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Cabo PenPals Privacy Policy

This privacy policy ("Policy") sets out how Cabo Applications, LLC. ("Cabo"), makers of the Cabo PenPals® AI-powered entertainment platform (“Cabo App”) use and protect the personal information of people who use the Cabo App.
Privacy Principles
Cabo has two fundamental principles when it comes to personal information: 
  • We created a system engineered that takes the extra step of encrypting your person-to-person communications to keep them private, even from us. We cannot access your person-to-person chats or chats in private groups. Your communications with Cabo AI Characters, communications in public group chats, including interactions in group chats featuring Cabo AI Characters, are not encrypted and are visible to other participants and to Cabo. 
  • We only store the personal information that we need to operate our Service so you can communicate with the people you choose.
  • We don’t sell your Personal Information.
We use AI to power our entertainment characters. Your interactions with AI Characters may be used to train and improve our AI models, as described in the “What We Collect” section below.
This Policy applies to anyone who accesses the Service. By using the Cabo App, you acknowledge that the collection, use, and sharing of your information will take place as described in this Policy.
So that we are clear about the terminology we are using, when we use the phrase “Personal Information” in this Privacy Policy, we mean information that is capable of being associated with or could reasonably be linked with you, such as your name, email, or mobile phone number.
What We Collect
The Cabo App is an AI-powered entertainment, communication, and social platform. To operate the Service, we may collect Personal Information you choose to provide us.
1. The Cabo App
a. Basic Account Data. To create a Cabo App account (“Account”), you provide your name, email address, mobile number for account creation, validation and attest that you are old enough to meet the age requirements. To facilitate a better user experience, you may also choose to customize your profile with information about your gender and birthdate, a profile photo and display name visible to other users and Cabo AI Character interactions.
b. Cabo App Messages. The Cabo App is a cloud service. However, your contacts stay local to your device. Your messages in one-on-one chats with other users and private group chats, are stored in an encrypted format that only you can decrypt. Content shared in Cabo AI Character chats (direct and group chats) and content in public group chats, and all other user generated content is not encrypted.
c. Cabo AI Character Interaction Data. When you interact with Cabo’s AI Characters, we collect the content of those interactions (your messages and the AI responses). This data may be used to: (i) deliver and personalize the entertainment experience; (ii) train, fine-tune, and improve our AI models and character personalities; (iii) detect and prevent misuse; and (iv) analyze engagement trends. Interaction data from public group chats may be reviewed by Cabo staff for moderation and quality purposes. You should not share sensitive personal information within AI Character conversations.
2. User Support
If you contact Cabo support, any Personal Information you may share with us is used only for the purposes of researching the issue and contacting you about your request.
3. Additional Technical Information
We use third-party Service Providers (as more fully described below), including services from Google, Apple and our AI infrastructure partners, to process your communications and analyze application performance. Our Services automatically log information about you and your mobile device, and how you interact with the Service. For example, when you access the Service, we may log your operating system type, language, how long you spent on the Cabo App, access times, device address, your mobile device ID, mobile device serial number, unique user ID, wireless carrier, and information about your use of and actions on the Service. Cabo collects this additional technical data to analyze usage trends and give us more information about how people use the Service to better the user experience.
Web Beacons
We may log information using pixels called web beacons on our Service or in our communication tools. We use web beacons to manage cookies, count visits, and to learn which of our messages are read and used by our users and which are not. We also use web beacons to tell if you open or act on our communications. Like cookies, we use web beacons to improve your experience with our Service.
Tracking Options and California Do Not Track Disclosures. You are welcome to adjust your operating system settings to limit this tracking.
Managing Your Information
You can manage your Personal Information, up to and including permanent deletion of your account and associated data in the Cabo App under Settings.
Use of Personal Information
We use the information that we have about you to operate, provide, support, personalize, and make our Service more relevant and useful to you and others.
We may use the Personal Information we collect from and about you to:
  • Operate, maintain, and improve our Service;
  • Allow you to find and connect with your friends (when instructed by you);
  • Let your friends know about your activity on the Service;
  • Analyze usage and trends and personalize and improve the Service and your experience using the Service;
  • Personalize Cabo AI Character interactions and entertainment experiences based on your engagement history and preferences;
  • Respond to your comments and questions and provide support;
  • Send information including confirmations, technical notices, updates, security alerts, and support and administrative messages;
  • Send marketing push notifications and emails that promote the use of the Cabo App from which you can opt-out;
  • Protect, investigate, and deter against fraudulent, unauthorized, or illegal activity; and
  • Provide and deliver products and services that you request.
