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Privacy Policy

Last updated: 13 May 2026

This Privacy Policy explains how Upskillist AI Limited, trading as Ambition AI, collects, uses, shares and protects personal data across all our services, including Kairo (our AI-powered mentor and progress platform), ambition.world (our company website), kairo.ai (our product website), and any future products or services operated by Ambition AI.
Please read this Privacy Policy carefully. It should be read together with our Terms of Service and Cookie Policy.

1. Introduction

This Privacy Policy applies to personal data we collect and process through:
In this Privacy Policy:

2. Who We Are / Data Controller

For the purposes of data protection laws, the controller of your personal data is:
Upskillist AI Limited, trading as Ambition AI
26/27 Pembroke Street Upper
Dublin 2
D02 X361
Ireland
Registered company number: 803098
General support: support@ambition.world
Data protection requests: privacy@ambition.world
As controller, we decide why and how personal data is collected and used in connection with Kairo and Ambition.
You can contact us at privacy@ambition.world if you have questions about this Privacy Policy, your personal data, your privacy rights or how Kairo uses your information.

3. Scope of This Privacy Policy

This Privacy Policy explains how we process personal data when you:
This Privacy Policy does not apply to third-party websites, platforms, payment providers, app stores, social media platforms, external content providers or services that we do not control.
For example, if you interact with Paddle, Apple, Google, Meta, TikTok, YouTube, Spotify, external websites, external content, third-party tools or other platforms, their own privacy policies and terms may apply.
We are not responsible for the privacy practices of third-party services. You should review their privacy policies before using them.

4. Summary: How Kairo Uses Data

Kairo is personalised by design.
To provide Kairo, we need to process information about you, your goals, your preferences, your activity and your use of the service.
This may include information such as:
We use this information to:
Some personalisation is essential to Kairo. If you do not want us to process the information needed to personalise and operate Kairo, you should not use Kairo’s personalised or AI-powered features.
We do not sell your Kairo conversations or personal goal data. We do not use your private Kairo conversations for third-party advertising targeting.

5. Personal Data We Collect

We collect personal data in different ways depending on how you use Kairo, Ambition, our websites, apps and services.

5.1 Information You Provide Directly

We may collect information that you provide directly to us, including:

5.2 Kairo AI Interaction Data

When you use Kairo’s AI-powered features, we may collect and process information relating to your interactions with Kairo.
This may include:
We use this information to provide Kairo’s AI-powered features, maintain continuity, personalise your experience, support your progress, improve safety and reliability, and provide support where needed.

5.3 Personalisation and Progress Data

Kairo is designed to personalise your experience based on your goals, activity and progress.
We may collect and process data such as:
We may use this information to create and maintain a personalised profile of your goals, skills, preferences, milestones, progress and activity so that Kairo can provide more relevant guidance, recommendations, reminders and content.

5.4 Account and Subscription Data

If you create an account, start a trial, purchase a subscription, use a partner offer or manage billing, we may collect and process account and subscription data, including:
Payments may be processed by Paddle, app stores or other payment providers. We do not store your full card number where payment is processed by those providers.

5.5 Payment and Billing Information

Where you purchase a subscription, trial, promotion or paid access, payment information may be collected and processed by Paddle, an app store or another payment provider.
Depending on the provider and transaction, we may receive limited billing-related information such as:
Your full card details are handled by the relevant payment provider, not by us.

5.6 Device, App and Technical Data

When you use Kairo, Ambition, our websites, apps or communications, we may collect technical information such as:
We use this information to operate, secure, maintain, troubleshoot, analyse and improve Kairo.

5.7 Cookies, Pixels and Tracking Data

We may collect information through cookies and similar technologies, including:
Our use of cookies and similar technologies is explained in our Cookie Policy.
Where required by law, we will ask for your consent before using non-essential cookies, advertising pixels or tracking technologies.

5.8 Communications Data

When we communicate with you, we may collect and process information such as:
We use this information to provide service messages, account notices, billing updates, product communications, onboarding support, progress reminders, marketing where permitted and customer support.

5.9 Information From Partners or Third Parties

We may receive limited information from partners or third parties where you interact with Kairo through a partner, app store, payment provider, affiliate, promotion, referral campaign, advertising campaign or third-party platform.
This may include:
We use this information to provide access, validate offers, measure campaign performance, prevent fraud, manage subscriptions and improve our services.

