Privacy Policy

Last Updated: July 30, 2026

1. Introduction

Palco Labs FZE LLC, doing business as Komie ("Komie," "we," "us," or "our"), operates a marketing operations platform that includes opt-in forms, hosted pages, booking and scheduling tools, lead qualification and scoring, routing, analytics, customer relationship management features, workflow tools, and related integrations (collectively, the "Services").

This Privacy Policy explains how we collect, use, disclose, and protect personal information when:

• you visit or interact with Komie's websites;
• you create, access, or administer a Komie account;
• you communicate with Komie;
• you use the Services as a Komie customer or authorized user; or
• you interact with a form, booking page, hosted page, widget, or other interface created or configured by a Komie customer.

For purposes of this Privacy Policy:

• "Customer" means a business or organization that uses the Services.
• "Account User" means an owner, administrator, team member, billing contact, or other authorized user of a Customer account.
• "Form Responder" means a person who interacts with or submits information through a Customer-created form, booking page, hosted page, widget, or similar interface.
• "Customer Data" means personal information submitted to, stored in, generated through, or processed using the Services on behalf of a Customer.
• "Komie-Controlled Data" means personal information that Komie processes for its own business purposes, such as account administration, billing, support, website operation, security, and compliance.

Komie is established in the United Arab Emirates (the "UAE" or "UAE"). This Privacy Policy is intended to provide transparency under applicable privacy and data protection laws, including applicable United States state privacy laws and the UAE's applicable data protection framework.

By using our Services, you agree to resolve privacy disputes through binding arbitration and waive your right to a jury trial or to participate in a class action lawsuit.

2. Our Role

2.1 Komie as a Controller

Komie determines the purposes and means of processing for Komie-Controlled Data. This includes information used to:

• create and administer accounts;
• authenticate Account Users;
• manage subscriptions and billing;
• provide customer support;
• operate, secure, and improve the Services;
• prevent fraud, misuse, and unauthorized access;
• manage preferences and communications; and
• comply with legal and contractual obligations.

2.2 Komie as a Service Provider or Processor

When Komie processes Customer Data through Customer-configured forms, booking pages, hosted pages, routing rules, lead-scoring workflows, analytics, CRM features, integrations, or related tools, Komie generally acts on behalf of the Customer.

The Customer determines why Customer Data is collected, which fields are presented, how the data is used, which communications are sent, which connected services are enabled, and how long the data is retained, subject to the Customer's agreement with Komie and applicable law.

Customers are responsible for:

• providing any legally required privacy notices to Form Responders;
• establishing an appropriate lawful basis for collecting and using Customer Data;
• obtaining any required consent for marketing, email, SMS, calls, recordings, or other communications;
• configuring their own consent checkboxes, disclosures, and preference mechanisms;
• ensuring that their use of connected services complies with applicable law; and
• responding to privacy requests relating to Customer Data.

Komie may provide platform legal links or "Powered by Komie" branding on Customer-facing pages. Those links do not replace the Customer's own privacy notice or change the Customer's responsibility for its collection and use of Customer Data.

3. Personal Information We Collect

The personal information we collect depends on how you interact with Komie and how a Customer configures the Services.

3.1 Account and Contact Information

We may collect:

• name;
• email address;
• phone number;
• company name;
• job title;
• mailing or billing address;
• Account User roles and permissions;
• account preferences; and
• communications with Komie.

3.2 Authentication and Security Information

We may collect:

• login timestamps;
• session identifiers;
• password hashes or authentication tokens;
• IP addresses;
• browser and device information;
• audit logs;
• security events;
• fraud and abuse signals; and
• records used to investigate unauthorized activity.

3.3 Billing and Subscription Information

We may collect:

• billing contact details;
• subscription plan information;
• invoice and transaction metadata;
• payment status; and
• limited payment-method information provided by our payment processors.

Komie does not need to store complete payment-card details when payment information is processed directly by a payment provider.

3.4 Usage and Technical Information

We may automatically collect:

• pages and features used;
• clicks and interactions;
• referral and exit pages;
• timestamps;
• browser type;
• device type;
• operating system;
• language and regional settings;
• IP address;
• approximate location derived from IP address;
• diagnostic information;
• performance metrics; and
• error logs.

3.5 Customer Data and Form Responses

Depending on the Customer's configuration, Customer Data may include:

• names;
• email addresses;
• phone numbers;
• company and employment information;
• form answers;
• custom-field responses;
• booking and appointment information;
• lead source and attribution data;
• qualification and lead-scoring information;
• routing and assignment data;
• CRM records;
• notes and workflow history;
• communication metadata;
• consent status and timestamps;
• uploaded files or content; and
• information received from Customer-authorized integrations.

3.6 Partially Completed Forms

Where enabled through the Services, Komie may capture limited information entered into a Customer-created form, booking page, hosted page, or widget before the full form is submitted. For example, information may be recorded after a Form Responder finishes interacting with a field or leaves the field.