  • Train, evaluate, and improve our AI models and Cabo AI Character personalities;
  • Moderate content in public group chats for safety and compliance with our Terms of Service and Community Guidelines.
We also retain a record of the age attestation you provide at account registration to confirm your eligibility to use the Service, for the life of your account, in compliance with our minimum age requirements and applicable law.
Our marketing emails tell you how to opt-out or unsubscribe. If you opt-out of marketing emails, we may still send you non-marketing emails and notifications, which may include information about your account, our business dealings with you, and updates regarding our policies.
Sharing of Personal Information
We may share the Personal Information we collect from and about you (1) with other Cabo App users, according to your account preferences selection and consistent with our Terms of Service; (2) for legal, protection, and safety purposes; (3) to comply with laws and in response to lawful requests and legal processes; (4) to protect the rights and property of Cabo, our agents, customers, and others, including by enforcing our agreements, policies, and Terms of Service; and (5) with those who need it to do work for us (our Service Providers, as defined below).
Other Cabo App Users
Other users of our Service with whom you choose to communicate will be given some of your Personal Information. These other users may be located anywhere in the world, including outside the European Economic Area (“EEA”). Note that by entering into the Terms of Service and choosing to communicate with such other users of the Cabo App, you are instructing us, as part of our contract with you, to transfer your Personal Information, on your behalf, to those users in accordance with this Privacy Policy. We employ all appropriate technical and organizational measures to ensure a level of security for your Personal Information that is appropriate to the risk.
If Cabo or substantially all of our assets are acquired by a third party, Personal Information held by us about our users will be one of the transferred assets. Such third party will be required to treat that Personal Information in a manner consistent with this Policy.
Service Providers
We work with third parties to provide some of our Service (“Service Providers”). For example, we use Third-Party SMS and/or Email Providers to send a verification message to you when you register on the Cabo App. We also work with third-party AI infrastructure providers to power our AI Characters and related features. Service Providers may have access to your Personal Information if needed to perform their business functions but may not share that Personal Information for purposes outside the scope of their functions related to the Service.
AI Model Providers
We use third-party large language model (LLM) and AI providers to generate Cabo AI Character responses. These providers may process the text of your conversations with Cabo AI Characters in order to generate responses. 
Our Commitment Towards Children’s Privacy
Users under 18 are not eligible to use the Service. If we learn that a user is under 18 years of age, we will take steps to disable the account and remove that user’s Personal Information from our databases. This minimum age reflects the nature of our AI entertainment content and applicable regulations.
Notification Choices
By default, Cabo sends you notifications regarding activities on the Service, e.g., when you receive a connection request, when there is activity in one of the chat groups you are part of, from one of the Cabo AI Characters or from the Cabo App platform. We may also communicate with you via informational, transactional, or marketing emails and/or text messages. You may choose to unsubscribe from emails by clicking “Unsubscribe” from the email. If you unsubscribe, we may still need to send you non-marketing emails about your account or our business dealings with you. We may also send you text notifications. You may also send requests about your Personal Information to [email protected]. You control your contact choices, opt-out of our sharing with others, and update your Personal Information.
Links to Other Sites
The Service may contain links to other third-party websites or applications. For example, we allow you to share information about the Cabo App via social media and use social credentials to access Cabo PenPals. Any information you provide on those sites is subject to that third party’s privacy policy. Our Policy does not apply to such sites, and we are not responsible for the privacy and security practices and policies of those third-party sites or applications.
Security of Your Personal Information
We are committed to protecting the security of your Personal Information. We have taken certain physical, administrative, and technical steps to help safeguard the information we collect from and about you. While we take steps to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures.
AI-Related Data Rights
Because Cabo uses AI to generate character responses, you have additional rights regarding AI-generated content and automated processing:
  • Right to Know: You may request information about how your interaction data has been used to train or inform AI models.
