;

website-derived knowledge;

FAQ generation;

blog generation;

blog-idea generation;

SEO-related content;

website auditing;

summarisation;

classification;

information extraction; and

other AI-powered functionality.

Information may be transmitted to relevant AI or infrastructure providers where necessary to perform the requested function.
3.5 Chatbot Training & Knowledge Retrieval

Where a customer trains or configures a chatbot, we may process authorised website content, uploaded documents, text and other knowledge sources to:

create or update the chatbot’s knowledge base;

index information;

retrieve relevant information;

generate responses;

improve retrieval quality; and

maintain the customer’s configured chatbot.

This processing is performed to provide the functionality requested by the customer.
3.6 Chatbot Conversations

Chatbot conversation information may be processed to:

generate responses;

maintain conversational context;

display conversation histories;

allow customers to review enquiries;

support lead capture;

troubleshoot technical issues;

detect misuse or security issues; and

provide relevant analytics.

Where SNOBBOT processes these conversations on behalf of a customer, the customer’s own purposes and lawful basis for collecting the information will generally govern the underlying customer-controlled processing.
3.7 Lead Capture

Where enabled by a customer, personal data may be processed to capture and organise enquiries and leads generated through Platform functionality.

This may allow the customer to:

identify a prospective customer;

review enquiry information;

view relevant conversation history;

respond to the enquiry;

manage captured leads; and

analyse lead activity.

SNOBBOT does not determine how an individual customer subsequently uses its captured leads where SNOBBOT is acting solely as processor.
3.8 WhatsApp & Other Integrations

Where a customer activates an external integration, we may process and transmit information as necessary to establish and operate that integration.

For WhatsApp-related functionality, this may include processing required to:

connect the relevant service;

facilitate communications;

associate conversations with the appropriate account;

transfer messages or contact information;

maintain integration functionality; and

troubleshoot technical problems.

External providers may independently process information under their own privacy terms.
3.9 SEO & Content Generation

Information submitted to SEO and content-generation features may be processed to generate:

FAQs;

articles or blog content;

blog ideas;

SEO-related suggestions; and

other requested content.

Generated content may be retained within the user’s account where necessary to provide Platform functionality.
3.10 Website Auditing

Where a user submits a website for auditing, we may retrieve and analyse relevant website information to generate the requested audit.

Processing may include:

retrieving publicly accessible webpages;

analysing website content;

analysing technical or structural information;

identifying relevant website characteristics; and

generating audit results.
3.11 Analytics & Reporting

We may process Platform activity and usage information to provide customers with analytics and reporting concerning their accounts and Platform features.

We may also use aggregated or appropriately de-identified information to understand:

Platform usage;

feature adoption;

system performance;

capacity requirements;

technical reliability; and

opportunities to improve the Platform.
3.12 Usage Measurement

The Platform may measure consumption including:

tokens;

characters;

messages;

content credits;

training data;

AI requests;

conversations;

generated content; and

other applicable usage units.

We use this information to administer plans, enforce usage limits, calculate consumption, support billing and maintain Platform capacity.
3.13 Customer Support

We process personal data where necessary to:

respond to support requests;

investigate problems;

troubleshoot Platform functionality;

communicate with users;

resolve billing or account issues; and

provide technical assistance.
3.14 Security, Fraud Prevention & Misuse

We may process account, technical, usage and other relevant information to:

protect accounts;

detect unauthorised access;

investigate suspicious activity;

prevent fraud;

identify abusive or prohibited use;

protect Platform infrastructure;

investigate security incidents;

enforce applicable Platform rules; and

protect SNOBBOT, customers, users and third parties.
3.15 Platform Development & Improvement

We may use appropriate Platform information to maintain, develop and improve our Services.

This may include:

diagnosing errors;

measuring performance;

improving user experience;

testing functionality;

understanding feature usage;

improving security; and

developing Platform functionality.

Where possible and appropriate, aggregated or de-identified information may be used for these purposes.
3.16 AI Model Training

SNOBBOT does not use customer confidential information or personal data processed on behalf of customers to train a SNOBBOT general-purpose AI model for unrelated purposes unless this has been expressly agreed and there is an appropriate lawful basis.

Third-party AI providers may have their own rules concerning retention, service improvement, abuse monitoring and model training.

Where available and commercially appropriate, SNOBBOT may use provider configurations designed to restrict the use of customer data for general model training.

Further details concerning third-party AI processing will be addressed in our AI Services & Responsible Use Policy.
3.17 Service Communications

We may use contact information to send communications necessary for operation of the Platform, including:

account verification;

password or security notices;

billing communications;

subscription information;

material service changes;

technical notices;

security alerts; and

important policy or contractual updates.

These operational communications may be necessary to provide the Platform and may not always be optional.
3.18 Marketing Communications

Where permitted by applicable law, we may use contact information to send information about:

Platform features;

new services;

product developments;

offers;

promotions; or

other relevant SNOBBOT services.

Where consent is required, marketing communications will be sent on the basis of consent.

Users may unsubscribe from marketing communications using the method provided in the relevant communication or by contacting SNOBBOT.
3.19 Legal & Regulatory Obligations

We may process personal data where necessary to:

comply with applicable law;

respond to lawful requests;

maintain legally required records;

comply with tax and accounting obligations;

establish or defend legal claims;

enforce contractual rights;

investigate suspected unlawful activity; and

cooperate with competent authorities where legally required.
3.20 Corporate Transactions

Where SNOBBOT undergoes a merger, restructuring, financing, acquisition, sale of assets or similar corporate transaction, relevant information may be disclosed or transferred where reasonably necessary and permitted by applicable law.

Any personal data transferred as part of such a transaction will remain subject to applicable data-protection requirements.

3.21 No Sale of Personal Data

SNOBBOT does not sell personal data as a business model.

We do not provide personal data to third parties in exchange for payment for those third parties’ independent marketing purposes.

3.22 Purpose Limitation

We will not use personal data for a materially incompatible purpose without an appropriate legal basis or other justification permitted by applicable law.

Where required, we will provide additional information or obtain consent before undertaking materially different processing.
SECTION 4 – Legal Bases for Processing Personal Data
4.1 Our Legal Bases

Where applicable data protection law requires SNOBBOT to identify a legal basis for processing personal data, the basis will depend upon the nature of the information, the relevant Platform functionality and SNOBBOT’s relationship with the individual.

We may process personal data on the basis of:

performance of a contract;

steps taken before entering into a contract;

legitimate interests;

compliance with legal obligations;

consent;

establishment, exercise or defence of legal claims; and

other lawful grounds available under applicable data protection law.
4.2 Contractual Necessity

We may process personal data where necessary to enter into or perform a contract with a user or customer.

This may include processing required to:

create and administer an account;

provide access to the Platform;

provide subscribed features;

administer subscriptions;

process payments;

maintain usage allowances and credits;

provide requested AI functionality;

provide customer support; and

communicate regarding the Services.

Where necessary information is not provided, we may be unable to provide the relevant Platform functionality.
4.3 Legitimate Interests

Where permitted by applicable law, SNOBBOT may process personal data where necessary for our legitimate business interests, provided those interests are not overridden by applicable rights and interests of the individual.

Our legitimate interests may include:

operating and improving the Platform;

maintaining Platform security;

preventing fraud and misuse;

protecting accounts and infrastructure;

troubleshooting technical problems;

understanding Platform usage;

improving functionality;

maintaining service reliability;

managing customer relationships;

protecting our legal rights; and

developing our business and Services.

Where required, we will consider the nature of the processing, its necessity and its potential impact upon individuals.
4.4 Consent

We may rely upon consent where required or appropriate.

This may include certain:

marketing communications;

non-essential cookies or tracking technologies;

optional integrations;

processing involving particular categories of information; or

other activities for which applicable law requires consent.

Where processing is based upon consent, individuals may withdraw that consent at any time.

Withdrawal of consent does not affect the lawfulness of processing carried out before consent was withdrawn.
4.5 Legal Obligations

We may process personal data where necessary to comply with legal or regulatory obligations applicable to SNOBBOT.

This may include obligations concerning:

accounting;

taxation;

corporate records;

regulatory compliance;

fraud prevention;

data protection;

cybersecurity;

lawful authority requests; and

other legally required records or disclosures.
4.6 Legal Claims & Protection of Rights

Where permitted by applicable law, we may process information where necessary to:

establish legal rights;

exercise contractual rights;

enforce agreements;

investigate disputes;

defend legal claims;

prevent abuse; or

protect SNOBBOT, our customers, users or third parties.
4.7 Processing on Behalf of Customers

Where SNOBBOT acts as a processor or service provider on behalf of a Platform customer, the customer is generally responsible for determining the appropriate legal basis for the underlying processing of personal data.

