Palmy AI Legal Documents

HoloAgent Terms of Service

Effective Date: April 21, 2025
Company: Palmy AI FZ LLC, Dubai, United Arab Emirates

Welcome to HoloAgent, a service operated by Palmy AI FZ LLC ("Palmy", "we", "our", or "us"). These Terms of Service ("Terms") form a legally binding agreement between you ("User", "you", or "your") and Palmy AI regarding your access to and use of the HoloAgent platform, its website (https://holoagent.ai/), and associated software, APIs, and services (collectively, the "Services").

By accessing or using the Services, you agree to be bound by these Terms and our Privacy Policy. If you do not agree, you must not access or use the Services.

1. Eligibility and Account Registration

You must be at least 18 years old or have the legal authority to enter into agreements on behalf of a company.
You agree to provide accurate, current, and complete information during account registration.
You are solely responsible for safeguarding your credentials. Any unauthorized use must be reported immediately.
We reserve the right to suspend or terminate any account suspected of abuse or breach of these Terms.

2. Description of Services

HoloAgent is an AI-powered assistant designed for organizations to automate customer engagement through advanced natural language interfaces. Core services may include:

Chat and voice assistant integration
Real-time AI-generated responses
Multi-channel deployment (web, WhatsApp, etc.)
Analytics and performance dashboards
Custom knowledge base training

3. User Responsibilities

You agree to:

Use the Services lawfully and in compliance with all applicable local, national, and international laws.
Not upload harmful code or use the Services to transmit spam, malware, or infringe on others’ rights.
Maintain responsibility for any content, queries, prompts, or datasets you upload or process through HoloAgent.
Ensure end users interacting with HoloAgent are aware of and accept applicable disclosures and limitations.

4. AI Services and Limitations

HoloAgent uses machine learning models that may produce inaccurate or unintended outputs.
The AI does not offer professional or legal advice. All content should be independently verified.
You accept all risks associated with relying on AI-generated content or suggestions.

5. Data Handling and Privacy

We process user data per our Privacy Policy and in line with our Data Processing Agreement (DPA).
While Palmy AI uses encryption and security best practices, no system is completely immune to vulnerabilities.
You are responsible for ensuring that your use of the Services complies with applicable privacy regulations (e.g., GDPR, DIFC Data Protection Law).

6. Payments and Subscription Terms

Certain features require a paid subscription. Fees are outlined on our pricing page and may be updated.
Payments are handled through secure third-party gateways. Palmy AI does not store payment details.
Failure to pay may result in service suspension or termination.

7. Cancellation, Refunds, and Downtime

You may cancel your subscription at any time. Refunds are not guaranteed and evaluated case-by-case.
We strive to maintain uptime but do not guarantee uninterrupted service.
Scheduled maintenance or unexpected outages may occur without prior notice.

8. Intellectual Property

All content, logos, software, and technologies used in HoloAgent are the intellectual property of Palmy AI or its licensors.
You may not copy, modify, sell, or distribute any part of the Services without written consent.

9. Confidentiality

Both parties agree to maintain confidentiality over proprietary information shared during the course of service usage.
This includes algorithms, training data, prompts, customer insights, or usage analytics.

10. Third-Party Services and Integrations

HoloAgent may integrate with third-party tools (e.g., messaging apps, CRMs). These tools are governed by their own terms.
Palmy AI is not responsible for the availability, accuracy, or data handling practices of third-party integrations.

11. Limitation of Liability

To the maximum extent allowed by law, Palmy AI is not liable for:

Indirect, incidental, or consequential damages
Any data loss or corruption
Errors or inaccuracies generated by the AI
Unauthorized access to your account
Delays or failures in performance beyond our control

Palmy’s total liability is limited to the subscription fees paid in the preceding 6 months.

12. Indemnification

You agree to indemnify and hold Palmy AI harmless against any losses, claims, or legal actions arising from:

Your misuse of the Services
Violation of these Terms
Infringement of third-party rights or laws

13. Termination

We may suspend or terminate your account immediately if:

You breach these Terms
You fail to pay applicable fees
You misuse the platform or jeopardize its integrity

Upon termination, your access will be revoked and any stored data may be deleted in accordance with our retention policy.

14. Changes to Terms

Palmy AI may modify these Terms at any time. We will notify you of material changes via email or in-app notification. Continued use of the Services after changes means you accept the updated Terms.

15. Governing Law

These Terms are governed by the laws of the United Arab Emirates, and any disputes shall be subject to the exclusive jurisdiction of the Dubai Courts.