  • No Consequential Automated Decisions: We do not use Cabo AI Character interaction data to make decisions that have legal or similarly significant effects on you.
California Consumer Privacy Act (CCPA) and General Data Protection Regulation (GDPR)
The CCPA and GDPR provide rights to certain individuals located in California and the European Union. We apply these rights to all of our users. You can contact us about these rights at [email protected]
CCPA
We do not disclose Personal Information beyond what is described in this Policy. All our users, including those in California, have the following rights:
Right to access: You have the right to know and see what data we have collected about you over the past 12 months including: categories of personal information we have collected about you; categories of sources from which the personal information is collected; the business or commercial purpose for collecting your personal information; the categories of third parties with whom we have shared your personal information; and the specific pieces of personal information we have collected about you.
Right to deletion: You have the right to request that we delete in certain circumstances the personal information we have collected from you.
Right not to be discriminated against: You have the right not to be discriminated against for exercising any of these rights. To request access to or deletion of your personal information, or to exercise any other data rights under the CCPA, please contact us at [email protected]
General Data Protection Regulation (GDPR)
We, Cabo, are the data controller of your Personal Information. Our contact information can be found at the end of this Policy.
Information According to GDPR Article 27 and UK Laws
Cabo is a company located outside of the European Union. In order to comply with GDPR Article 27 and UK laws, Prighter has been engaged as our representative in the European Union and the UK. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative Prighter or make use of your data subject rights, please visit: https://prighter.com/q/12798451744 or simply email us at [email protected].
We also have an appointed Data Protection Officer, who can be contacted at [email protected]
All our users, including those in the European Economic Area (EEA), have the following rights, about which you can contact us at [email protected]
Right to access: the right to request certain information about, access to and copies of the Personal Information about you that we are holding;
Right to rectify, limit, cease processing or erase: information we hold about you in certain circumstances;
Right to data portability: the right to request that we return any information you have provided in a structured, commonly used, and machine-readable format, or that we send it directly to another company, where technically feasible;
Right to object: the right to object to our use of your Personal Information including where we use it for our legitimate interests or, if applicable, for marketing purposes; and
Right to lodge a complaint: about us to a supervisory body in your country of work or residence (for instance, the Information Commissioner’s Office in the UK).
Legal Basis for Processing
We process your Personal Information on the ground that such processing is necessary to further our legitimate interests (including: (1) providing an effective and innovative Service to our users; (2) operating and improving AI-powered entertainment features; and (3) to detect, prevent or otherwise address fraud or security issues in respect of our provision of the Service), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of Personal Information.
We also process your Personal Information where it is necessary on the basis of performing under our contract with you in accordance with our Terms of Service, or in order to create a contract with you.
Recipients of Personal Information and transfers to third countries: as set out in the sections above called Sharing of Personal Information and Service Providers, we share your Personal Information with certain third-party providers in the United States, and such transfers are subject to appropriate safeguards.
Retention
We may retain the Personal Information you provide as long as you have a Cabo App Account. 
Cabo App
If you delete your Account, your Personal Information, and any conversations you saved will be deleted on our servers within 30 days. This includes your name, profile picture, messages, images, videos, and information you have shared with other users through the Cabo App that are stored on your mobile. Deleting your user account will not have any impact on the other person’s end. That is, they can still view past chats with you (now anonymized) unless they have already deleted or cleared the chat themselves on their end.
If you delete your Account and had earlier synced your phone’s contact list with the Cabo App, the contact data, and names of any of your contacts who have not registered on the Cabo App will also be deleted from our servers within 30 days. If in the future you sign up again with the same phone number, you’ll be starting with a blank slate.
All data from your participation in that Group will be removed from your Cabo App. However, communications made prior to exiting the Group will remain for the Group users, unless the Group moderators remove messages that violate either Group rules or the Cabo Community Guidelines.
Contact Information
We welcome your comments or questions about this Policy. You may contact us at [email protected]
Changes to Privacy Policy
We may modify this Policy from time to time. If we make any changes, we will change the Last Updated date below. We also may provide additional notice, as applicable, depending on the type of change. If you object to any changes, you may stop using the Service. Your continued use of the Service after we publish or otherwise provide notice about our changes to the Policy means that you have read and understood the updated Policy.
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Last Updated on June 30, 2026

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