For example, this may apply where a customer uses the Platform to process:

chatbot conversations;

website visitor information;

captured leads;

WhatsApp communications;

uploaded customer information;

knowledge-base data; or

other personal data controlled by that customer.

SNOBBOT processes such information in accordance with the customer’s documented instructions, applicable contractual arrangements and applicable law.
4.8 Customer Responsibility for End-User Data

Customers using SnobBots functionality on their own websites, applications or communication channels are responsible for determining whether they need to:

provide privacy notices;

obtain consent;

establish another lawful basis;

provide cookie notices;

disclose AI processing;

identify third-party processors;

provide opt-out mechanisms; or

satisfy other privacy requirements.

The availability of a feature within the Platform does not, by itself, mean that every possible use of that feature is lawful in every jurisdiction.
4.9 Lead Capture Legal Basis

Where customers use the Platform to capture leads, the customer is responsible for establishing an appropriate lawful basis for collecting and subsequently using those leads.

SNOBBOT’s processing of lead information on behalf of a customer is performed for the purpose of providing the Platform functionality requested by that customer.

If SNOBBOT separately uses an individual’s information for SNOBBOT’s own purposes, we will require an independent lawful basis for that processing.
4.10 WhatsApp & External Communications

Customers connecting WhatsApp or other communication services are responsible for ensuring that their communications with individuals comply with applicable:

privacy laws;

direct-marketing requirements;

electronic communications laws;

consent requirements; and

third-party platform rules.

SNOBBOT’s provision of technical integration functionality does not establish the customer’s lawful basis for contacting an individual.
4.11 Website Crawling & Training

Where customers instruct the Platform to scan, crawl or process website content, the customer is responsible for ensuring that it has lawful authority to use the relevant website and content for the intended purpose.

SNOBBOT may process that information as necessary to provide the requested Platform functionality.

4.12 Special Categories & Sensitive Personal Data

Where processing involves sensitive or specially protected categories of personal data, an additional legal condition or safeguard may be required under applicable law.

Customers must not use the Platform to process such information unless they have determined that the processing is lawful and have implemented any required safeguards.

SNOBBOT may restrict particular forms of sensitive-data processing where necessary for legal, security or Platform-risk reasons.

4.13 Children’s Personal Data

The Platform is primarily intended for business and professional use and is not directed at children.

Customers must not intentionally configure Platform functionality to collect personal data from children where doing so would violate applicable law.

Where a customer intends to deploy a Platform feature in a context involving children, it is responsible for determining and implementing applicable age-verification, parental-consent, transparency and safeguarding requirements.

4.14 Automated Processing

The Platform uses Artificial Intelligence and other automated technologies to perform requested functions.

The use of automated processing does not necessarily constitute automated decision-making producing legal or similarly significant effects.

SNOBBOT does not intentionally use Platform account data to make solely automated decisions about individuals that produce legal or similarly significant effects unless such processing is permitted by applicable law and appropriate safeguards are implemented.

Customers remain responsible for determining whether their own deployment of Platform functionality involves regulated automated decision-making.

4.15 Balancing Rights & Interests

Where SNOBBOT relies upon legitimate interests, we will consider whether the processing is reasonably necessary and proportionate to the relevant purpose and whether the individual’s rights and interests require additional safeguards.

Individuals may have the right to object to certain processing based upon legitimate interests, depending upon applicable law.
SECTION 5 – How We Share Personal Data & Third-Party Service Providers
5.1 When We Share Personal Data

SNOBBOT may disclose or make personal data available to third parties where reasonably necessary to:

operate the Platform;

provide requested Platform functionality;

process payments;

provide Artificial Intelligence functionality;

host and secure the Platform;

operate integrations;

provide communications functionality;

analyse Platform performance;

provide customer support;

prevent fraud or misuse;

comply with legal obligations; or

protect SNOBBOT’s legitimate rights and interests.

We do not permit service providers to use personal data for unrelated purposes merely because they provide services to us, except where they independently act as controllers under applicable law.
5.2 AI & Machine-Learning Providers

The Platform may rely upon third-party Artificial Intelligence providers, models, APIs or infrastructure to provide AI-powered functionality.

Depending upon the feature being used, information transmitted to these providers may include:

prompts;

chatbot messages;

instructions;

website content;

knowledge-base content;

uploaded information;

contextual information; and

other data necessary to generate the requested output.

The particular AI technologies and providers used by the Platform may change over time as technologies, availability, security requirements and Platform functionality evolve.

Further information concerning third-party AI technologies will be addressed in our AI Services & Responsible Use Policy.
5.3 Hosting & Infrastructure Providers

We may use third-party hosting, cloud, database, storage, content-delivery and infrastructure providers to operate the Platform.

These providers may process technical information, account information, Platform data and other information stored or transmitted through their infrastructure.
5.4 Payment Providers

Payments and subscription transactions may be processed through independent payment providers.

Payment providers may process information including:

name;

billing details;

payment method information;

transaction information;

fraud-prevention information; and

other information necessary to process payments.

Payment providers may act as independent controllers for certain processing activities conducted under their own legal and regulatory obligations.

SNOBBOT does not necessarily receive or store complete payment-card information where the transaction is processed directly by the payment provider.
5.5 Authentication Providers

Where users choose third-party authentication functionality, such as supported social or account sign-in services, information may be exchanged with the relevant authentication provider to:

verify identity;

authenticate access;

create or connect an account; and

maintain login functionality.

The information received depends upon the provider, the user’s settings and the permissions granted.
5.6 WhatsApp & Messaging Providers

Where customers use WhatsApp or another external messaging integration, information may be transmitted between the Platform and the relevant messaging provider as necessary to provide the integration.

The third-party provider may independently collect and process information under its own privacy terms.

Customers are responsible for ensuring that their use of messaging integrations complies with applicable privacy, communications and marketing laws.
5.7 Analytics & Performance Providers

We may use analytics, monitoring, diagnostic and performance services to understand and maintain the operation of SnobBots.com.

Depending upon the service and applicable consent requirements, these providers may process information concerning:

browser or device information;

IP address;

Platform activity;

technical events;

errors;

performance;

sessions; and

usage patterns.

Further information concerning cookies and related tracking technologies will be provided in our Cookie Policy.
5.8 Customer Support & Communications Providers

We may use third-party services to support:

customer communications;

transactional email;

support requests;

service notifications;

account verification; and

other operational communications.

Only information reasonably necessary to provide the relevant service should be made available to such providers.
5.9 Platform Integrations

Customers may choose to connect the Platform with external services.

When an integration is enabled, information may be exchanged with the selected third party as necessary to provide the requested functionality.

The customer is responsible for determining whether the integration is appropriate for its intended use and whether it has the necessary authority to transmit relevant information.

Third-party integrations are also governed by the privacy practices and contractual terms of their respective providers.
5.10 White-Label & Reseller Relationships

Where the Platform supports white-label or reseller arrangements, personal data may be processed between SNOBBOT, the reseller and the reseller’s customers as necessary to:

create and administer accounts;

provide white-labelled Platform functionality;

manage customer plans;

administer subscriptions or billing arrangements;

provide technical support;

configure domains and branding; and

operate the relevant Platform Services.

The respective roles of SNOBBOT, the reseller and the reseller’s customer may differ according to the particular processing activity.

Where required, these responsibilities may be addressed through contractual data-processing arrangements.
5.11 Customer Access to End-User Data

Customers may have access through their Platform accounts to information collected through functionality they deploy, including:

chatbot conversations;

captured leads;

contact information;

conversation histories;

analytics; and

other customer-controlled Platform information.

SNOBBOT does not control how a customer independently uses information after accessing or exporting it from the Platform.

Customers are responsible for their own processing of such information under applicable data protection law.
5.12 Professional Advisers

Where reasonably necessary, personal data may be disclosed to professional advisers such as:

lawyers;

accountants;

auditors;

insurers;

tax advisers; and

other professional consultants.

Such disclosures will be limited to information reasonably necessary for the relevant professional purpose.
5.13 Legal Authorities & Regulatory Disclosures

We may disclose personal data where we reasonably believe disclosure is necessary to:

comply with applicable law;

comply with a court order;

respond to a legally valid request from a competent authority;

meet regulatory obligations;

investigate suspected unlawful activity;

protect against fraud or cybersecurity threats;

establish or defend legal claims; or

protect the rights, property or safety of SNOBBOT, our customers, users or others.

