Privacy Policy for Paloma

Last updated: April 20, 2026

At Paloma Software Corporation, we are committed to protecting your personal information and your right to privacy. If you have any questions or concerns about this privacy policy or our practices with regard to your personal information, please contact us at contact@palomaparties.com.

The privacy of your data is incredibly important to us, as is ensuring the main effects of it are easy to understand. Here’s the summary:

What we collect: Names, email addresses, event details, uploads, correspondence - only what’s needed to help make it easier to book events. We don’t go looking for extra data. What we don’t do: We don’t sell your personal information. Ever. Who sees your data: The venue you’re booking with and the service providers that keep things running (like payment processors). We don’t sell your data or share it for advertising. Where it’s stored: Primarily in Canada, with some processing in the US through our service providers. Your rights: You can access, correct, or delete your data anytime by emailing contact@palomaparties.com.

Below is our full legal privacy policy.

Privacy Policy

Paloma Software Corporation (“Paloma”) is committed to protecting your personal information and your right to privacy. Paloma’s business involves providing software tools or “widgets” (“Widgets”) for Paloma restaurant and other event space customers (“Customers”) to include on their websites (“Customer Websites”) to simplify and provide easy and interactive event bookings by their guests (their “Guests”). To function properly and provide the best service to Paloma’s Customers and their Guests, Paloma’s Widgets collect certain personal information from Guests.

The purpose of this Privacy Policy is to outline Paloma’s commitment towards respecting Guests’ privacy and to comply with the applicable privacy laws and associated rules governing how or when any Guest personal information is collected, used and disclosed while using or accessing Paloma’s Widgets, websites operated by Paloma (“Websites”) and/or Services (as defined in Paloma’s Terms of Service located at https://www.palomaparties.com/terms). Paloma knows that Guests take their personal data and information very seriously and so do we. Paloma suggests all Paloma’s Customers and their Guests to familiarize themselves with Paloma’s Privacy Policy to understand the circumstances where both non-identifiable or personally identifiable Guest data may be collected or processed while using Paloma’s Widgets, Websites, and/or Services.

In this Privacy Policy: (1) “personal information” means information about an identified or identifiable individual; and (2) “you” and “your” refer to individual Guests who have used or accessed Paloma’s Widgets, Website and/or Services.

European Residents: If you reside in the European Union, the European Economic Area or Switzerland, please also see Paloma’s European Privacy Policy below for further information on your rights under applicable European privacy laws.

California Residents: If you reside in California, please also see Paloma’s California Privacy Rights section below for further information on your rights under the California Consumer Privacy Act.

Your access to and use of Paloma’s Widgets, Websites and/or Services is also subject to Paloma’s Terms of Service (our “Terms of Service”). Any capitalized terms used but not defined in this Privacy Policy have the meanings provided in Paloma’s Terms of Service.

1. Consent.

By accessing or using Paloma’s Widgets, Websites and/or Services, you agree to this Privacy Policy and give your explicit, informed consent to the collection, use and processing of your personal data in accordance with this Privacy Policy. If you do not agree to this Privacy Policy or Paloma’s Terms of Service, please do not access or use any of Paloma’s Widgets, Websites and/or Services.

You may withdraw your consent at any time, unless such consent would frustrate the performance of a legal obligation. Your withdrawal may restrict Paloma’s ability to provide any of Paloma’s Widgets, Website and/or Services. There are limited circumstances in which Paloma may collect, use or disclose personal information without your consent. They include: (a) when the collection, use or disclosure of personal information is permitted or required by law; (b) in an emergency that threatens an individual’s life, health or personal security; (c) when the personal information is available from a public source; (d) when Paloma requires legal advice from a lawyer; (e) for the purposes of collecting debt; (f) to protect ourselves from fraud; or (g) to investigate an anticipated breach of an agreement or a contravention of law.

2. How Paloma Collects Information.

Paloma collects information about you from a variety of sources when you access or use Paloma’s Widgets, Websites or Services, including: (a) directly from you (when you enter personal information into Paloma’s Widgets); (b) from Paloma’s business partners (including, without limitation, Paloma’s Customers) and service providers; (c) from third party sources including AI Platforms (as defined below); and (d) automatically from devices you use to connect to Paloma’s Widgets, Websites or Services.