6. Sensitive Personal Data

Kairo is not designed to collect or process sensitive personal data unless a specific feature clearly asks for it and explains why it is needed.
You should not submit sensitive personal data to Kairo unless you are comfortable doing so and it is necessary for your use of the service.
Sensitive personal data may include, for example:
Kairo is not a medical, therapeutic, financial, legal, tax, investment, employment, immigration or emergency support service. You should not rely on Kairo for situations that require qualified professional help or urgent support.
If you submit sensitive personal data voluntarily, we may process it as necessary to provide, secure and operate Kairo, subject to this Privacy Policy and applicable law. We may also delete, restrict or refuse to process sensitive information where we believe it is not needed, creates risk or is inappropriate for the service.
We do not use sensitive personal data for training, content generation or product improvement purposes, even where it is voluntarily submitted. Where we identify sensitive personal data in Kairo interactions, we may restrict, redact or delete it from datasets used for these purposes.

7. How We Use Personal Data

We use personal data to provide, operate, personalise, secure, improve and market Kairo and Ambition, and to comply with our legal obligations.

7.1 To Provide Kairo

We use personal data to provide the core Kairo service, including to:

7.2 To Personalise Kairo

Kairo is personalised by design.
We use personal data to personalise your experience, including to:
This personalisation is a core part of Kairo. Without it, Kairo cannot provide its main AI-powered and progress-support features.

7.3 To Power AI Features

We use personal data to operate Kairo’s AI-powered features, including to:
Kairo is an AI-powered system. When you interact with Kairo, you are interacting with automated AI technology, not a human advisor.

7.4 To Communicate With You

We use personal data to send communications related to your account and use of Kairo, including:
Some communications are necessary to provide Kairo and manage your account. We may also send marketing communications where permitted by law.

7.5 To Process Payments and Subscriptions

We use personal data to manage trials, subscriptions and payments, including to:
Payments may be processed by Paddle, app stores or other payment providers. We receive limited payment and subscription information from those providers so we can manage your access to Kairo.

7.6 To Improve Kairo and Ambition

We use personal data to understand and improve our products, services and communications, including to:
Where possible, we use aggregated, anonymised or de-identified information for analysis and reporting.

7.7 To Market Kairo and Ambition

We may use personal data to market Kairo and Ambition where permitted by law, including to:
We do not sell your Kairo conversations or personal goal data. We do not use your private Kairo conversations for third-party advertising targeting.
Where required by law, we will ask for your consent before using advertising pixels, non-essential tracking technologies or certain marketing communications.

7.8 To Keep Kairo Safe and Secure

We use personal data to protect Kairo, Ambition, users and third parties, including to:

7.9 To Comply With Law and Protect Rights

We may use personal data where necessary to:

7.10 To Train and Improve Kairo

Kairo is designed to learn from how people use the platform so that we can improve the service, develop new content and refine personalisation for all users.
We may use personal data, including your interactions with Kairo, your goals, preferences, progress and Ambition Graph data, to:
Where we use personal data for these purposes, we use aggregated, de-identified or pseudonymised data wherever possible.
We do not provide your private Kairo conversations or personal goal data to third-party AI providers to train their own general-purpose AI models. We do not sell your personal data.
We do not use sensitive personal data, such as health, mental health, racial or ethnic, religious or other special category information, for training or content generation purposes, even where users voluntarily include this information in their Kairo interactions.
Where we rely on legitimate interests to train and improve Kairo, you have the right to object to this processing. You can do so by contacting us at privacy@ambition.world.

8. Legal Bases for Processing

Where GDPR, UK GDPR or similar data protection laws apply, we must have a legal basis for processing your personal data.
The legal bases we rely on may include:
The table below explains the main purposes and legal bases we may rely on.
PurposeLegal basis
Creating and managing your accountContract
Providing access to KairoContract
Providing Kairo AI featuresContract
Personalising Kairo based on your goals, progress and activityContract
Maintaining your personalised profile and progress continuityContract
Providing free, preview, trial or paid accessContract
Processing subscriptions, renewals, cancellations and billing accessContract; legal obligation
Managing payment status and fraud preventionContract; legitimate interests; legal obligation
Customer support and billing supportContract; legitimate interests
Sending service, account, billing, security and legal noticesContract; legal obligation; legitimate interests
Sending progress reminders, onboarding messages and product communications related to your use of KairoContract; legitimate interests
Sending marketing emails or promotional messagesConsent or legitimate interests, depending on your location and the nature of the communication
Using cookies and similar technologies that are strictly necessaryContract; legitimate interests
Using non-essential analytics cookies, advertising pixels or tracking technologiesConsent, where required by law
Product analytics and service improvementLegitimate interests or consent, depending on the technology used and applicable law
AI safety, reliability testing and misuse detectionLegitimate interests; contract
Security monitoring, fraud prevention and abuse detectionLegitimate interests; legal obligation
Legal, tax, accounting and regulatory complianceLegal obligation
Managing disputes, complaints or legal claimsLegitimate interests; legal claims
Business transfers, corporate restructuring, financing, recapitalisation, merger or acquisition activityLegitimate interests; legal obligation where applicable
Training and improving Kairo's algorithms, content and personalisation systemsLegitimate interests
Developing new content (including AI-generated content) based on user-stated needsLegitimate interests
Some personalisation is essential to Kairo. If you use Kairo’s personalised or AI-powered features, we process the information needed to provide those features as part of our contract with you.
Where we rely on consent, you may withdraw your consent at any time. Withdrawing consent does not affect processing that occurred before consent was withdrawn. It may also mean that certain features, communications or tracking technologies no longer work or are no longer available to you.

9. AI, Profiling and Automated Processing

Kairo is an AI-powered service. We use artificial intelligence, automation and personalisation technologies to provide Kairo’s core features.

9.1 How Kairo Uses AI

Kairo may use AI to:
When you interact with Kairo, you are interacting with an automated AI-powered system, not a human advisor.

9.2 Personalised Profile and Progress Support

Kairo may create and maintain a personalised profile based on information such as:
We use this personalised profile to make Kairo more relevant to you, including by adapting guidance, recommendations, reminders, content and progress support.

9.3 Inferences and Recommendations

Kairo may infer certain information from your activity and interactions, such as:
These inferences are used to personalise Kairo and support your progress. They are not intended to make legally binding or similarly significant decisions about you.

9.4 No Professional Advice or Guaranteed Accuracy

AI-generated outputs may be incomplete, inaccurate, outdated, misunderstood or unsuitable for your circumstances.
Kairo does not provide legal, financial, tax, medical, psychological, therapeutic, investment, employment, immigration, safety-critical or other professional advice.
You are responsible for reviewing and evaluating any AI-generated output before relying on it. You should seek qualified professional advice where appropriate.

9.5 Automated Decisions

Kairo may use automation to personalise features, content, reminders, recommendations, access levels, fraud prevention, security checks and product experiences.
However, we do not use Kairo to make decisions that have legal or similarly significant effects on you solely by automated means, such as decisions about employment, credit, housing, insurance, healthcare, legal rights or access to essential services.
If this changes in the future, we will update this Privacy Policy and provide any notices or rights required by law.

9.6 AI Providers and Safeguards

We may use third-party AI, automation, infrastructure, hosting and technology providers to help operate Kairo and generate AI-powered outputs.
These providers may process personal data only as needed to provide services to us, operate Kairo, generate outputs, support reliability, maintain security, improve safety or comply with legal obligations.
Where required, we use contractual safeguards with service providers that process personal data on our behalf.
We do not sell your Kairo conversations or personal goal data. We do not use your private Kairo conversations for third-party advertising targeting.

10. How We Share Personal Data

We may share personal data with trusted service providers, partners and other parties where necessary to provide, operate, secure, improve and market Kairo and Ambition, or where required by law.
We do not sell personal data in the traditional sense. However, some advertising or measurement technologies may be considered “sharing”, “targeted advertising” or similar concepts under certain privacy laws. Where required, we will provide consent or opt-out controls.
We do not share your private Kairo conversations with advertising platforms for third-party advertising targeting.

10.1 Service Providers and Partners We Use

We may share personal data with service providers and partners who help us operate our services, including providers of:
These providers may process personal data only as needed to provide their services to us and must protect it in accordance with applicable law and contractual obligations.

10.2 Payment Providers and App Stores

If you start a trial, purchase a subscription or manage billing, your payment and billing information may be processed by Paddle, app stores or other payment providers.
These providers may process information such as:
We receive limited billing and subscription information from payment providers so that we can manage your access to Kairo.
Payment providers and app stores may process your data under their own terms and privacy policies. We do not control all aspects of how they process payment data.

10.3 AI, Automation and Infrastructure Providers

Kairo's AI features are powered by trusted third-party AI infrastructure and platform providers. These providers process your Kairo interactions to generate AI responses, maintain conversation continuity and deliver the personalised features of Kairo.
Our AI infrastructure providers are contractually committed not to use your Kairo conversations to train, develop or improve their own general-purpose AI models. AI inference may be delivered through underlying large language model providers on a per-request basis, subject to the same contractual restrictions.
We may share personal data with AI, automation, hosting, infrastructure and technology providers that help us:
These providers may process Kairo interaction data and related account, technical or usage data only as needed to provide their services to us, under data processing agreements and confidentiality obligations.
A current list of our sub-processors is available on request by contacting privacy@ambition.world.

10.4 Analytics, Product and Communication Providers

We may share personal data with providers that help us understand product usage, improve Kairo and communicate with users.
This may include data relating to:
Where possible, we use aggregated, anonymised or de-identified data for reporting and analysis.

10.5 Advertising and Measurement Partners

We may work with advertising and measurement partners to understand the effectiveness of our marketing and, where permitted, to show or measure relevant advertising.
This may include platforms such as social media, search, advertising networks or analytics providers.
Advertising and measurement data may include:
Where required by law, we will ask for your consent before using advertising pixels, targeted advertising technologies or similar tracking tools.
We do not share your private Kairo conversations or personal goal data with advertising platforms for third-party advertising targeting.

10.6 Legal, Safety and Compliance Disclosures

We may disclose personal data if we believe it is necessary to:

10.7 Business Transfers

We may share or transfer personal data as part of an actual or potential business transaction, including:
If such a transaction occurs, personal data may be transferred to the relevant buyer, investor, successor, adviser or other party involved, subject to appropriate safeguards where required by law.

11. International Transfers

Kairo and Ambition are operated from Ireland, but we may use service providers, technology providers, infrastructure providers, AI providers, payment providers, communication providers, analytics providers and other partners located in other countries.
This means your personal data may be processed, stored or accessed outside Ireland, the European Economic Area, the United Kingdom or your country of residence.
Where personal data is transferred internationally, we take steps designed to protect it in accordance with applicable data protection laws.
These steps may include:
Some countries may not provide the same level of data protection as your country of residence. Where required by law, we use appropriate safeguards to protect your personal data when it is transferred internationally.
You can contact us at privacy@ambition.world if you would like more information about international transfers and the safeguards we use.

12. Cookies and Similar Technologies

We use cookies and similar technologies to operate, secure, personalise, analyse and improve Kairo and Ambition.
Cookies and similar technologies may include:
We may use these technologies to:
Where required by law, we will ask for your consent before using non-essential cookies, advertising pixels or similar tracking technologies.
Some browsers or devices may send “Do Not Track” or similar signals. Because there is no single accepted standard for these signals, our response may vary depending on the signal, browser, device and legal requirement. Where required by applicable law, we will honour recognised opt-out preference signals, such as Global Privacy Control, for applicable advertising or tracking choices.
You can find more information in our Cookie Policy.
Once our cookie management tool is live, you will be able to manage your cookie preferences through the cookie banner or “Manage Cookie Preferences” link on our website.
You can also control cookies through your browser settings and app permissions through your device settings.

13. Marketing Communications and Preferences

We may send you service-related, account-related and transactional communications about Kairo.
These may include:
Some communications are necessary to provide Kairo, manage your account, operate your subscription, protect security or comply with legal obligations. You may not be able to opt out of these while you have an active account, trial or subscription.
We may also send marketing communications where permitted by law. These may include:
You can opt out of marketing emails by using the unsubscribe link in the email or following the instructions provided in the communication.
If we use push notifications, SMS, WhatsApp, in-app messages or other communication channels, we may ask for your permission where required. You can manage certain communication preferences through your device settings, account settings, unsubscribe links or other preference tools we make available.
Opting out of marketing communications does not stop transactional, account, billing, security, service or legal communications.
We do not share mobile opt-in information or SMS consent data with third parties for their own marketing purposes.