16. Contact Us

Palmy AI FZ LLC
Dubai Internet City, Dubai, United Arab Emirates
Email: info@palmy.ai
Phone: +971 56 969 6674

Privacy Policy – Palmy AI (HoloAgent)

Version: 001
Last Updated: 21.08.2024

1. Introduction

This Privacy Policy outlines how Palmy AI FZ LLC ("Palmy AI", "we", "our", or "us") collects, processes, uses, discloses, and protects personal information through our product HoloAgent, an AI-enabled assistant platform designed to serve the event and retail industry. This policy applies to all interactions with HoloAgent through our website, mobile application, services, APIs, platform access, and communications (collectively, the "Services").

By using our Services, you acknowledge that you have read and understood this Privacy Policy and agree to its terms. For any privacy-related questions, reach out to: privacy@palmy.ai.

We may periodically update this Privacy Policy. Any revisions will be posted on this page along with the updated version date.

2. Palmy AI as a Data Processor

Palmy AI may process Personal Data on behalf of our business clients (data controllers), such as venue partners or event vendors, who use HoloAgent to serve their customers. In such cases, Palmy AI acts solely as a Data Processor, and data handling is governed by a Data Processing Agreement (DPA) with each customer. If you interact with HoloAgent through such a third party, please refer to their privacy policy for data practices specific to their organization.

3. How We Collect Personal Data

We collect personal information through three main sources:

a) Directly from you:

Account registration (e.g., name, email, phone)
Use of the HoloAgent platform or rentals
Customer service communications
Feedback, reviews, or surveys

b) Automatically via your interaction:

IP address, device IDs, browser types
Geolocation and session behavior
Usage logs and cookies

c) From third-party sources:

Payment providers (e.g., Stripe)
Analytics partners (e.g., Google, Meta)
Authentication via social login services

4. Why We Collect Personal Data & Legal Basis

Purpose	Data Collected	Legal Basis
Free Demo/Trial	Device info, voluntary data	Legitimate Interest
Account Management	Name, contact info, IP, credentials (hashed)	Contractual Obligation
Payment Processing	Payment token, email	Contractual Obligation
Service Enhancement	Pseudonymized user logs, usage data	Legitimate Interest
Abuse Monitoring	Session logs, fraud detection indicators	Legal Obligation & Legitimate Interest
Support Services	Contact data, issue logs	Contractual Obligation
Marketing	Name, email	Consent / Legitimate Interest
Recruitment	CVs, contact info	Pre-contractual Steps
Cookies	Session ID, analytics tags	Consent (see Section 8)

5. Data Retention

Data Type	Retention Period
User Account Data	12 months post-deletion
Marketing Emails	24 months or until opt-out
Payment Records	7 years (legal requirement)
User Content for R&D	Until no longer needed
Recruitment Data	6 months unless extended

6. Who We Share Data With

We do not sell personal information. However, we may share your Personal Data with:

Authorized Palmy AI staff and contractors
Cloud infrastructure and hosting providers (e.g., AWS, Google Cloud)
Payment processors: Stripe (GDPR compliant, USA-based)
Analytics & email platforms: Google Analytics, HubSpot, Meta, Mailchimp
AI/LLM model providers (pseudonymized): OpenAI, Azure, ElevenLabs
Legal/regulatory authorities as required by law

All third parties are subject to GDPR-compliant contracts, including data processing agreements and confidentiality clauses.

7. Your Rights

Depending on your jurisdiction, you may have the right to:

Request access to or a copy of your personal data
Rectify inaccuracies or request deletion
Withdraw consent where applicable
Restrict or object to specific processing activities
Receive your data in portable format (data portability)
File a complaint with your local data protection authority (e.g., UAE Data Office)

To exercise any of these rights, contact us at privacy@palmy.ai. We aim to respond within 30 days.

8. Cookies & Tracking

We use cookies and similar technologies for functionality, analytics, and advertising purposes.

Types of Cookies:

Essential: Required for secure login and navigation
Analytics: Usage tracking (e.g., Google Analytics)
Marketing: Measure ad and campaign performance

You can manage cookie preferences via your browser settings or through our in-app cookie banner.

9. Security Measures

Palmy AI applies strict security controls to protect personal data:

End-to-end SSL encryption
Role-based access control (RBAC) and 2FA for internal systems
Regular penetration testing and vulnerability scans
Use of pseudonymization and anonymization
Real-time incident detection systems
Secure cloud environments with zero-trust architecture

In the event of a data breach, affected users and relevant authorities will be notified within the legally mandated period.

10. Children’s Privacy

HoloAgent is not intended for children under 13 years of age. We do not knowingly collect Personal Data from minors. If you suspect your child has submitted personal data, please contact privacy@palmy.ai immediately.

11. International Data Transfers

Your data may be processed in jurisdictions outside your country, including countries that may not offer the same level of data protection. All such transfers are secured through:

Standard Contractual Clauses (SCCs)
Adequacy decisions by the EU or UK (where applicable)
Encrypted transport and storage

12. Limitation of Liability

While we follow industry best practices to safeguard your data, no digital platform is 100% secure. Palmy AI is not liable for unauthorized access or data loss resulting from causes beyond our reasonable control, including but not limited to force majeure events, third-party actions, or unavoidable technical issues.

13. Data Processing Agreement (DPA)

Palmy AI provides a Data Processing Agreement (DPA) to customers of HoloAgent. The DPA governs how personal data is processed on behalf of our customers in compliance with applicable data protection laws, including GDPR and UAE Federal Law No. 45 of 2021 on the Protection of Personal Data (PDPL).

14. Contact Us

Palmy AI FZ LLC
In5 Tech, Dubai Internet City, Dubai, United Arab Emirates
Email: info@palmy.ai
Phone: +971 56 969 6674

Data Processing Agreement (DPA)

Effective Date: 21.04.2025
Version: 1.0
Company: Palmy AI FZ LLC, Dubai, United Arab Emirates

This Data Processing Agreement ("Agreement") is part of the Terms of Service for the use of HoloAgent, a service offered by Palmy AI FZ LLC ("Palmy AI", “Processor”, “we”, “our”, or “us”) and is entered into with the entity or person who uses or signs up for HoloAgent ("Customer", "Controller", or "you").

This Agreement outlines the terms under which Palmy AI processes personal data on behalf of the Customer, in compliance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1. Definitions

Applicable Data Protection Law: Refers to all laws applicable to the processing of Personal Data under this Agreement.
Personal Data: Means information relating to an identified or identifiable individual.
Processing: Means any operation performed on Personal Data, such as collection, storage, use, or deletion.
Sub-processor: Means any third party appointed by Palmy AI to process Personal Data on behalf of the Customer.

2. Purpose and Scope

Palmy AI processes Personal Data exclusively to provide HoloAgent services, which include AI-powered customer support, analytics, and automated interaction features.

3. Palmy AI's Obligations (Processor)

Palmy AI commits to:

Process Personal Data only on documented instructions from the Customer.
Ensure all personnel who handle Personal Data maintain confidentiality.
Implement appropriate technical and organizational safeguards.
Assist the Customer in fulfilling data subject rights (e.g., access, erasure).
Promptly notify the Customer of any data breach.
Delete or return Personal Data at the end of service (unless legally required to retain it).
Make relevant records available to demonstrate compliance.

4. Customer’s Obligations (Controller)

The Customer is responsible for:

Ensuring lawful processing of Personal Data.
Providing adequate privacy notices and obtaining necessary consents.
Ensuring instructions given to Palmy AI comply with applicable laws.

5. Sub-processors

Palmy AI may use trusted Sub-processors to support service delivery. These Sub-processors are bound by data protection obligations consistent with this Agreement. A current list is available upon request.

6. International Data Transfers

Where Personal Data is transferred outside of the European Economic Area (EEA), Palmy AI ensures appropriate safeguards are in place (e.g., Standard Contractual Clauses or equivalent).

7. Security Measures

Palmy AI maintains industry-standard security measures, including:

Data encryption in transit and at rest
Access controls and authentication
Regular vulnerability assessments
Disaster recovery protocols

8. Data Breach Notification

In the event of a data breach, Palmy AI will:

Notify the Customer without undue delay
Provide details of the breach (type, scope, impact)
Cooperate with the Customer in regulatory reporting

9. Audit Rights

The Customer may, with reasonable notice, audit Palmy AI’s compliance with this Agreement. Audits may occur once per year, or more frequently if required by law.

10. Duration and Termination

This Agreement remains in effect while Palmy AI processes Personal Data on the Customer's behalf. Upon termination of service:

Palmy AI will, at the Customer’s option, return or delete all Personal Data.
Some data may be retained where required by applicable law.

11. Liability

Each party is responsible for its own compliance. Neither party is liable for indirect damages unless caused by gross negligence or willful misconduct.

12. Governing Law

This Agreement is governed by the laws of the United Arab Emirates. Any disputes will be resolved by the competent courts of Dubai.

Annex 1: Data Processing Details

Detail	Description
Subject Matter	Processing of Personal Data through the HoloAgent platform
Duration	For the duration of the service relationship
Nature and Purpose	AI-powered communications, support, and analytics
Personal Data Types	Name, contact info, chat data, usage data, IP address
Data Subjects	End-users, employees, customers of the Controller

Contact Information

Palmy AI FZ LLC
Dubai, United Arab Emirates
Email: info@palmy.ai
Phone: +971 56 969 6674