3. Types of Information Paloma Collects and Why.

The amount and type of information that Paloma collects about you depends on the nature of your interaction with Paloma’s Widgets, Websites and Services. Paloma collects information only insofar as is necessary or appropriate to fulfill the purpose of your interaction with us. Paloma collects the following information based on different scenarios of usage while accessing or using Paloma’s Widgets, Websites and Services directly or through an app or integration on third-party generative AI platforms such as OpenAI’s ChatGPT or other MCP enabled platforms (“AI Platforms”):

a. Widget Information.

When using Paloma’s Widgets on any Customer Website or through any AI Platform, Paloma collects your name, Email address, event form data, event preferences and location shared in coversation through an AI Platform and, if you provide it, your profile picture. Paloma may also collect information relating to your address(es), past transactions with Paloma’s Customers, social media accounts, billing information, information about individuals you may invite to your event(s), reviews and other information you may choose to share with us. This information is used to provide Paloma’s Services to Paloma’s Customers, including to show you event bookings and other transactions made through Paloma’s Widgets.

Paloma does not proactively collect sensitive personal information, such as health-related information; however, Paloma’s Widgets may include text boxes that are designed to permit you to voluntarily describe details about your preferences in booking events that you want Paloma or Paloma’s Customers to know. Such details may include allergy, dietary restriction, accessibility or other health-related information. You should know that any such information that you freely submit in these boxes may reveal to Paloma or to Paloma’s Customers certain information that may be considered sensitive personal information under applicable laws. Paloma does not use any such information to market or advertise products or services to you. All such information that you voluntarily disclose to Paloma is processed on the basis of your consent which you may revoke at any time pursuant to the provisions of this Privacy Policy.

b. Usage Information.

Like most website and app operators, Paloma collects information about your interactions with Paloma’s Widgets, Website and Services, such as which screens or pages you visit, what you click on, when you perform those actions, language preferences, and so on (see section 3(e) AI Platform Inquiry Information and section 7 Tracking and Cookies for more information on how Paloma collects such information).

c. Billing Information.

Payment information is collected by Paloma’s third party payment providers such as Stripe and Square, each of which may require you to provide your billing details and financial information corresponding to your selected method of payment (e.g. a credit card number and expiration date). In most cases, Paloma will have access to transaction reference numbers and/or your billing information pertaining to each payment; however, Paloma does not store or otherwise process any credit card information. This information is used to track payment and for processing purposes. Please refer to each payment provider’s terms and conditions and privacy policies as applicable.

d. Information from Third Parties, Integration Partners and AI Platforms.

Paloma collects your information or data from third parties (including, without limitation, Paloma’s Customers and AI platforms which have integrated Paloma’s Widget) if you give permission to those third parties to share your information with Paloma or where you have made that information publicly available online (e.g. Paloma’s Customers with whom you may book events may share your information with us or information submitted as an inquiry or search session through an AI platform, all of which sharing will be controlled by such Customers); this information is used to better serve you and optimize your usage of Paloma’s Services. Paloma may also receive your information from other sources (to the extent permitted by applicable law, Paloma may receive additional information about you, such as demographic data or fraud detection information and warnings, or other information about you from partner networks).

e. AI Platform Inquiry Information.

When submitting an inquiry into an AI Platform, such search session data (including general location to match shared by you with the AI Platform to match you with relevant venues or event preferences shared during the conversation) does not persist beyond the request. Paloma does not access, store, or receive your conversation history from the AI platform. Inquiry data submitted to Paloma through Paloma’s app or Widget integrated with an AI Platform is retained as part of Paloma’s booking request records, subject to the retention policies described elsewhere in this Privacy Policy. Location and event preferences are used solely to search for and display relevant venues during your session on an AI Platform and this information may be retained in aggregated or anonymized form for analytics purposes, such as understanding search trends and improving venue matching. Paloma is not responsible for, nor does Paloma accept any liability for how such third party AI Platforms collect, use, and disclose personal information shared by you directly with such AI Platforms and not through Paloma’s app or Widget. You should consult the privacy policies of these AI Platforms before providing any personal information.

4. How Paloma Uses the Information it Collects.

Paloma uses your information for the purposes identified in this Privacy Policy at the time of collection or for a purpose related thereto, including to develop and provide Paloma’s Widgets, Website and Services and to fulfill your requests. In addition to the uses described in Section 3 above, Paloma may also use your information for the following: (a) verifying identity and authenticating information; (b) monitoring information you transmit through Paloma’s Widgets, Website and/or Services to operate Paloma’s Services and to protect ourselves, Paloma’s Customers and the public; (c) sending Email notifications and reminders related to the Services; (d) providing the Services and operating Paloma’s business; (e) responding to Customer and/or Guest requests and complaints; (f) sending newsletters or other marketing material, only where you have provided your express consent to receive such communications; (g) establishing and maintaining relationships with Customers and their Guests; (h) optimizing experiences by performing analytics and conducting research; (i) conducting investigations, detecting fraud, abuse, security breaches and other harmful activity; (j) resolving disputes and enforcing agreements and policies; and (k) meeting and complying with legal and regulatory requirements. Paloma will not rent or sell personal information.