We will not voluntarily disclose personal data to authorities merely because it is requested where we are not legally permitted or otherwise appropriately authorised to do so.
5.14 Corporate Transactions

Personal data may be disclosed to appropriate parties in connection with a proposed or completed:

merger;

acquisition;

restructuring;

financing;

investment;

sale of business assets; or

similar corporate transaction.

Where appropriate, confidentiality and data-protection safeguards will apply to such disclosures.
5.15 Subprocessors

Where SNOBBOT acts as a processor on behalf of a customer, we may appoint subprocessors to assist with providing the Platform.

Subprocessors may include providers of:

hosting;

cloud infrastructure;

AI technology;

databases;

communications;

monitoring;

security;

support; and

other technical services.

Where required by applicable law or contractual arrangements, SNOBBOT will impose appropriate data-protection obligations upon subprocessors.
5.16 Changes to Service Providers

The technologies and providers supporting an AI Platform may change over time.

SNOBBOT may therefore:

add providers;

replace providers;

remove providers; or

change technical infrastructure

where reasonably necessary to maintain, improve, secure or develop the Platform.

Where applicable law or contractual data-processing terms require notice of material subprocessor changes, SNOBBOT will provide such notice in accordance with those requirements.
5.17 No Sale of Personal Data

SNOBBOT does not sell personal data to data brokers or third parties for their independent commercial marketing purposes.

Where information is disclosed to service providers, processors or subprocessors, such disclosure is for legitimate Platform, operational or legal purposes rather than the sale of personal data.
SECTION 6 – International Data Transfers
6.1 International Operation of the Platform

SNOBBOT SOLUTION – FZCO is established in the United Arab Emirates, while SnobBots.com may be used by customers and users located in multiple countries.

As a result, personal data processed through the Platform may be transferred to, stored in or accessed from countries outside the country in which the individual is located.

This may occur where:

SNOBBOT operates or administers the Platform from the UAE;

third-party cloud or hosting providers operate internationally;

AI providers process information in other jurisdictions;

messaging or integration providers operate internationally;

payment providers process transactions internationally;

support or infrastructure providers operate from other countries; or

customers themselves access Platform information from different jurisdictions.
6.2 Transfers to the United Arab Emirates

Where users or customers are located outside the UAE, personal data may be transferred to or accessed from the UAE because SNOBBOT is established and operates from Dubai.

Such transfers will be handled in accordance with applicable data-protection requirements.
6.3 Third-Party Infrastructure

The Platform may rely upon third-party providers whose infrastructure is distributed across multiple geographic regions.

Depending upon the provider, configuration and Service being used, information may be processed in:

the UAE;

the United Kingdom;

the European Economic Area;

the United States; or

other jurisdictions in which relevant service providers operate.

The precise processing location may vary according to the technology and configuration used.
6.4 AI Providers

Information submitted to AI-powered Platform features may be transmitted to third-party AI providers for processing.

The geographic location of such processing may depend upon:

the AI provider;

the model selected;

the provider’s infrastructure;

account configuration;

regional availability; and

the service tier being used.

Where specific data-residency requirements are commercially or legally necessary, customers should identify those requirements before using the relevant Platform functionality.
6.5 UK & EEA Personal Data

Where UK GDPR or EU GDPR requirements apply to an international transfer of personal data, SNOBBOT will use an appropriate transfer mechanism where required.

Depending upon the circumstances, this may include:

an applicable adequacy decision or regulation;

Standard Contractual Clauses;

the UK International Data Transfer Agreement;

the UK Addendum to the EU Standard Contractual Clauses; or

another legally recognised transfer mechanism.

Additional technical, contractual or organisational safeguards may be implemented where appropriate.
6.6 UAE Personal Data

Where international transfers are subject to the UAE Personal Data Protection Law, SNOBBOT will handle those transfers in accordance with applicable requirements governing transfers of personal data outside the UAE.

Where required, appropriate safeguards or another legally permitted transfer basis will be used.
6.7 Customer-Controlled International Transfers

Where SNOBBOT acts as a processor on behalf of a customer, the customer’s use of the Platform may itself create international transfers.

For example, this may occur where a customer:

uploads personal data from another jurisdiction;

enables an international AI provider;

connects WhatsApp or another external service;

exports Platform data;

allows personnel in multiple countries to access an account; or

uses a white-label service across multiple jurisdictions.

The customer remains responsible for determining whether its own processing requires additional international-transfer safeguards.
6.8 White-Label & Reseller Customers

White-label and reseller customers may provide Platform access to their own customers or end users in different jurisdictions.

Where this occurs, the reseller is responsible for understanding the geographic scope of its own processing and complying with international-transfer requirements applicable to its activities.

SNOBBOT will fulfil its own obligations in relation to transfers for which it is legally responsible.
6.9 Data Residency

Unless expressly agreed otherwise in writing, use of the Platform does not guarantee that personal data will remain exclusively within a particular country or geographic region.

Customers requiring:

UAE-only processing;

UK-only processing;

EEA-only processing;

dedicated regional hosting;

specific cloud regions;

zero-data-retention AI processing; or

other specialised data-residency arrangements

should confirm that such functionality is available and expressly agreed before submitting affected data.
6.10 Third-Party Provider Changes

Third-party providers may change:

infrastructure locations;

subprocessors;

data centres;

processing regions; or

international-transfer arrangements.

Where such changes materially affect SNOBBOT’s data-protection obligations, we will take reasonable steps to maintain appropriate safeguards.
6.11 Risks of International Processing

Data-protection laws and government-access rules differ between countries.

Where required by applicable law, SNOBBOT will assess and implement appropriate safeguards intended to protect transferred personal data.

However, no international data-transfer mechanism can eliminate every risk associated with processing information through global internet and cloud infrastructure.

6.12 Further Information

Customers or individuals with questions concerning international transfers of personal data may contact:

SNOBBOT SOLUTION – FZCO
Email: info@snobbots.ae

Where applicable, individuals may request further information concerning safeguards used for relevant international transfers, subject to confidentiality, security and legal restrictions.
SECTION 7 – Data Retention, Deletion & Account Closure
7.1 General Retention Principle

SNOBBOT retains personal data only for as long as reasonably necessary for the purposes for which it was collected or subsequently lawfully processed.

The appropriate retention period may depend upon:

the type of personal data;

the relevant Platform feature;

the duration of the customer relationship;

contractual requirements;

security requirements;

legal and regulatory obligations;

accounting and tax requirements;

dispute or claims periods;

customer instructions where SNOBBOT acts as processor; and

technical limitations of relevant third-party providers.

Personal data may subsequently be deleted, anonymised or otherwise handled in accordance with applicable law.
7.2 Account Data

Personal data associated with an active Platform account may be retained for as long as the account remains active and for a reasonable period afterwards where necessary for:

account administration;

billing;

security;

fraud prevention;

legal compliance;

dispute resolution;

enforcement of contractual rights; and

maintenance of appropriate business records.

Closing an account does not necessarily result in immediate deletion of every record associated with that account.
7.3 Subscription & Billing Records

Information relating to:

subscriptions;

payments;

invoices;

transactions;

credits;

refunds;

billing disputes; and

related financial records

may be retained for periods required by applicable accounting, tax, corporate and other legal obligations.

Payment providers may independently retain transaction information in accordance with their own legal obligations and privacy practices.
7.4 Customer Content & Training Data

Customer-provided content used with Platform functionality may be retained while necessary to provide the relevant Service.

This may include:

website training data;

crawled or scanned content;

uploaded files;

documents;

knowledge-base information;

prompts;

configuration data; and

other customer-controlled content.

Where SNOBBOT acts as a processor, retention and deletion may also be governed by the customer’s instructions and applicable data-processing terms.
7.5 Chatbot Conversations

Chatbot conversations may be retained within the Platform so that authorised customers can:

review conversations;

manage enquiries;

analyse chatbot performance;

access conversation history;

investigate issues; and

use related Platform functionality.

The applicable customer is responsible for determining an appropriate retention period for personal data it controls through its chatbot deployment.
7.6 Lead Data

Lead information captured through the Platform may remain available within the customer’s account until:

it is deleted;

the account or relevant Service is terminated;

an applicable retention period expires; or

another deletion event occurs under the relevant contractual or technical arrangements.

Where customers export lead information from the Platform, SNOBBOT does not control the customer’s subsequent retention of the exported information.
7.7 WhatsApp & External Integration Data

Information processed through WhatsApp or another third-party integration may be retained by:

SNOBBOT;

the Platform customer; and

the relevant third-party provider

for different periods according to their respective roles and purposes.

