Introduction

Tombolo Research FZ LLC ("Tombolo Research," "we," "us," or "our") is committed to protecting the privacy and personal information of our website visitors, course registrants, and users. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website (tomboloresearch.ai) and use our services, including our AI-assisted registration system.

This policy has been prepared with reference to Bermuda's Personal Information Protection Act 2016 (PIPA). By using our website or registering for our courses, you consent to the practices described in this policy.

Information We Collect

Information You Provide Directly

When you register for one of our AI courses — whether through our AI assistant Lily or through our manual registration form — we collect the following information:

• Full name

• Email address

• Phone number

• Age

• Gender

• Organization or employer

• Job title or role

• AI knowledge level and experience

• Reasons for interest in AI

• Coding experience (Applied AI Lab registrants)

• Topics of interest

• Accessibility needs

• Any additional information you choose to share

Information Collected Automatically

When you use our AI-assisted registration (Lily), the following is collected automatically:

• Audio recording of your conversation with Lily

• Transcript of the conversation

• Conversation metadata (date, time, duration)

We do not collect video or visual data from your camera during registration conversations. Camera access is not required to use Lily.

Website Data

When you visit our website, we may automatically collect standard technical data such as your IP address, browser type, device information, and pages visited, through cookies and similar technologies as described in our Cookie Policy.

How We Use Your Information

We use the information we collect for the following purposes:

• Processing your course registration and enrollment

• Sending confirmation emails and course-related communications

• Managing course logistics and planning

• Responding to your inquiries

• Improving our services and course offerings

• Complying with legal obligations

We do not use your personal information for marketing purposes unrelated to your course enrollment unless you separately opt in.

Third-Party Service Providers

To process registrations and deliver our services, your information is shared with some third-party service providers.

International Data Transfers

Our third-party service providers are based in the United States. By using our services, you consent to the transfer, processing, and storage of your personal information outside of Bermuda. We take reasonable steps to ensure that your information is treated securely and in accordance with this Privacy Policy, and we select service providers that maintain appropriate security measures.

Data Retention

We retain your registration information for as long as necessary to fulfill the purposes for which it was collected, including to complete your course enrollment, comply with legal obligations, and resolve disputes. Specifically:

• Registration records are retained for the duration of the course and for up to 12 months afterward for administrative purposes.

• Conversation transcripts are retained for up to 90 days after registration, after which they are deleted.

• Mailchimp subscriber data is retained until you unsubscribe or request deletion.

You may request deletion of your personal information at any time by contacting us at info@tomboloresearch.ai.

Data Security

We implement reasonable administrative, technical, and physical safeguards to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include encrypted data transmission, secure storage with access controls, and careful selection of service providers with strong security practices.

However, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security of your information.

Your Rights Under PIPA

Under Bermuda's Personal Information Protection Act, you have the right to:

• Access the personal information we hold about you

• Request correction of inaccurate personal information

• Request deletion of your personal information

• Withdraw consent for the processing of your information

• Know what personal information we have disclosed and to whom

• File a complaint with the Privacy Commissioner if you believe your rights have been violated

To exercise any of these rights, contact us at info@tomboloresearch.ai. We will respond to your request within 45 days.

Cookies

Our website uses cookies and similar tracking technologies to enhance your browsing experience. You can control cookie preferences through your browser settings. Essential cookies required for website functionality cannot be disabled.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or for other operational, legal, or regulatory reasons. The updated policy will be posted on this page with a revised "Last Updated" date. We encourage you to review this policy periodically.

Contact Us

If you have questions about this Privacy Policy, your personal information, or wish to exercise your rights, please contact us:

Tombolo Research FZ LLC

Email: info@tomboloresearch.ai

Phone: +1(441)519-5756

If you are not satisfied with our response to your inquiry, you may contact the Privacy Commissioner for Bermuda.