5. How Paloma Shares the Information it Collects.

Paloma may disclose personal information to fulfill the purposes identified in this Privacy Policy, and for purposes related thereto, and to provide the Services, including as follows:

• a. within Paloma’s organization and to communicate with you;

• b. with Paloma’s third party service providers (including, without limitation, Paloma’s AI service providers), affiliates and trusted key partners (including, without limitation, Paloma’s Customers) to provide Paloma’s Services including, without limitation, to:

  • i. facilitate payment processing;
  • ii. facilitate sending email surveys or marketing notifications where express consent has been obtained by opt-in mechanism;
  • iii. manage Paloma’s support services;
  • iv. analyze and optimize event inquiries and management;
  • v. deliver and help Paloma track Paloma’s marketing and advertising content; and
  • vi. help Paloma track success metrics;

• c. certain information may be shared with third parties (including, without limitation, Paloma’s Customers) or published when you follow links to their websites – Paloma does not own or control these third parties and when you interact with them you may be providing information to them directly – such third parties will have their own rules and policies in respect of the collection, use and disclosure of personal information and Paloma encourages you to review these rules and policies;

• d. at your request or with your consent;

• e. as required by applicable laws and related rules and regulations, including, without limitation, as requested by law enforcement, pursuant to a subpoena or other governmental or regulatory authorities (including, without limitation, pursuant to any applicable “know your customer” and similar requirements to verify your identity);

• f. with a buyer, investor, new affiliate or other successor if Paloma or any affiliate undergoes a business transaction, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of Paloma’s assets or any affiliates or during steps in contemplation of such activities (e.g. negotiations and due diligence);

• g. with Paloma’s financial, insurance, legal, accounting or other advisors that provide professional services to Paloma or as otherwise needed to safeguard Paloma’s rights and meet Paloma’s contractual obligations, for example for insurance purposes; and

• h. Paloma may collect statistics about the behavior of visitors to Paloma’s Website.

  Paloma may display this information, in aggregated form, publicly or provide it to others.

6. International Transfers of Personal Information.

Paloma will store personal information on Paloma’s internal servers or with service providers. Personal information collected about you may be stored and/or processed outside of your jurisdiction of residence, including Québec, other Canadian provinces and the United States. Paloma’s service providers may also store and process personal information outside your jurisdiction. Paloma continues to have exclusive control over such data; however, when information is stored or processed outside your jurisdiction, it may be subject to the laws of, and accessible by, legal authorities in those other jurisdictions. Paloma ensures that its service providers comply with all applicable privacy laws. By submitting your personal information, engaging with Paloma’s Widgets or Websites or using Paloma’s Services, you consent to such transfer and storage. For more information about Paloma’s data processing abroad, please contact Paloma at contact@palomaparties.com.

7. Cookies and Tracking.

Our Websites use “cookies” which enables Paloma to remember you and understand and save your preferences. A cookie is a string of information stored on your computer or mobile device, and that your browser provides to the website each time you return. Paloma uses cookies to help Paloma identify and track visitors to Paloma’s Websites, their usage of the Websites, and their access preferences on each Website, to improve Paloma’s Widgets, Websites and Services. If you do not wish to have cookies placed on your device you should set your browsers to refuse cookies before using Paloma’s websites. If you do this, the drawback is that certain features of Paloma’s Websites and Services may not function properly and this may also block cookies for any other website you visit.

Paloma also collects log data each time a device accesses Paloma’s servers; log data includes details about the nature of each access including originating IP addresses, access times, device type, operating system versions, internet service providers, pages you view before and after using Widgets, Websites or Services, links to third party applications, and hardware and software information. Paloma will not respond to Web browser “do not track” signals. If you would like additional information about online tracking and various opt-out mechanisms, please see https://youradchoices.com/.

Because Paloma links to social media sites, other parties may collect your personally identifiable information about your online activities over time and across different websites when you visit Paloma’s Websites.

Please note that not all tracking will stop even if you delete cookies.

