Privacy Policy

Last Updated January 24, 2024

1. Introduction
Welcome to Abulé Inc. Abulé Inc. (“Company, “us”, “we” or “our”) is committed to protecting your privacy. The following policy (the “Privacy Policy”) describes our practices for collecting, using, maintaining, and disclosing information that we collect from you or that you provide to us when you visit our website (our “Site”), use our mobile application, Tribe (“App”), or use any other products and services made available by us (collectively, the “Services”). Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. The use of information collected through our Services will be limited to the purposes described under this Privacy Policy and our Terms of Service (or other relevant customer contracts). By accessing or using the Services, you agree to this Privacy Policy. Please be aware that if you are using the Services on behalf of an entity, you are agreeing to this Privacy Policy for that entity and are representing to us that you have the authority to do so (in which case “you” will refer to that entity). If you do not agree with our policies and practices, your choice is not to use the Services. This Privacy Policy may change from time to time. If we make any changes, we will post the changes on this page and indicate at the top of this page the date the policy was last revised. We will also notify you of any material changes either through a pop-up notice, email or through other reasonable means. Any such changes are effective immediately when we post them and apply to all access to and use of the Services thereafter. Your continued use of the Services after the date any such changes become effective constitutes your acceptance of the new policy.

2. Information Collection
We may collect several different types of information you provide directly via the Services and automatically when you use the Services to provide and improve your experience with the Services and for other lawful purposes. Personal DataWhile using our Service, we may ask you to provide us with some or all of the following personally identifiable information that can be used to contact or identify you about you or your child(ren) or dependent(s) (“Personal Data”). Personal Data may include, but is not limited to:

(a) Email address

(b) First name and last name

(c) Phone number

(d) Residential and/or school address, State, Province, ZIP/Postal code, City

(e) Age

(f) Cookies and Usage Data
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link. Usage Data We may also collect information automatically whenever you access our Services (“Usage Data”), including:

(a) Your browser type and operating system

(b) Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area

(c) Geolocation information

(d) Other unique identifiers, including mobile device identification numbers

(e) Sites you visited before and after visiting the Services

(f) Pages you view and links you click on within the Services

(g) Information collected through cookies, web beacons, and other technologies

(h) Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded

(i) Standard Server Log Information
When you access the Services with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.‍ Tracking Cookies Data We collect the above information in a variety of ways, including by using “cookies”, “pixel tags,” and “web beacons”.Cookies are small bits of data that are stored on your computer’s browser. You can decide if and how your computer will accept a cookie by configuring your browser. However, if you do not accept cookies, you may not be able to use some portions of the Services. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

3. Use of Data
The Company may use the information that we collect about you or that you provide to us, including Personal Data, for various purposes, including:

(a) to provide and maintain our Service;

(b) to notify you about changes to our Service;

(c) to allow you to participate in interactive features of our Services when you choose to do so;

(d) to provide customer support;

(e) to improve our Service;

(f) to monitor the usage of our Service;

(g) to detect, prevent and address technical issues and fraud;

(h) to fulfill any other purpose for which you provide it;

(i) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

(j) to provide you with notices about your account and/or subscription, including expiration and renewal notices, and email-instructions;

(k) to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;

(l) in any other way we may describe when you provide the information;

(m) for any other purpose with your consent.

4. Retention of Data
We strive to keep your information only as long as we need it for legitimate business purposes and as permitted by applicable legal requirements. If you close your account, we will retain certain data for analytical purposes and recordkeeping integrity, as well as to prevent fraud, enforce our Terms of Use, take actions we deem necessary to protect the integrity of our Services or our users, or take other actions otherwise permitted by law. In addition, if certain information has already been provided to third parties asdescribed in this Privacy Policy, retention of that information will be subject to those third parties’ policies. You acknowledge that the Company may establish general practices and limits concerning use of the Services, including the maximum storage space that will be allotted our servers on your behalf. You further acknowledge that the Company reserves the right to change these general practices and limits at any time, in its sole discretion. We will endeavor to give you notice of any such change where required by applicable law.