Deletion from SnobBots.com does not necessarily delete information independently retained by WhatsApp or another external provider.
7.8 AI Prompts & Generated Content

AI prompts, inputs and generated outputs may be retained where necessary to:

provide Platform functionality;

maintain user history;

allow users to access generated content;

troubleshoot technical problems;

maintain security;

investigate misuse; or

satisfy legal requirements.

Relevant third-party AI providers may maintain their own retention practices.

Where specific third-party retention controls are available, their operation may depend upon the provider and service configuration.
7.9 Website Audits & Generated SEO Content

Website audit results, generated FAQs, blog content, blog ideas and other AI-generated materials may remain associated with a user’s account where necessary to provide the relevant Platform functionality.

Users should retain independent copies of material they require for their own long-term business records where appropriate.
7.10 Analytics & Usage Records

Platform analytics and usage information may be retained for purposes including:

providing customer analytics;

calculating usage;

administering tokens, characters, credits or messages;

billing;

capacity planning;

security;

fraud prevention;

troubleshooting; and

Platform improvement.

Aggregated or properly anonymised information that no longer constitutes personal data may be retained for longer periods.
7.11 Security Logs

Technical and security records may be retained for a reasonable period where necessary to:

identify security incidents;

investigate unauthorised access;

detect fraud or misuse;

maintain system integrity;

troubleshoot technical problems; and

establish or defend legal claims.
7.12 Customer Support Records

Support communications may be retained where reasonably necessary to:

resolve ongoing enquiries;

maintain support history;

improve service quality;

investigate disputes;

demonstrate actions taken; and

comply with legal obligations.
7.13 Account Closure

Where a customer closes or terminates its Platform account, SNOBBOT may begin deletion or deactivation processes for information associated with that account.

However, certain information may continue to be retained where:

required by law;

necessary for tax or accounting purposes;

required for security or fraud prevention;

relevant to an existing or reasonably anticipated dispute;

necessary to enforce contractual rights;

retained within backups awaiting normal deletion cycles; or

independently retained by a third-party provider.
7.14 Customer Responsibility Before Account Closure

Before closing an account, customers should export or otherwise retain any information they are entitled to keep and require for their own purposes.

Subject to applicable law and contractual obligations, SNOBBOT is not required to maintain indefinite access to:

chatbot conversations;

leads;

generated content;

analytics;

audit results;

training information; or

other Platform data

after an account or relevant Service has been terminated.
7.15 Backups

Personal data deleted from active systems may remain temporarily within secure backup systems until those backups are overwritten, rotated or otherwise deleted in accordance with applicable retention procedures.

Information retained solely within backups will not ordinarily be restored except where required for legitimate disaster-recovery, security or legal purposes.
7.16 Third-Party Retention

SNOBBOT cannot directly control information independently retained by third-party providers acting under their own legal responsibilities or technical systems.

Third-party retention may apply to providers involved in:

payments;

authentication;

AI processing;

WhatsApp or messaging;

hosting;

analytics; or

other Platform integrations.
7.17 Deletion Requests

Individuals may request deletion of personal data where they have a right to do so under applicable law.

Requests relating to personal data for which SNOBBOT is the controller may be submitted directly to SNOBBOT.

Where SNOBBOT processes information solely on behalf of a Platform customer, individuals may need to direct their request to that customer as the relevant controller.

Where appropriate, SNOBBOT will reasonably assist customers in responding to valid data-subject requests in accordance with applicable contractual and legal obligations.
7.18 Legal Holds & Disputes

SNOBBOT may temporarily suspend deletion where information is reasonably necessary in connection with:

litigation;

regulatory investigation;

legal claims;

contractual disputes;

fraud investigations;

cybersecurity incidents; or

another lawful preservation requirement.

When the relevant need ends, the information will return to the applicable retention and deletion process.
7.19 No Universal Retention Period

Because SnobBots.com processes different categories of information for different purposes, a single retention period does not apply to all Platform data.

SNOBBOT will determine retention according to the nature and purpose of the information, our role as controller or processor, applicable contractual arrangements and legal requirements.
SECTION 8 – Data Security & Protection
8.1 Security Approach

SNOBBOT takes reasonable technical and organisational measures designed to protect personal data processed through SnobBots.com against:

unauthorised access;

unlawful processing;

accidental loss;

destruction;

alteration;

unauthorised disclosure;

misuse; and

other reasonably foreseeable security threats.

The measures applied may vary according to the nature, sensitivity and risk associated with the information and the relevant Platform functionality.
8.2 Technical & Organisational Measures

Depending upon the relevant systems and circumstances, security measures may include:

access controls;

authentication mechanisms;

account permissions;

encryption in transit where appropriate;

secure hosting infrastructure;

security monitoring;

logging;

software updates;

vulnerability management;

backup and recovery procedures;

restricted administrative access;

credential-management procedures; and

other proportionate technical or organisational controls.

No particular security measure should be interpreted as an absolute guarantee against every possible security incident.
8.3 Account Security

Users are responsible for maintaining the security of their Platform accounts.

Users must:

maintain appropriate password security;

protect login credentials;

prevent unauthorised sharing of accounts;

restrict access to authorised personnel;

maintain the security of connected accounts and integrations; and

notify SNOBBOT promptly of suspected unauthorised access.

Where available, users should make appropriate use of additional security features provided through the Platform or relevant authentication providers.
8.4 Customer User Access

Customers are responsible for managing access granted to employees, contractors, administrators and other authorised users associated with their account.

Customers should promptly remove or modify access when an individual:

leaves the organisation;

changes responsibilities;

no longer requires Platform access; or

should otherwise cease having access to customer-controlled information.
8.5 AI-Specific Security Risks

Artificial Intelligence systems may introduce security risks beyond those associated with conventional software.

These may include:

prompt injection;

malicious prompts;

attempts to bypass AI safeguards;

unauthorised extraction of information;

manipulation of AI behaviour;

malicious content embedded in external sources;

inappropriate disclosure through generated outputs; and

emerging AI-specific attack techniques.

SNOBBOT may implement reasonable safeguards against such risks, but no AI system can be guaranteed to resist every current or future attack technique.
8.6 Website Training & External Content

Where customers instruct the Platform to scan websites, process external content or use information within chatbot knowledge sources, such information may contain malicious, misleading or inappropriate material.

Customers should only connect or submit sources they are authorised to use and should exercise appropriate care when selecting information used by AI functionality.
8.7 Uploaded Files & Customer Content

Customers are responsible for ensuring that files, documents and other content submitted to the Platform:

are obtained lawfully;

do not contain malicious software;

do not unnecessarily contain sensitive personal data;

do not expose credentials or secrets; and

are appropriate for the intended processing.

SNOBBOT may restrict, reject or remove content where reasonably necessary to protect Platform security or comply with applicable law.
8.8 API Keys, Passwords & Credentials

Users should not place:

passwords;

unrestricted API keys;

private cryptographic keys;

authentication tokens;

payment credentials; or

other sensitive security credentials

into chatbot training data, AI prompts, uploaded documents or other Platform content unless expressly required for a supported integration and appropriate safeguards are in place.
8.9 Third-Party Integrations

Integrations with external services may require information or authentication credentials to pass between SnobBots.com and the relevant third party.

Customers are responsible for:

selecting integrations they trust;

maintaining security of third-party accounts;

granting only appropriate permissions;

reviewing third-party access; and

revoking integrations that are no longer required.

SNOBBOT does not control the security of independent third-party services.
8.10 WhatsApp Security

Where WhatsApp functionality is enabled, communications may pass through systems operated by third parties involved in providing the messaging service.

Customers should not assume that connecting WhatsApp to the Platform changes the security, privacy or retention characteristics imposed by the relevant messaging provider.

8.11 Payment Security

Payment information may be processed by specialist third-party payment providers.

Where payment information is submitted directly to such a provider, its security infrastructure and data-protection practices govern its independent processing.

SNOBBOT does not intentionally store complete payment-card details where those details are processed directly by the payment provider and are not required by SNOBBOT.
8.12 White-Label & Reseller Security

White-label and reseller customers are responsible for appropriately managing:

their own customer accounts;

user permissions;

custom domains;

administrator access;

connected services;

billing integrations; and

credentials under their control.

A reseller must not provide unauthorised persons with access to customer information available through reseller functionality.
8.13 Data Minimisation

Security risks can be reduced by limiting the personal data submitted to AI and other Platform systems.

Customers and users should avoid submitting personal information that is unnecessary for the relevant purpose.

This is particularly important for:

AI prompts;

chatbot conversations;

training data;

uploaded documents;

lead-capture configurations;

website knowledge bases; and

third-party integrations.
8.14 Security Monitoring

SNOBBOT may process technical, account and usage information to:

detect suspicious activity;

identify unauthorised access;

investigate misuse;

diagnose vulnerabilities;

protect Platform infrastructure;

prevent fraud;

investigate incidents; and

maintain Platform security.

Security monitoring may involve automated systems where appropriate.
8.15 Security Incidents

Where SNOBBOT becomes aware of a personal-data breach affecting information for which SNOBBOT is legally responsible, we will take reasonable steps appropriate to the circumstances, which may include:

investigating the incident;

containing the incident;

mitigating ongoing risk;

securing affected systems;

preserving relevant evidence; and

notifying affected parties or competent authorities where required by applicable law.
8.16 Processor Breach Notifications

Where SNOBBOT acts as a processor on behalf of a customer and becomes aware of a qualifying personal-data breach involving customer-controlled personal data, SNOBBOT will notify the relevant customer in accordance with applicable law and contractual data-processing obligations.

The customer remains responsible for determining its own notification obligations as controller, except where applicable law provides otherwise.
8.17 Customer Security Incidents

Customers should notify SNOBBOT promptly if they become aware of a security incident that may affect the Platform, including:

compromised Platform credentials;

unauthorised account access;

exposed API credentials;

compromised integrations;

suspected chatbot data exposure;

unexpected access to conversations or leads; or

other suspicious Platform activity.

Prompt notification may allow protective measures to be implemented more quickly.
8.18 Security of Exported Data

Customers may be able to export information from the Platform.

Once information has been lawfully exported to a customer-controlled environment, the customer is responsible for protecting that copy, including through appropriate:

access controls;

storage security;

encryption where appropriate;

retention policies; and

deletion procedures.
8.19 No Absolute Security Guarantee

Although SNOBBOT takes reasonable measures designed to protect personal data, no internet-connected service, cloud platform, AI system or electronic storage method can be guaranteed to be completely secure.

Accordingly, SNOBBOT cannot guarantee that unauthorised access, cybersecurity incidents or other security events will never occur.

This does not limit any security obligation or liability that cannot lawfully be excluded under applicable law.

SECTION 9 – Your Privacy Rights & Choices
9.1 Privacy Rights

Depending upon where you are located, the nature of the processing and the applicable data protection law, you may have rights concerning your personal data.

These rights may include the right to:

request access to personal data;

request correction of inaccurate or incomplete data;

request deletion of personal data;

request restriction of processing;

object to certain processing;

withdraw consent;

request portability of certain personal data;

obtain information concerning how personal data is processed;

object to certain direct marketing;

raise concerns regarding automated decision-making; and

lodge a complaint with an appropriate supervisory or regulatory authority.

Not every right applies in every circumstance.
9.2 Right of Access

Where applicable, you may request information concerning personal data SNOBBOT holds about you and obtain a copy of relevant personal data.

We may need to verify your identity before responding to an access request.

Certain information may be withheld or redacted where permitted or required by law, including where disclosure would adversely affect the rights of another person.

9.3 Right to Correction

You may request correction of personal data that is inaccurate or completion of information that is materially incomplete.

Registered users may also be able to update certain account information directly through the Platform.
9.4 Right to Deletion

Where applicable, you may request deletion of personal data.

The right to deletion is not absolute.

We may retain information where necessary for purposes including:

compliance with legal obligations;

accounting or tax requirements;

security and fraud prevention;

establishment, exercise or defence of legal claims;

contractual obligations; or

another lawful basis permitting continued retention.
9.5 Right to Restrict Processing

Where provided by applicable law, you may request that processing of certain personal data be restricted.

For example, this may apply while the accuracy or lawfulness of particular processing is being considered.

9.6 Right to Object

Where SNOBBOT relies upon legitimate interests for processing, you may have the right to object to that processing.

We will consider the objection in accordance with applicable law and may continue processing where there are compelling legitimate grounds or another lawful reason permitting us to do so.
9.7 Direct Marketing

You may object to or opt out of direct electronic marketing from SNOBBOT.

Marketing communications may contain an unsubscribe mechanism where appropriate.

You may also contact us directly to request that marketing communications stop.

Opting out of marketing does not prevent SNOBBOT from sending necessary operational communications concerning:

your account;

subscription;

billing;

security;

Platform functionality; or

contractual or policy changes.
9.8 Withdrawal of Consent

Where processing is based upon your consent, you may withdraw that consent at any time.

Withdrawal does not affect processing lawfully undertaken before consent was withdrawn.

Withdrawal may affect our ability to provide functionality that depends upon the relevant consent.

9.9 Data Portability

Where applicable, you may have the right to receive certain personal data you provided in a structured, commonly used and machine-readable format and, where technically feasible and legally required, request transmission to another controller.

This right does not necessarily apply to all information processed through the Platform.

9.10 Automated Decision-Making

Depending upon applicable law, individuals may have rights concerning decisions based solely upon automated processing that produce legal or similarly significant effects.

SNOBBOT does not intentionally use personal data for which it acts as controller to make solely automated decisions producing legal or similarly significant effects unless the processing is lawful and appropriate safeguards are implemented.

Customers using the Platform to create their own automated processes are responsible for determining whether their deployment creates additional obligations or rights for affected individuals.
9.11 Rights Relating to Customer-Controlled Data

An important distinction applies where personal data has been collected through a SnobBots-powered service operated by one of our customers.

For example, if you:

interact with a customer’s chatbot;

submit a lead through a customer’s chatbot;

communicate through a customer’s connected WhatsApp service; or

otherwise provide information through customer-controlled Platform functionality,

the customer may be the relevant data controller.

In those circumstances, privacy requests should normally be directed to that customer.

SNOBBOT will provide reasonable assistance to the customer where required by applicable law and our contractual obligations.
9.12 Requests Received Directly From Customer End Users

Where SNOBBOT receives a privacy request concerning personal data that we process solely on behalf of a customer, we may:

identify the relevant customer where appropriate;

direct the individual to that customer;

notify the customer of the request; or

assist the customer in responding,

subject to applicable law and contractual requirements.

SNOBBOT will not independently determine a customer’s response where the customer is legally responsible for the relevant processing.
9.13 Account & Platform Controls

Certain privacy choices may be available directly through the Platform, depending upon the functionality provided.

These may include controls relating to:

account information;

integrations;

customer content;

chatbot data;

leads;

generated content;

exports; and

account closure.

Using an account control does not necessarily delete information independently retained for legal, security, billing or other lawful purposes.
9.14 Cookie Choices

Users may manage certain cookie and tracking preferences through the mechanisms provided on SnobBots.com.

Browser and device settings may also provide controls relating to cookies and similar technologies.

Further information will be provided in our separate Cookie Policy.
9.15 Identity Verification

To protect personal data from unauthorised disclosure, SNOBBOT may need to verify the identity of a person making a privacy request.

Depending upon the request, we may ask for information reasonably necessary to confirm:

identity;

account ownership;

authority to act for another person; or

the personal data to which the request relates.

We will not intentionally request more information than reasonably necessary for verification.
9.16 Authorised Representatives

Where permitted by applicable law, an individual may appoint an authorised representative to submit a privacy request on their behalf.

SNOBBOT may request evidence that the representative has authority to act for the individual.

9.17 Response Times

SNOBBOT will respond to valid privacy requests within the period required by applicable law.

Where legally permitted, additional time may be required for complex or numerous requests.

If an extension applies, we will provide appropriate information where required.

9.18 Manifestly Unfounded or Excessive Requests

Where permitted by applicable law, SNOBBOT may refuse or charge an appropriate fee for requests that are manifestly unfounded, excessive or repetitive.

Where a request is refused, we will provide an explanation where required by law.

9.19 Exercising Your Rights

Privacy requests relating to personal data for which SNOBBOT is the controller may be submitted to:

SNOBBOT SOLUTION – FZCO
Email: info@snobbots.ae

Please provide sufficient information for us to understand and respond to your request.

9.20 Complaints

If you have concerns regarding SNOBBOT’s handling of your personal data, you may contact us first so that we can investigate the matter.

Depending upon applicable law and your location, you may also have the right to lodge a complaint with the competent data-protection or supervisory authority.

For individuals in the United Kingdom, this may include the Information Commissioner’s Office (ICO).

For individuals whose processing falls under UAE data-protection law, complaints and regulatory rights will be subject to the competent UAE authority and applicable UAE legal framework.
SECTION 10 – Cookies, Analytics & Tracking Technologies
10.1 Use of Cookies & Similar Technologies

SnobBots.com and the Platform may use cookies and similar technologies to operate, secure and improve the Platform and, where applicable, understand how users interact with our Services.

These technologies may include:

browser cookies;

session cookies;

persistent cookies;

local storage;

authentication technologies;

analytics technologies; and

other similar technical mechanisms.

Further information about specific cookies and their purposes will be provided in the separate SnobBots.com Cookie Policy.
10.2 Strictly Necessary Technologies

Certain cookies or similar technologies may be necessary for the Platform to function correctly.

These may be used for purposes including:

user authentication;

maintaining login sessions;

account security;

fraud prevention;

maintaining Platform functionality;

remembering essential settings;

load balancing; and

protecting the Platform against malicious activity.

Where permitted by applicable law, strictly necessary technologies may operate without consent because they are required to provide a service requested by the user or maintain essential Platform functionality.
10.3 Functional Technologies

Where used, functional technologies may enable the Platform to remember choices or provide enhanced functionality.

These may include:

account preferences;

interface settings;

language preferences;

remembered configurations; and

other user-selected functionality.

Where applicable law requires consent for such technologies, they will be subject to the relevant consent mechanism.
10.4 Analytics Technologies

Subject to applicable consent requirements, SNOBBOT may use analytics technologies to understand matters such as:

visits to SnobBots.com;

Platform usage;

feature usage;

navigation patterns;

session activity;

technical performance;

errors;

device and browser characteristics; and

general interaction with the Platform.

This information may be used to maintain, analyse and improve Platform performance and user experience.
10.5 Platform Analytics vs Website Tracking

Analytics presented to Platform customers concerning their own:

chatbot conversations;

leads;

usage;

credits;

messages;

training data;

content generation; or

other Platform activity

may form part of the core Platform Service and should not necessarily be treated in the same way as optional advertising or website-tracking cookies.

The legal treatment of a particular technology depends upon what the technology actually does and applicable law.
10.6 Authentication & Session Information

The Platform may store information necessary to:

recognise authenticated users;

maintain secure sessions;

prevent repeated logins;

protect accounts; and

provide authorised access to Platform functionality.

Disabling technologies necessary for authentication or session management may prevent parts of the Platform from functioning correctly.
10.7 Third-Party Technologies

Certain third-party providers integrated with SnobBots.com may place or access cookies or use similar technologies in accordance with their own services and privacy practices.

These may include providers supporting:

authentication;

payments;

analytics;

customer support;

security; or

other Platform functionality.

The specific providers and technologies used may change as the Platform develops.
10.8 Cookie Consent

Where applicable law requires consent before a non-essential cookie or similar technology is placed or accessed, SNOBBOT will seek consent through an appropriate mechanism.

Users should be able to make choices concerning relevant categories of non-essential technologies where required by applicable law.

10.9 Withdrawal or Modification of Consent

Where processing relies upon cookie consent, users may withdraw or modify that consent through the available cookie-management mechanism.

Withdrawal of consent does not affect the lawfulness of processing undertaken before consent was withdrawn.
10.10 Browser Controls

Most browsers allow users to control cookies through browser settings.

Depending upon the browser, users may be able to:

block cookies;

delete existing cookies;

restrict third-party cookies;

receive notifications when cookies are used; or

configure other privacy settings.

Blocking essential cookies may prevent some Platform functionality from operating correctly.
10.11 Customer-Deployed Chatbots

A SnobBots-powered chatbot deployed on a customer’s website may involve technologies necessary to:

load the chatbot;

maintain conversation state;

provide chatbot functionality;

preserve a session; or

support security.

The customer operating the website is responsible for determining its own cookie and tracking obligations concerning technologies deployed through its website, including whether consent or disclosure is required.

SNOBBOT may provide relevant technical information to customers where reasonably necessary to assist them with those obligations.
10.12 Customer Tracking Technologies

Customers must not use the Platform or SnobBots integrations to deploy unlawful tracking technologies or circumvent applicable cookie, privacy or consent requirements.

Where customers independently add analytics, advertising or other tracking technologies to websites or services connected with SnobBots, those technologies remain the customer’s responsibility.

10.13 Changes to Cookies & Technologies

The cookies and technical services used by SnobBots.com may change as the Platform develops.

The Cookie Policy will provide the more detailed record of applicable cookie categories and, where appropriate, relevant third-party technologies and retention information.
SECTION 11 – Children’s Privacy & Age Restrictions
11.1 Business & Professional Platform

SnobBots.com is primarily designed as a business and professional Artificial Intelligence platform.

The Platform is not designed or directed specifically towards children, and SNOBBOT does not intentionally market the Platform to children.

11.2 Account Registration by Minors

Individuals must satisfy the minimum age requirements applicable in their jurisdiction to create and operate a Platform account or otherwise enter into a binding agreement with SNOBBOT.

Where an individual is not legally capable of entering into the applicable agreement, the Platform must only be used under the authority and responsibility of an appropriately authorised adult or organisation, where permitted by law.

Further account eligibility requirements may be established in the SnobBots.com Platform Terms & Conditions.
11.3 Customer-Deployed Chatbots

Customers may deploy SnobBots-powered chatbots on websites or digital services that can potentially be accessed by children.

SNOBBOT does not necessarily control the audience of websites on which customer chatbots are deployed.

The customer deploying the chatbot is responsible for determining whether its service is:

directed towards children;

likely to be accessed by children;

collecting children’s personal data; or

subject to specific child-privacy or safeguarding requirements.
11.4 Customer Responsibility

Where a customer uses Platform functionality in circumstances involving children, the customer is responsible for determining and implementing all measures required by applicable law.

Depending upon the jurisdiction and use case, these may include:

parental or guardian consent;

age verification or age assurance;

child-appropriate privacy information;

restrictions on data collection;

restrictions on behavioural tracking;

appropriate retention periods;

safeguarding controls;

restrictions on profiling;

restrictions on marketing; and

additional security measures.
11.5 Lead Capture Involving Children

Customers must not intentionally use Platform lead-capture functionality to collect personal data from children unless the collection and subsequent processing are lawful and appropriate safeguards have been implemented.

Customers should configure lead-capture functionality proportionately to the intended audience of their website or service.
11.6 AI Conversations With Children

AI-generated responses are automated and may occasionally be:

inaccurate;

incomplete;

inappropriate for a particular age;

misunderstood; or

unsuitable for reliance without adult supervision.

Customers deploying AI functionality for services likely to be used by children must assess whether additional:

content restrictions;

human oversight;

moderation;

escalation;

disclosures; or

safeguarding measures

are required.
11.7 Sensitive Information Concerning Children

Customers should not use the Platform to collect unnecessary sensitive personal information concerning children.

Where such processing is necessary for a lawful use case, the customer must ensure that appropriate legal, technical and organisational safeguards are implemented before processing begins.
11.8 Knowledge of Children’s Personal Data

If SNOBBOT becomes aware that personal data relating to a child has been collected or processed in circumstances that appear inconsistent with applicable law or Platform requirements, we may take appropriate action.

Depending upon the circumstances, this may include:

investigating the issue;

contacting the relevant customer;

restricting the affected functionality;

requesting deletion or remediation;

deleting information where SNOBBOT is legally authorised or required to do so; or

taking other measures required by applicable law.
11.9 Requests Concerning Children’s Data

A parent, guardian or other legally authorised person who believes that SNOBBOT holds personal data concerning a child in circumstances where SNOBBOT acts as controller may contact:

SNOBBOT SOLUTION – FZCO
Email: info@snobbots.ae

SNOBBOT may require appropriate verification before disclosing, modifying or deleting information.

Where the relevant personal data is controlled by a Platform customer, the request may need to be directed to that customer.
11.10 No Circumvention of Child-Protection Requirements

Customers must not use SnobBots.com to circumvent:

age restrictions;

parental-consent requirements;

child-privacy protections;

safeguarding obligations; or

other legal protections applicable to children.

The availability of Platform functionality does not constitute approval by SNOBBOT for its use in a child-directed environment.
SECTION 12 – Customer Responsibilities for Personal Data
12.1 Customer Responsibility

Customers are responsible for ensuring that their collection, submission, use and other processing of personal data through the Platform complies with applicable privacy and data-protection laws.

Where SNOBBOT processes personal data on behalf of a customer, the customer remains responsible for its obligations as controller or other responsible party under applicable law.
12.2 Lawful Authority to Provide Data

Customers must ensure that they have the necessary lawful basis, authority, permissions and, where required, consents to provide personal data to SNOBBOT or otherwise process it through the Platform.

This applies particularly to:

chatbot conversations;

captured leads;

contact information;

uploaded documents;

training data;

knowledge bases;

website content;

WhatsApp communications;

connected data sources; and

information relating to employees, customers, prospects or other third parties.
12.3 Customer Privacy Notices

Customers deploying SnobBots functionality through their own websites, applications or communications channels are responsible for providing appropriate privacy information to affected individuals.

Where required, customer privacy notices should explain matters including:

what personal data is collected;

why it is collected;

how it is used;

the relevant lawful basis;

whether Artificial Intelligence is involved;

relevant service providers or processors;

international transfers;

retention;

individual rights; and

how the individual can contact the customer regarding privacy.
12.4 Chatbot Privacy

Customers deploying a SnobBots-powered chatbot are responsible for ensuring that the chatbot is used consistently with their privacy obligations.

Customers should consider whether users need to be informed that:

they are interacting with an automated or AI-powered system;

their messages may be recorded or retained;

conversations may be accessible to the business operating the chatbot;

information may be processed by third-party technology providers; and

they should avoid submitting unnecessary sensitive information.
12.5 Lead Capture

Customers using lead-capture functionality are responsible for determining:

what information should be collected;

the lawful basis for collection;

what notices should be provided;

whether consent is required;

how leads will subsequently be contacted;

how long lead information should be retained; and

when information should be deleted.

The ability to capture information through the Platform does not constitute legal authorisation to use that information for unrestricted marketing.
12.6 Direct Marketing

Where customers use information obtained through the Platform for:

email marketing;

WhatsApp marketing;

SMS;

telephone marketing;

remarketing;

sales outreach; or

other direct-marketing activities,

the customer is responsible for complying with applicable privacy, electronic communications, anti-spam and direct-marketing requirements.
12.7 WhatsApp & Messaging

Customers connecting WhatsApp or another messaging service are responsible for ensuring that:

they are authorised to contact relevant individuals;

required notices have been provided;

required consents have been obtained;

messaging practices comply with applicable law; and

use complies with the relevant third-party provider’s terms and policies.
12.8 Website Scanning & Training

Customers must only instruct the Platform to crawl, scan, retrieve, train upon or otherwise process website content where they have lawful authority to do so.

Customers are responsible for ensuring that use of website content does not unlawfully infringe:

privacy rights;

confidentiality obligations;

intellectual property rights;

database rights;

contractual restrictions; or

other third-party rights.
12.9 Uploaded Documents & Knowledge Bases

Customers are responsible for information they upload or connect to the Platform.

Customers should not upload personal data unless it is reasonably necessary for the intended purpose.

In particular, customers should assess whether documents contain:

sensitive personal data;

confidential information;

financial information;

health information;

children’s information;

credentials;

identification documents; or

other information requiring enhanced protection.
12.10 Data Accuracy

Customers should take reasonable steps to ensure that personal data they provide to the Platform is accurate and, where necessary, kept current.

SNOBBOT is not responsible for inaccuracies inherent in customer-provided information where SNOBBOT has not caused those inaccuracies.

12.11 Data Minimisation

Customers should configure Platform functionality so that only information reasonably necessary for the intended purpose is collected or processed.

Customers should avoid collecting personal data merely because the Platform technically allows it.
12.12 Access Controls

Customers are responsible for controlling access to personal data within their accounts.

This includes appropriately managing:

administrators;

employees;

contractors;

reseller users;

customer users;

login credentials;

permissions; and

connected integrations.
12.13 Exported Information

Where customers export:

leads;

conversations;

analytics;

account information; or

other personal data

from the Platform, the exported copy becomes subject to the customer’s own security, retention and privacy controls.

SNOBBOT cannot control how information is independently stored or processed after lawful export from the Platform.
12.14 Data Subject Requests

Where a customer acts as controller, the customer is responsible for responding to requests from individuals concerning their personal data.

SNOBBOT may provide reasonable assistance where required by applicable law and applicable contractual data-processing terms.

12.15 Customer Retention Decisions

Customers are responsible for determining appropriate retention periods for personal data they control through the Platform.

Customers should not retain chatbot conversations, leads or other personal information indefinitely without a legitimate purpose.

12.16 Data Breaches & Security Incidents

Customers must promptly investigate security incidents involving systems or credentials under their control.

Where an incident may affect SnobBots.com or information processed by SNOBBOT, the customer should notify SNOBBOT promptly so that appropriate protective measures can be considered.
12.17 White-Label & Reseller Responsibilities

White-label and reseller customers may have additional privacy responsibilities where they provide Platform functionality to their own customers.

Depending upon the arrangement, the reseller may be responsible for:

providing privacy notices;

establishing lawful bases;

managing customer relationships;

responding to privacy requests;

managing consent;

ensuring lawful marketing;

implementing appropriate contractual terms; and

communicating relevant information concerning SNOBBOT’s role in processing.

White-labelling the Platform does not transfer SNOBBOT’s legal obligations to the reseller, nor does it remove the reseller’s own obligations.
12.18 Customer Instructions

Where SNOBBOT acts as processor, we may process customer-controlled personal data in accordance with the customer’s documented instructions, except where applicable law requires otherwise.

SNOBBOT is not required to follow an instruction that would require us to process information unlawfully.
12.19 Prohibited or Unlawful Processing

Customers must not use the Platform to intentionally:

collect personal data unlawfully;

obtain information through deception or impersonation;

conduct unlawful surveillance;

process stolen or unlawfully obtained data;

circumvent privacy rights;

send unlawful marketing communications; or

otherwise violate applicable data-protection law.

Additional restrictions will be contained within the Platform Terms & Conditions and AI Services & Responsible Use Policy.
12.20 Responsibility Cannot Be Transferred by Technology

The availability of a Platform feature does not mean that its use is lawful or appropriate in every jurisdiction or context.

Customers remain responsible for assessing the legality and appropriateness of their own use of personal data through SnobBots.com.
SECTION 13 – Data Processing on Behalf of Customers
13.1 Controller and Processor Relationship

Where a customer uses SnobBots.com to process personal data for purposes determined by that customer, the customer will generally act as the data controller and SNOBBOT will act as the data processor, or equivalent roles recognised under applicable law.

This may apply to personal data contained within:

chatbot conversations;

captured leads;

WhatsApp communications;

customer knowledge bases;

uploaded documents;

website training data;

customer contact information;

connected data sources; and

other customer-controlled information processed through the Platform.

The precise legal roles will depend upon the circumstances and applicable law.
13.2 Customer Instructions

Where SNOBBOT acts as processor, we will process customer-controlled personal data for the purpose of providing the Platform Services and in accordance with:

the customer’s documented instructions;

the applicable agreement;

any applicable Data Processing Agreement;

this Privacy Policy; and

applicable law.

The customer’s use and configuration of the Platform may constitute documented instructions for processing reasonably necessary to provide the selected functionality.
13.3 Scope of Processing

Processing performed on behalf of customers may include:

collection;

receipt;

hosting;

storage;

organisation;

indexing;

retrieval;

analysis;

transmission;

AI processing;

generation;

display;

export;

deletion; and

other operations necessary to provide the relevant Platform functionality.
13.4 Purpose of Processing

SNOBBOT will process customer-controlled personal data as reasonably necessary to:

provide the Platform;

operate requested features;

maintain customer accounts;

provide technical support;

maintain security;

prevent misuse;

troubleshoot Platform functionality;

comply with lawful customer instructions; and

fulfil applicable legal obligations.

SNOBBOT will not intentionally use customer-controlled personal data for unrelated independent purposes where we are acting solely as processor.
13.5 Confidentiality

Persons authorised by SNOBBOT to process customer-controlled personal data will be subject to appropriate confidentiality obligations where required.

Access to customer information should be limited to persons or systems requiring access for legitimate operational, technical, support, security or legal purposes.
13.6 Security of Processing

SNOBBOT will implement reasonable technical and organisational measures appropriate to the nature and risk of the processing for which SNOBBOT is responsible.

Customers remain responsible for security matters under their own control, including:

account permissions;

user access;

customer credentials;

connected systems;

customer-controlled integrations; and

exported information.
13.7 Subprocessors

SNOBBOT may use subprocessors to assist in providing the Platform.

Subprocessors may provide services including:

cloud hosting;

databases;

storage;

Artificial Intelligence;

communications;

authentication;

monitoring;

security;

support; and

other infrastructure or technical functionality.

