Privacy Policy

1. Our Commitment to Privacy

Pombo Labs ("we," "us," or "our") is comprised of two core initiatives: Pombo Research, our non-profit arm focused on open-source research and development in Natural Language Processing (NLP) to support and translate Sierra Leonean languages, and Pombo Studio, our for-profit arm that develops innovative software and AI solutions for clients, with revenue supporting the activities of Pombo Research.

We are committed to protecting the privacy and security of personal data. This Privacy Policy describes how we collect, use, store, share, and protect your personal data when you visit our website (pombolabs.com), interact with us, or use the services provided by Pombo Studio. It also outlines your rights in relation to your personal data.

Specific data handling protocols for research projects undertaken by Pombo Research, particularly concerning linguistic corpora and collaborations, may be detailed in separate notices, consent forms, or data usage agreements where applicable.

2. The Data We Collect About You

Personal data means any information about an individual from which that person can be identified. We may collect, use, store, and transfer different kinds of personal data about you, including:

• Identity Data: Includes first name, last name, username, or similar identifier.
• Contact Data: Includes email address, telephone numbers, and professional affiliations.
• Client Data: Information provided by or on behalf of clients of Pombo Studio necessary for the provision of our services.
• Technical Data: Includes internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website.
• Usage Data: Includes information about how you use our website, products, and services.
• Marketing and Communications Data: Includes your preferences in receiving marketing from us and your communication preferences.
• Research Contributor Data (for Pombo Research): If you contribute data, collaborate on research, or participate in studies, we may collect specific data as outlined in relevant project documentation and consent forms. This may include linguistic data contributions, contact information for collaboration, and professional information. We strive to use anonymized or de-identified data for research wherever possible.

3. How We Use Your Personal Data

We use your personal data only when the law allows us to and for specific purposes. These include:

• Providing Services (Pombo Studio): To perform contracts with our clients, manage projects, and deliver software and AI solutions.
• Conducting Research (Pombo Research): To conduct NLP research, develop language models and tools for Sierra Leonean languages, foster academic collaboration, and create open-source resources. Personal data used in research will be handled according to ethical guidelines and specific project protocols, prioritizing anonymization or de-identification.
• Website Operation: To administer and protect our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting, and hosting of data).
• Communication: To manage our relationship with you, including notifying you about changes to our terms or privacy policy, and responding to inquiries.
• Legitimate Interests: For our legitimate interests (or those of a third party) where your interests and fundamental rights do not override those interests (e.g., improving our services, research for societal benefit, preventing fraud).
• Legal Obligations: To comply with legal or regulatory obligations.
• Marketing: With your consent where required, to inform you about services or research updates we believe may interest you. You can opt-out of marketing communications at any time.

4. Data Sharing and Disclosure

We do not sell your personal data. We may share your personal data with:

• Service Providers: Third parties who provide IT, system administration, hosting, and other services on our behalf, under strict data processing agreements.
• Pombo Research Collaborators & Interns: For Pombo Research activities, data (often anonymized or de-identified, or with explicit consent) may be shared with academic collaborators or interns working on specific research projects, under confidentiality obligations.
• Open-Source Community (Pombo Research): Pombo Research is committed to open science. We may publish or share anonymized, aggregated, or specifically licensed datasets and research findings with the broader community to advance NLP for Sierra Leonean languages. We will ensure personal identifiable information is not released in such contexts without appropriate safeguards or consent.
• Pombo Studio Clients: Data relevant to a client project may be shared with that client as part of service delivery, governed by our client agreements.
• Professional Advisors: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services.
• Legal Authorities: If required by law, regulation, or legal process.

5. Data Security

We have implemented appropriate technical and organizational security measures to prevent your personal data from being accidentally lost, used, accessed in an unauthorized way, altered, or disclosed. We limit access to your personal data to those employees, agents, contractors, interns (where applicable to their project), and other third parties who have a legitimate business or research need to know and are subject to a duty of confidentiality.

We have procedures to deal with any suspected personal data breach and will notify you and any applicable regulator where we are legally required to do so.

6. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including satisfying any legal, regulatory, tax, accounting, or reporting requirements.

For research data managed by Pombo Research, retention periods may be longer, as this data can be essential for ongoing model improvement, longitudinal linguistic studies, reproducibility of research, and the continued availability of open-source resources. Such data will be managed in accordance with ethical research practices and any specific consent provided.

7. International Data Transfers

Pombo Labs operates globally, which may involve transferring your personal data outside your country of residence, including to Sierra Leone or to other countries where our service providers or collaborators are based.

Where we transfer your personal data internationally, we will ensure that appropriate safeguards are in place to protect your data in accordance with applicable data protection laws. This may include relying on adequacy decisions, using Standard Contractual Clauses, or other legally recognized transfer mechanisms.

8. Your Legal Rights

Under certain data protection laws, you may have rights in relation to your personal data, including the right to:

• Request access to your personal data.
• Request correction of inaccurate personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Withdraw consent at any time where we rely on consent to process your personal data.

If you wish to exercise any of these rights, please contact us at privacy@pombolabs.com.

9. Cookies and Tracking Technologies

Our website may use cookies and similar tracking technologies to enhance your Browse experience, analyze website traffic, and for functionality purposes. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on our website and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.