This information is processed as Customer Data on behalf of the Customer. The Customer is responsible for providing any notice or lawful basis required for this collection.

4. How We Collect Personal Information

We collect personal information:

4.1 Directly From You

This includes information you provide when you:

• create or manage an account;
• use the Services;
• submit or interact with a form or booking page;
• contact sales or support;
• request information;
• subscribe to communications; or
• otherwise communicate with Komie.

4.2 Automatically

We may collect information automatically through:

• cookies;
• local storage;
• pixels;
• tags;
• scripts;
• logs;
• software development kits; and
• similar technologies.

4.3 From Customers and Connected Services

We may receive information from Customers, Customer-authorized integrations, payment providers, analytics providers, security providers, infrastructure providers, and other service providers used to operate the Services.

5. How We Use Personal Information

5.1 Komie-Controlled Data

We may use Komie-Controlled Data to:

• provide, maintain, and operate the Services;
• create, authenticate, and administer accounts;
• manage subscriptions, payments, and billing;
• respond to support and sales inquiries;
• communicate service, security, billing, and administrative information;
• improve performance, functionality, and user experience;
• develop and test features;
• monitor availability and diagnose technical issues;
• prevent fraud, abuse, spam, and unauthorized access;
• enforce our agreements and policies;
• maintain records and audit trails;
• comply with applicable law and lawful requests;
• resolve disputes and establish, exercise, or defend legal claims; and
• send marketing communications where permitted by law.

5.2 Customer Data

Komie processes Customer Data to provide the Services configured and requested by the Customer. This may include:

• hosting forms, pages, and widgets;
• collecting and organizing responses;
• providing booking and scheduling functionality;
• calculating Customer-configured qualification or scoring results;
• routing and assigning leads;
• maintaining CRM and workflow records;
• providing analytics and reporting;
• enabling Customer-authorized integrations; and
• supporting, securing, and troubleshooting the Customer's use of the Services.

Komie does not sell Customer Data. Komie does not use Customer Data for its own cross-context behavioral advertising.

6. Connected Services and Customer Communications

Customers may connect third-party services to Komie. When a Customer enables an integration, Komie may exchange Customer Data with that service as necessary to provide the requested functionality.

Komie does not independently determine the recipients, content, timing, or legal basis of communications sent by Customers through their own connected providers. Customers are responsible for their email, SMS, calling, marketing, and other communications, including consent, opt-out, and recordkeeping obligations.

Third-party services are governed by their own terms and privacy policies. Komie is not responsible for the independent privacy practices of those services.

7. How We Disclose Personal Information

We may disclose personal information to:

7.1 Service Providers

We may use service providers for:

• cloud hosting and infrastructure;
• database and storage services;
• payment processing;
• analytics and performance monitoring;
• error detection;
• security and fraud prevention;
• customer support;
• email and operational communications;
• identity and account authentication; and
• professional legal, accounting, audit, or compliance services.

These providers may process personal information only for the purposes of providing services to Komie and subject to applicable contractual restrictions.

7.2 Customer-Authorized Services

We may disclose Customer Data to integrations, applications, or services selected or authorized by the Customer.

7.3 Legal and Safety Requirements

We may disclose information where reasonably necessary to:

• comply with applicable law, regulation, subpoena, court order, or lawful government request;
• protect the rights, property, or safety of Komie, our Customers, Form Responders, or others;
• investigate fraud, abuse, security incidents, or violations of our agreements; or
• establish, exercise, or defend legal claims.

7.4 Corporate Transactions

Personal information may be transferred in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar corporate transaction, subject to appropriate confidentiality and data-protection obligations.

7.5 With Your Direction or Consent

We may disclose information for another purpose when you or the applicable Customer directs us to do so or provides valid consent.

8. Cookies and Tracking Technologies

Komie uses cookies and similar technologies to:

• provide essential site and account functionality;
• authenticate users and maintain sessions;
• remember preferences;
• protect the Services;
• measure traffic and usage;
• diagnose errors; and
• improve performance.

You may control cookies through your browser or device settings. Blocking certain cookies may affect the functionality of the Services.

Customers may add or enable their own analytics, attribution, advertising, or tracking technologies on Customer-controlled pages. Those technologies are controlled by the Customer. The Customer is responsible for providing appropriate notice, obtaining any required consent, and responding to related privacy requests.

Some browsers provide a Do Not Track signal. Because there is no universally adopted standard for responding to Do Not Track signals, the Services may not respond to them. Where applicable law requires recognition of a legally valid opt-out preference signal, Komie will process the signal as required for covered Komie-controlled processing.

9. Data Retention

Komie retains Komie-Controlled Data only for as long as reasonably necessary to:

• provide and operate the Services;
• administer accounts and subscriptions;
• maintain security and prevent fraud;
• comply with legal, tax, accounting, and regulatory obligations;
• maintain consent, preference, and compliance records;
• resolve disputes;
• enforce agreements; and
• establish, exercise, or defend legal claims.