14. Data Retention

We keep personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.
The period for which we keep personal data may depend on:
In general, we keep personal data for the following periods:
If you request deletion of your personal data, we will handle the request in accordance with applicable law. We may retain certain information where necessary for legal, tax, accounting, security, fraud prevention, dispute resolution, regulatory, legitimate business or compliance purposes.
Data stored in backups may take additional time to delete or isolate, but we will not use backup data for active operational purposes unless restoration is necessary.

15. Security

We take reasonable technical and organisational measures designed to protect personal data from unauthorised access, loss, misuse, alteration, disclosure or destruction.
These measures may include:
However, no website, app, database, AI system, transmission method or storage system is completely secure. We cannot guarantee absolute security.
You are responsible for keeping your account login details secure. You should not share your password or account access with anyone else. If you believe your account has been accessed without permission, contact us immediately at support@ambition.world.

16. Your Privacy Rights

Depending on where you live, you may have rights under data protection laws in relation to your personal data.
These rights may include the right to:
If you want to exercise your rights, you can contact us at privacy@ambition.world.
We may need to verify your identity before responding to a request. We may also ask for additional information to help us understand and process your request.
Some rights are subject to limits. For example, we may need to keep certain data for legal, tax, accounting, security, fraud prevention, dispute resolution, regulatory or legitimate business reasons.
If you are based in the European Union or European Economic Area, you may have the right to complain to your local data protection authority. As we are based in Ireland, you may also contact the Irish Data Protection Commission.
If you are based in the United Kingdom, you may have the right to complain to the UK Information Commissioner’s Office.
We encourage you to contact us first at privacy@ambition.world so we can try to resolve your request.

17. California and US State Privacy Rights

If you are a resident of California or another US state with applicable privacy laws, you may have additional rights in relation to your personal information.
Depending on your location and the law that applies, these rights may include the right to:
We do not sell your Kairo conversations or personal goal data.
We do not use your private Kairo conversations for third-party advertising targeting.
Some advertising or measurement technologies, such as pixels or cookies, may be considered “sharing”, “targeted advertising” or similar concepts under certain US state privacy laws. Where applicable, you may be able to opt out through our cookie or privacy preference tools once available, through browser or device controls, or by contacting us at privacy@ambition.world.
To make a privacy request, contact us at privacy@ambition.world. We may need to verify your identity before processing your request.
If you use an authorised agent to make a request on your behalf, we may ask the agent to provide proof of authorisation and may also require you to verify your identity directly with us, where permitted by law.

18. Children’s Privacy

Kairo is intended for users aged 18 or over.
We do not knowingly collect personal data from children. If we become aware that a child has created an account or provided personal data to us, we may delete or restrict the account and delete the relevant personal data, subject to any legal or safety obligations.
If you believe that a child has provided personal data to Kairo, please contact us at privacy@ambition.world.

19. Third-Party Links, Content and Platforms

Kairo and Ambition may link to, recommend, display or reference third-party websites, platforms, videos, podcasts, articles, tools, content or services.
This may include external content or services provided by:
We do not control third-party websites, platforms, content or services and are not responsible for their privacy practices, security, content, accuracy, availability or policies.
If you click a third-party link, interact with third-party content, use an external platform, make a payment through a provider, subscribe through an app store, or engage with Kairo or Ambition on social media, the relevant third party’s terms and privacy policy may apply.
You should review the privacy policies and terms of any third-party services you use.

20. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.
We may make changes for reasons including:
When we update this Privacy Policy, we will update the “Last updated” date at the top of the page.
If we make material changes, we will take reasonable steps to notify you, such as by email, in-app notice, website notice or another appropriate method.
Your continued use of Kairo or Ambition after an updated Privacy Policy takes effect means that you acknowledge the updated Privacy Policy, subject to any additional consent requirements under applicable law.

21. Contact Us

If you have questions about this Privacy Policy, your personal data, your privacy rights, your account, or how Kairo uses your information, you can contact us at:
Upskillist AI Limited, trading as Ambition AI
26/27 Pembroke Street Upper
Dublin 2
D02 X361
Ireland
General support: support@ambition.world
Data protection requests: privacy@ambition.world
Registered company number: 803098
For privacy-related requests, including access, deletion, correction, restriction, portability, objection or consent withdrawal requests, contact us at privacy@ambition.world.
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