5. Disclosure of Data
We may disclose information that we collect or yo provide through the Services with third parties as follows:

(a) Disclosure for Law Enforcement: Under certain circumstances, we may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities.

(b) Business Transaction: If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred to one or more third parties as part of that transaction.

(c) Other cases. We may disclose your information also:

(i) to our subsidiaries and affiliates;

(ii) to contractors, service providers, and other third parties we use to support our business;

(iii) to fulfill the purpose for which you provide it;

(iv) for any other purpose disclosed by us when you provide the information;

(v) with your consent in any other cases;

(vi) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

6. Security of Data
We take reasonable steps to protect the Personal Data provided to us from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. Please keep this in mind when disclosing any Personal Data to us via the Internet. In the event that Personal Data is compromised as a breach of security, we will promptly notify our customers in compliance with applicable law.7. Choices About How We Collect, Use and Disclose Your Information We strive to provide you with choices regarding our collection, use and disclosure of the information you provide to us. The mechanisms listed below aim to provide you with control over such collection, use and disclosure:

Marketing Communications. If you do not want us to send you marketing or promotional communications, you can opt-out by clicking the “unsubscribe” link in any such promotional emails, checking the relevant box located on the form on which we collect your data or emailing us at legal@abule.io. Cookies. You have the option to accept or disable cookies at any time through your browser. You may refuse to accept browser cookies by activating the appropriate setting on your browser. If you choose to disable your cookies, your user experience may be limited.

Google Analytics. You can opt out of tracking by Google Analytics by using Google’s Ads Settings or going to tools.google.com. You may also opt out of Google marketing products, but please note that this does not opt you out of being served generic ads. Mobile Analytics. If you are using our App, we use Mobile Device IDs, instead of cookies, to recognize you. We use the Mobile Device IDs and other mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. These Mobile Device IDs are only tracking and collecting Non-Personal Data. The software may record information such as how often you use the Services, the events that occur within the App, aggregated usage, performance data, and where the App was downloaded from.

Third-Party Advertising. If you are interested in more information about tailored advertising and your choices to prevent third parties from delivering tailored web advertisements, you may visit the following websites: networkadvertising.org or aboutads.info. These opt-out tools are provided by third parties. We do not control or operate these tools or the choices that advertisers and others provide through these tools.

7. Payments
We may provide paid products and/or services within Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment details. That information is provided directly to our third-party payment processors whose use of your Personal Data is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSSas managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information. We will, however, have access to certain information associated with your account should you purchase the Services, including the amount and date of the purchase.

8. Third-Party Sites and Services
Our Services may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site and will be bound by the third party’s privacy policy and terms of service. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services accessed through our Services. The Services may allow you to post information to various third-party services or platforms, such as social networking services like Instagram, Twitter and Facebook. You acknowledge that if you choose to use this feature, your friends, followers and subscribers on these third-party services or platforms will be able to view such activity. If you choose to access or make use of third-party social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services. The use of the information by such social networking websites will be governed by their privacy policies, and we do not control their use of the shared data.

9. Do Not Track Signals
Third parties may keep track of your browsing activities across third party websites. California Business & Professions Code Section 22575(b) provides that California residents are entitled to know we respond to “Do Not Track” browser signals. Certain web browsers enable users to activate a “Do Not Track” signal but we do not currently respond to the “Do Not Track” signal or other similar mechanisms.

10. Children's Privacy
Our Site and Services, under no circumstances, are meant to be used by users under the age of 13. If you are under the age of 13, you are not permitted to submit any Personal Information to us. If you believe we might have any information from or about a child under 13, please contact us at legal@abule.io

11. Notice to California Residents California Civil Code Section 1798.83
Also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a calendar year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please send an email to legal@abule.io

12. Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

13. International Users
Please note that the Services are directed towards users who reside in the United States. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States. Some of these countries may not offer the same level of privacy protection as your own.

14. Contact Us
Please send your feedback, comments, requests for technical support:

By email: legal@abule.io

By mail: Abulé Inc.
Attn: Legal Department
276 5th Ave Suite 704 #927
New York, NY 10001