Where required by applicable law, SNOBBOT will impose appropriate data-protection obligations upon subprocessors.
13.8 AI Providers as Subprocessors

Where customer-controlled personal data is transmitted to an AI provider solely to provide requested Platform functionality, that provider may act as a subprocessor or otherwise process information within the relevant provider relationship.

The specific legal role of a provider may depend upon its terms, the service configuration and applicable law.

SNOBBOT may replace or add AI providers as Platform technology evolves, subject to applicable contractual and legal obligations.

13.9 International Processing

Customer-controlled personal data may be processed internationally as described in Section 6 – International Data Transfers.

Where required, appropriate international-transfer mechanisms will be implemented for transfers for which SNOBBOT is responsible.
13.10 Assistance With Data Subject Rights

Taking into account the nature of the processing and information reasonably available to SNOBBOT, we may assist customers with responding to valid requests concerning:

access;

correction;

deletion;

restriction;

portability;

objection; and

other applicable privacy rights,

where required by applicable law or contractual data-processing terms.
13.11 Personal Data Breaches

Where SNOBBOT acts as processor and becomes aware of a personal-data breach affecting customer-controlled personal data, we will notify the relevant customer where required by applicable law or contractual obligations.

SNOBBOT may provide information reasonably available to us concerning:

the nature of the incident;

affected systems or information;

known consequences;

containment measures; and

remediation undertaken.

The customer remains responsible for determining whether notifications to individuals or authorities are required where the customer is the controller.
13.12 Data Protection Assessments

Where legally required and taking into account the nature of the processing and information available to SNOBBOT, we may provide reasonable assistance to customers with relevant:

data protection impact assessments;

security assessments;

regulatory enquiries; or

prior consultations with supervisory authorities.

Material assistance outside normal Platform support may be subject to separate commercial arrangements where permitted by the applicable agreement.
13.13 Compliance Information

Where required by applicable law or contractual data-processing arrangements, SNOBBOT may make available information reasonably necessary to demonstrate compliance with applicable processor obligations.

Any audit or inspection rights will be subject to appropriate:

confidentiality;

security;

proportionality;

scheduling; and

contractual requirements.
13.14 Return or Deletion Following Termination

Following termination of the relevant Services, customer-controlled personal data will be returned, made available for export, deleted or otherwise handled in accordance with:

applicable contractual terms;

available Platform functionality;

applicable Data Processing Agreements;

legal retention requirements; and

relevant third-party technical limitations.

Customers should export information they require before account closure where export functionality is available.
13.15 Legally Required Processing

If SNOBBOT is legally required to process customer-controlled personal data other than in accordance with the customer’s instructions, we may do so to the extent required by applicable law.

Where legally permitted, we will inform the customer of the relevant requirement.

13.16 Unlawful Instructions

SNOBBOT is not required to follow a customer instruction that we reasonably believe would violate applicable data-protection law.

Where appropriate, we may inform the customer of the concern and require the instruction to be modified before processing continues.
13.17 Customer Data Processing Agreement

Where applicable data-protection law requires additional contractual provisions between SNOBBOT and a customer concerning processing of personal data, the parties may enter into or otherwise incorporate a Data Processing Agreement (“DPA”).

The DPA may address matters including:

subject matter and duration of processing;

nature and purpose of processing;

categories of personal data;

categories of data subjects;

controller instructions;

confidentiality;

security;

subprocessors;

international transfers;

data-subject rights;

breach notification;

deletion and return; and

legally required compliance assistance.
13.18 Privacy Policy Does Not Replace a Required DPA

This Privacy Policy explains SNOBBOT’s general privacy practices but does not automatically replace a Data Processing Agreement where a separate DPA is legally or contractually required.

Where a DPA applies and conflicts with this Privacy Policy concerning customer-controlled processing, the DPA will govern to the extent specified by the applicable contractual framework.
SECTION 14 – Changes to This Privacy Policy
14.1 Policy Updates

SNOBBOT may update or amend this Privacy Policy from time to time to reflect changes in:

the SnobBots.com Platform;

Platform features and functionality;

Artificial Intelligence technologies;

third-party service providers;

integrations;

data-processing practices;

security requirements;

applicable laws and regulations;

regulatory guidance; or

SNOBBOT’s business and operational practices.

The current version of this Privacy Policy will be made available through SnobBots.com.
14.2 Platform Development

SnobBots.com is an evolving AI Platform. New functionality may be introduced and existing functionality may be modified, replaced or discontinued.

This may include changes to:

chatbot functionality;

website scanning and training;

knowledge bases;

lead capture;

WhatsApp and messaging integrations;

SEO and content-generation tools;

website auditing;

analytics;

subscriptions and billing functionality;

white-label and reseller functionality;

AI models and providers; and

other Platform features.

Where a change materially affects how personal data is processed, this Privacy Policy may be updated accordingly.
14.3 Material Privacy Changes

Where required by applicable law, we will provide appropriate notice of material changes to this Privacy Policy.

Depending upon the circumstances, notice may be provided through:

com;

the Platform dashboard;

email;

account notifications; or

another appropriate communication method.
14.4 Changes Requiring Consent

Where a proposed change involves processing for which applicable law requires consent, publication of an updated Privacy Policy alone will not replace that consent.

Where required, SNOBBOT will obtain appropriate consent before undertaking the relevant processing.
14.5 Changes to Third-Party Providers

The third-party technologies supporting SnobBots.com may change as the Platform develops.

SNOBBOT may add, replace or remove providers involved in:

Artificial Intelligence;

cloud hosting;

databases;

storage;

authentication;

payments;

messaging;

analytics;

security;

communications; and

other Platform infrastructure.

Where a provider change materially affects our privacy obligations, we will update relevant documentation or provide notice where required.
14.6 Subprocessor Changes

Where SNOBBOT acts as a processor and contractual or legal requirements provide customers with specific rights concerning new or replacement subprocessors, those changes will be handled in accordance with the applicable Data Processing Agreement or other contractual terms.

14.7 Effective Date

The effective date and most recent revision date of this Privacy Policy will be identified at the beginning of the document.

Unless otherwise stated, an updated version becomes effective from the date specified, subject to any additional notice or consent requirements imposed by applicable law.
SECTION 15 – Contact, Complaints & Final Provisions
15.1 Privacy Contact

Questions, requests or concerns regarding this Privacy Policy or SNOBBOT’s processing of personal data may be directed to:

SNOBBOT SOLUTION – FZCO

IFZA Business Park
Dubai Digital Park
Dubai Silicon Oasis
Dubai
United Arab Emirates

Licence Number: 77651
Corporate Tax Registration Number (TRN): 105398497500001
Email: info@snobbots.ae
Platform: snobbots.com
15.2 Privacy Rights Requests

Where SNOBBOT acts as controller, requests concerning applicable privacy rights may be submitted using the contact details above.

Please provide sufficient information to allow us to:

identify the relevant information;

understand the request; and

verify identity where reasonably necessary.

Where the information is controlled by one of our Platform customers, we may direct the request to that customer or otherwise handle the request in accordance with our processor obligations.
15.3 Customer End-User Enquiries

If you interacted with a SnobBots-powered chatbot, lead-capture service, WhatsApp integration or other functionality operated by one of our customers, that customer may be the controller of your personal data.

Privacy requests concerning the customer’s use of your information should generally be directed to the organisation operating the relevant website, chatbot or service.

15.4 Complaints

Individuals who have concerns about SNOBBOT’s processing of personal data may contact us using the details above.

Where applicable law provides the right to do so, individuals may also lodge a complaint with the competent data-protection or supervisory authority.

For individuals in the United Kingdom, this may include the Information Commissioner’s Office (ICO) where UK data-protection law applies.

Rights concerning complaints under UAE data-protection law will be subject to the applicable UAE regulatory framework and competent authority.

15.5 No Waiver of Mandatory Rights

Nothing in this Privacy Policy is intended to exclude, restrict or waive privacy or data-protection rights that cannot lawfully be excluded, restricted or waived.

Where mandatory applicable law provides greater protection than this Privacy Policy, the mandatory legal requirement will apply to the extent required.

15.6 Severability

If any provision of this Privacy Policy is determined to be invalid, unlawful or unenforceable, that provision will be interpreted or modified to the minimum extent necessary where legally possible.

The remaining provisions will continue to apply.
15.7 Relationship With Platform Terms

This Privacy Policy explains how personal data is handled and should be read alongside the applicable:

com Platform Terms & Conditions;

Cookie Policy;

AI Services & Responsible Use Policy;

Data Processing Agreement, where applicable; and

any other privacy notice or contractual documentation expressly applicable to a particular Service.