Customer Data is retained according to the Customer's account settings, instructions, contractual arrangements, and applicable legal requirements. Komie may retain limited backups or records for a reasonable period after deletion where necessary for security, legal compliance, dispute resolution, or system integrity.

Deletion requests are subject to applicable legal and operational exceptions.

10. International Data Transfers

Komie is a UAE company and may use service providers located in different countries. Personal information may therefore be transferred to, stored in, or accessed from countries outside the country where you are located.

Those countries may have different data-protection laws. Where required by applicable law, Komie uses contractual, organizational, or technical safeguards designed to protect personal information during international transfers.

11. Information Security

Komie uses administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, misuse, alteration, and disclosure.

These safeguards may include:

• access controls;
• authentication controls;
• encryption where appropriate;
• logging and monitoring;
• secure development practices;
• vendor-risk controls; and
• incident-response procedures.

No system or method of transmission is completely secure. Komie cannot guarantee absolute security.

12. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

• request access to personal information;
• request correction of inaccurate information;
• request deletion of personal information;
• request a portable copy of certain information;
• object to or restrict certain processing;
• withdraw consent where processing is based on consent;
• opt out of certain sales, sharing, targeted advertising, or profiling;
• appeal a refusal to act on a request where applicable; and
• exercise your rights without unlawful discrimination.

These rights may be subject to verification, exceptions, and limitations under applicable law.

12.1 Requests Concerning Komie-Controlled Data

To exercise rights relating to Komie-Controlled Data, contact us at support@komie.io.

We may request information reasonably necessary to verify your identity and authority to make the request. An authorized agent may submit a request where permitted by law, subject to verification of the agent's authority.

12.2 Requests Concerning Customer Data

If you are a Form Responder, lead, contact, or other person whose information was collected through a Customer-created form, booking page, hosted page, widget, or workflow, direct your request to the relevant Customer.

The Customer controls that data and determines how it is used. Komie will assist the Customer with valid requests as required by applicable law and the Customer's agreement with Komie.

13. California Residents

Under the California Consumer Privacy Act (CCPA), California residents have additional rights. We do not sell personal information. For more details about categories of information collected and purposes, contact privacy@komie.io.

This section applies only to the extent the California Consumer Privacy Act, as amended by the California Privacy Rights Act ("CCPA"), applies to Komie's processing.

During the preceding 12 months, Komie may have collected the categories of personal information described in Section 3 from the sources described in Section 4 and used or disclosed them for the purposes described in Sections 5 and 7.

California residents may have the right to:

• know the categories and specific pieces of personal information collected;
• know the categories of sources, purposes, and third parties involved;
• correct inaccurate personal information;
• delete personal information, subject to exceptions;
• obtain a portable copy of certain personal information;
• opt out of the sale or sharing of personal information;
• limit certain uses or disclosures of sensitive personal information; and
• exercise rights without discrimination.

Komie does not sell Customer Data. To the extent a disclosure of Komie-Controlled Data through website analytics, advertising, or measurement technologies is legally considered a "sale" or "sharing," California residents may submit an opt-out request by contacting support@komie.io or through any preference mechanism made available on the Services.

Komie does not knowingly sell or share the personal information of individuals under 16 years of age.

Where Komie processes personal information solely on behalf of a Customer, Komie acts as a service provider or processor and the request should be directed to that Customer.

14. European Union Residents

Under the General Data Protection Regulation (GDPR), EU residents have enhanced rights. Our legal basis for processing includes consent (for marketing communications), legitimate interests (for analytics, attribution, and fraud prevention), and contract fulfillment (for Customer services). You may lodge a complaint with your local supervisory authority if you believe your rights have been violated.

15. Marketing Communications

You may unsubscribe from optional Komie marketing emails by using the unsubscribe link in the message or contacting us.

You may continue to receive non-marketing communications that are necessary to operate the Services, including account, billing, security, support, and legal notices.

Communications sent by Customers through their own connected providers are controlled by the Customer. Opt-out requests concerning those communications should be directed to the applicable Customer.

16. Children's Privacy

The Services are not directed to children under 16, and Komie does not knowingly collect personal information from children under 16 for its own purposes.

If a Customer uses the Services to collect information relating to a minor, the Customer is responsible for complying with applicable children's privacy laws and obtaining any required parental or guardian consent.

If you believe Komie has collected personal information from a child in violation of this section, contact us at support@komie.io.

17. Third-Party Websites

The Services may contain links to third-party websites or services. Komie does not control and is not responsible for their content, security, or privacy practices. Review the privacy policy of any third-party service before providing information to it.

18. Changes to This Privacy Policy

We may update this Privacy Policy to reflect changes in our Services, technology, legal requirements, or data practices.

We will post the updated version with a revised "Last Updated" date. Where required by applicable law, we may provide additional notice of material changes.

19. Contact Us

Questions, privacy requests, and complaints may be submitted using the following contact information:

Email: support@komie.io

Website: komie.io

Mail: