Effective August 22, 2025
Effective February 19, 2026
We at Gambit Technologies Inc. (together with our affiliates, “Provider”, “we”, “our” or “us”) respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you. This Privacy Policy describes our practices with respect to Personal Information we collect from or about you when you use our website, applications, and services (collectively, “Services”). This Privacy Policy does not apply to content that we process on behalf of customers of our business offerings, such as resellers or distributors of our software or services. Our use of that data is governed by our customer agreements covering access to and use of those offerings.
Gambit Co provides technology and communication services (including the Chloe AI Concierge) on behalf of our clients, including the City of Vail. When we reference “Services” in this Privacy Policy, this includes technology and communication services we provide on behalf of our clients.
A note about accuracy: Our Services generate responses by reading a user’s request and, in response, predicting the words most likely to appear next. In some cases, the words most likely to appear next may not be the most factually accurate. For this reason, you should not rely on the factual accuracy of output from our models.
We may collect personal information relating to you (“Personal Information”) as follows:
Personal Information You Provide: We collect Personal Information if you create an account to use our Services or communicate with us as follows:
Account Information: If you create an account with us, we will collect information associated with your account, including (depending on the nature of the account and the information required to create it) your name, contact information, account credentials, payment card information, and transaction history (collectively, “Account Information”).
Anonymous User Sessions: If you use our Services without creating an account, we may create a persistent anonymous user record in our system. This record allows us to maintain your sessions and interaction history. Anonymous sessions reset after 30 days of inactivity, unless you return within that period, in which case the session is extended for another 30 days. You may also manually clear your session at any time using the “Clear Session” option in the Service. If a session is reset, your previous interactions remain linked to the same anonymous user record, and a new session will begin.
User Content: When you use our Services, we collect Personal Information that is included in the input, file uploads, or feedback that you provide to our Services (“Content”).
Communication Information: If you communicate with us, we collect your name, contact information, and the contents of any messages you send (“Communication Information”).
Social Media Information: We may have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube and LinkedIn. If you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
Other Information You Provide: We may collect other information that you provide to us, such as when you participate in surveys or programs, or provide us with information to establish your identity (collectively, “Other Information You Provide”).
Personal Information We Receive Automatically From Your Use of the Services: When you visit, use, or interact with the Services, we may receive the following information (“Technical Information”):
Log Data: Information that your browser or device automatically sends when you use our Services. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interact with our Services.
Usage Data: We may automatically collect information about your use of the Services, such as the types of content that you view or engage with, the features you use and the actions you take, as well as your time zone, country, the dates and times of access, user agent and version, type of computer or mobile device, and your computer connection.
Device Information: Includes name of the device, operating system, device identifiers, and browser you are using. Information collected may depend on the type of device you use and its settings.
Cookies: We use cookies to operate and administer our Services, and improve your experience. A “cookie” is a piece of information sent to your browser by a website you visit. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, a website or certain areas or features of a website.
Analytics: We may use a variety of online analytics products that use cookies to help us analyze how users use our Services and enhance your experience when you use the Services.
We may use Personal Information for the following purposes:
Aggregated or De-Identified Information. We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyze the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to reidentify the information, unless required by law.
As noted above, we may use Content you provide us to improve our Services, for example to train the models that power our software and Services.
In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the law:
Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may provide Personal Information to vendors and service providers, including providers of hosting services, customer service vendors, cloud services, email communication software, web analytics services, and other information technology providers, among others. Pursuant to our instructions, these parties will access, process, or store Personal Information only in the course of performing their duties to us. However, this excludes text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Business Transfers: If we are involved in strategic transactions, reorganization, bankruptcy, receivership, or transition of service to another provider (collectively, a “Transaction”), your Personal Information and other information may be disclosed in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets. However, text messaging originator opt-in data and consent will not be shared with any third parties as part of any such Transaction for marketing or promotional purposes.
Legal Requirements: We may share your Personal Information, including information about your interaction with our Services, with government authorities, industry peers, or other third parties (i) if required to do so by law or in the good faith belief that such action is necessary to comply with a legal obligation, (ii) to protect and defend our rights or property, (iii) if we determine, in our sole discretion, that there is a violation of our terms, policies, or the law; (iv) to detect or prevent fraud or other illegal activity; (v) to protect the safety, security, and integrity of our products, employees, or users, or the public, or (vi) to protect against legal liability. Notwithstanding the foregoing, text messaging originator opt-in data and consent will not be shared with any third parties for marketing or promotional purposes.
Affiliates: We may disclose Personal Information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with us. Our affiliates may use the Personal Information we share in a manner consistent with this Privacy Policy. However, this excludes text messaging originator opt-in data and consent; this information will not be shared with any affiliates for marketing or promotional purposes.
Organization Account Administrators: If your access to our Services is made available through a reseller or distributor arrangement with us, the administrators of that organization may access and control your account. In addition, if you create an account using an email address belonging to your employer or another organization, we may share the fact that you have an account and certain account information, such as your email address, with your employer or organization to, for example, enable you to be added to their account.
Other Users and Third Parties You Share Information With: Certain features allow you to display or share information with other users or third parties. For example, you may share conversations with other users via shared links or send information to third-party applications via custom actions. Be sure you trust any user or third party with whom you share information. Notwithstanding the foregoing, text messaging originator opt-in data and consent will not be shared with any third parties for marketing or promotional purposes.
When you opt in to receive text messages from us or from services we operate on behalf of our clients (including the Chloe AI Concierge operated on behalf of the City of Vail), we collect your mobile phone number and your consent to receive such messages.
Mobile information and text messaging originator opt-in data and consent will not be shared with any third parties, affiliates, or partners for marketing or promotional purposes.
We use your phone number and opt-in consent solely to send you the text messages you have requested or consented to receive. You may opt out of text messages at any time by replying STOP to any message. Standard message and data rates may apply.
Depending on location, individuals may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:
The following table provides additional information about the categories of Personal Information we collect and how we disclose that information. You can read more about the Personal Information we collect in “Personal information we collect” above, how we use Personal Information in “How we use personal information” above, and how we retain Personal Information in “Security and Retention” below.
| Category of Personal Information | Disclosure of Personal Information |
|---|---|
| Identifiers, such as your name, contact details, IP address, and other device identifiers | We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; to corporate administrators of enterprise or team accounts; and to other users and third parties you choose to share it with. |
| Commercial Information, such as your transaction history | We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to corporate administrators of enterprise or team accounts. |
| Network Activity Information, such as Content and how you interact with our Services | We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to other users and third parties you choose to share it with. |
| Geolocation Data | We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; and to parties involved in Transactions. |
| Your account login credentials and payment card information (Sensitive Personal Information) | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions. |
| Text Messaging (SMS) Data, such as your phone number and opt-in consent | This information will not be shared with any third parties, affiliates, or partners for marketing or promotional purposes. It is used solely to deliver the text messaging services you have consented to receive. |
To the extent provided for by local law and subject to applicable exceptions, individuals may have the following privacy rights in relation to their Personal Information:
We don’t “sell” Personal Information or “share” Personal Information for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also don’t process sensitive Personal Information for the purposes of inferring characteristics about a consumer.
Exercising Your Rights. To the extent applicable under local law, you can exercise privacy rights described in this section by submitting a request through to us by email.
Verification. In order to protect your Personal Information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request.
Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us.
Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law.
Our Service is not directed to children under the age of 13. We do not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Service, please contact us. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you are 13 or older, but under 18, you must have permission from your parent or guardian to use our Services.
The Service may contain links to other websites not operated or controlled by us, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.
We’ll retain your Personal Information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.
For anonymous users, we retain the anonymous user record in our system. Individual sessions tied to that record will reset after 30 days of inactivity, or when you manually clear your session. Previous interactions remain associated with the anonymous user record, while new activity is logged under a new session.
By using our Service, you understand and acknowledge that your Personal Information will be processed and stored in our facilities and servers in the United States and/or Canada and may be disclosed to our service providers and affiliates in other jurisdictions.
Legal Basis for Processing. Our legal bases for processing your Personal Information include:
Data Transfers. Where required, we will use appropriate safeguards for transferring Personal Information outside of certain countries. We will only transfer Personal Information pursuant to a legally valid transfer mechanism.
We may update this Privacy Policy from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law.
If you have any questions or concerns not already addressed in this Privacy Policy, or if you would like to exercise any rights with respect to your Personal Information, please contact us at: AI@gambitco.io.
Personal Information We Receive Automatically From Your Use of the Services: When you visit, use, or interact with the Services, we may receive the following information (“Technical Information”):
2. How we use personal information
We may use Personal Information for the following purposes:
Aggregated or De-Identified Information. We may aggregate or de-identify Personal Information so that it may no longer be used to identify you and use such information to analyze the effectiveness of our Services, to improve and add features to our Services, to conduct research and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Services and share aggregated information like general user statistics with third parties, publish such aggregated information or make such aggregated information generally available. We may collect aggregated information through the Services, through cookies, and through other means described in this Privacy Policy. We will maintain and use de-identified information in anonymous or de-identified form and we will not attempt to reidentify the information, unless required by law.
As noted above, we may use Content you provide us to improve our Services, for example to train the models that power our software and Services.
3. Disclosure of personal information
In certain circumstances we may provide your Personal Information to third parties without further notice to you, unless required by the law:
4. Your rights
Depending on location, individuals may have certain statutory rights in relation to their Personal Information. For example, you may have the right to:
5. Additional disclosures
The following table provides additional information about the categories of Personal Information we collect and how we disclose that information. You can read more about the Personal Information we collect in “Personal information we collect” above, how we use Personal Information in “How we use personal information” above, and how we retain Personal Information in “Security and Retention” below.
| Category of Personal Information | Disclosure of Personal Information |
| Identifiers, such as your name, contact details, IP address, and other device identifiers | We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; to corporate administrators of enterprise or team accounts; and to other users and third parties you choose to share it with. |
| Commercial Information, such as your transaction history | We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to corporate administrators of enterprise or team accounts. |
| Network Activity Information, such as Content and how you interact with our Services | We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; to parties involved in Transactions; and to other users and third parties you choose to share it with. |
| Geolocation Data | We may disclose this information to our affiliates, vendors and service providers to process in accordance with our instructions; to law enforcement and other third parties for the legal reasons described above; and to parties involved in Transactions. |
| Your account login credentials and payment card information (Sensitive Personal Information) | We disclose this information to our affiliates, vendors and service providers, law enforcement, and parties involved in Transactions. |
To the extent provided for by local law and subject to applicable exceptions, individuals may have the following privacy rights in relation to their Personal Information:
We don’t “sell” Personal Information or “share” Personal Information for cross-contextual behavioral advertising (as those terms are defined under applicable local law). We also don’t process sensitive Personal Information for the purposes of inferring characteristics about a consumer.
Exercising Your Rights. To the extent applicable under local law, you can exercise privacy rights described in this section by submitting a request through to us by email.
Verification. In order to protect your Personal Information from unauthorized access, change, or deletion, we may require you to verify your credentials before you can submit a request to know, correct, or delete Personal Information. If you do not have an account with us, or if we suspect fraudulent or malicious activity, we may ask you to provide additional Personal Information and proof of residency for verification. If we cannot verify your identity, we will not be able to honor your request.
Authorized Agents. You may also submit a rights request through an authorized agent. If you do so, the agent must present signed written permission to act on your behalf and you may also be required to independently verify your identity and submit proof of your residency with us.
Appeals. Depending on where you live, you may have the right to appeal a decision we make relating to requests to exercise your rights under applicable local law.
6. Children
Our Service is not directed to children under the age of 13. We do not knowingly collect Personal Information from children under the age of 13. If you have reason to believe that a child under the age of 13 has provided Personal Information to us through the Service, please contact us. We will investigate any notification and if appropriate, delete the Personal Information from our systems. If you are 13 or older, but under 18, you must have permission from your parent or guardian to use our Services.
7. Links to other websites
The Service may contain links to other websites not operated or controlled by us, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
8. Security and Retention
We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Information both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or email. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third-party websites.
We’ll retain your Personal Information for only as long as we need in order to provide our Service to you, or for other legitimate business purposes such as resolving disputes, safety and security reasons, or complying with our legal obligations. How long we retain Personal Information will depend on a number of factors, such as the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure, our purpose for processing the information, and any legal requirements.
For anonymous users, we retain the anonymous user record in our system. Individual sessions tied to that record will reset after 30 days of inactivity, or when you manually clear your session. Previous interactions remain associated with the anonymous user record, while new activity is logged under a new session.
9. International users
By using our Service, you understand and acknowledge that your Personal Information will be processed and stored in our facilities and servers in the United States and/or Canada and may be disclosed to our service providers and affiliates in other jurisdictions.
Legal Basis for Processing. Our legal bases for processing your Personal Information include:
Data Transfers. Where required, we will use appropriate safeguards for transferring Personal Information outside of certain countries. We will only transfer Personal Information pursuant to a legally valid transfer mechanism.
10. Changes to the privacy policy
We may update this Privacy Policy from time to time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law.
11. How to contact us
If you have any questions or concerns not already addressed in this Privacy Policy, or if you would like to exercise any rights with respect to your Personal Information, please contact us at: AI@gambitco.io.