8. Links to Other Websites.

Paloma may offer links to other websites controlled by third parties (including, without limitation, Paloma’s Customers). Paloma is not responsible for, nor does Paloma accept any liability for how such third parties collect, use, and disclose personal information. You should consult the privacy policies of these other websites before providing any personal information.

9. Security of Personal Information.

Paloma is committed to the security of your personal information and Paloma takes reasonable steps to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal and other risks. Paloma stores personal information in a secure location, accessible by designated staff and Paloma only uses it for the purposes for which you provide it (as set out in this Privacy Policy). However, please note that the safety and security of your information is also your responsibility.

Paloma uses reasonable and appropriate security measures when Paloma destroys personal information.

Paloma routinely reviews and updates its security policies and controls to ensure ongoing reasonable personal information security, though the Internet is not a 100% secure environment so Paloma cannot guarantee the complete security and protection of the transmission and storage of your information.

10. Safety of Minors.

Paloma encourages parents and guardians to be aware of their children’s online activities. Paloma does not knowingly collect the personal information of minors (persons under the age of 13 or under a higher age if permitted by the laws of their residence). If you are aware that a minor has provided Paloma with personal information, please contact Paloma at contact@palomaparties.com. If it comes to Paloma’s attention that it has collected personal information from a minor, Paloma may delete this information without notice.

11. Limitation of Liability.

UNDER NO CIRCUMSTANCES SHALL PALOMA BE LIABLE FOR ANY DIRECT OR INDIRECT, SPECIAL, INCIDENTAL OR CONSEQUENTIAL DAMAGES THAT MAY ARISE FROM A CLAIM OF BREACH OF THIS PRIVACY POLICY. Some jurisdictions do not allow the exclusion or limitation of liability for consequential or incidental damages. In such jurisdictions, Paloma’s liability is limited to the greatest extent permitted by law, or $5, whichever is less.

12. Retention of and Access and Change to Personal Information.

Paloma will only retain personal information it collects for as long as necessary in accordance with applicable laws. Once Paloma no longer needs your personal information to achieve Paloma’s purposes, it will, unless allowed to do otherwise by applicable laws, delete this information in accordance with applicable requirements.

Paloma makes reasonable efforts to ensure your personal information is accurate and complete. You may make a request to update, correct or delete your personal information at any time by submitting a request in writing to contact@palomaparties.com. It is your responsibility to provide updates to your personal information and to maintain its accuracy.

You may request access to your personal information or request to know how Paloma uses it or to whom it has been disclosed, subject to limited exceptions prescribed by law. Requests must be made in writing via Email to contact@palomaparties.com. Paloma will respond to requests in accordance with applicable laws. To the extent permitted by applicable law, fees may be charged to access information, but you will be notified of such in advance so you can choose whether or not to proceed. Before providing you with access to your information, Paloma may ask you for specific information to help Paloma confirm your identity and right of access, and to provide you with the personal information Paloma holds about you, or to make the requested changes. In some cases, applicable law requires Paloma to refuse to provide you with access to some or all of the personal information Paloma holds about you, or that Paloma may have destroyed or erased in accordance with its legal record-keeping obligations and privacy best practices.

A government agency may ask Paloma to set aside a copy of specific information while it applies for legal process to compel the disclosure of that information. Preservation requests only apply to information that Paloma and its affiliates have at the time of the request, not information that may be generated in the future.

Please note that if you request deletion of certain information, Paloma may not be able to provide you with certain services. Paloma will explain the consequences of deletion at that time to assist you in your decision. If Paloma is unable to provide you with access to your personal information, Paloma will inform you of the reasons why, subject to any legal or regulatory restrictions. Such restrictions may include, for example, information about another individual that would reveal their personal information or confidential business information or would be prohibitively costly to provide.

For connected accounts (such as Google), you may revoke Paloma’s access to your external accounts at any time via the web interface or by contacting us at contact@palomaparties.com. Upon disconnection, your external account data will be deleted within 30 days.

13. Contacting Us.

If there are any questions regarding this Privacy Policy you may contact Paloma’s Privacy Officer using the information below.

Paloma Software Corporation 620 Cooper St. Ottawa ON K1R 5J2 Attention: Privacy Officer contact@palomaparties.com

Paloma’s Privacy Officer reviews all complaints within a reasonable time and if a complaint is determined to be justified, then Paloma’s Privacy Officer will conduct an investigation and take appropriate steps to remediate the issue including, if necessary, amending Paloma’s policies and procedures, safeguards and information management practices. Paloma’s Privacy Officer will inform any complainant as to the result of any investigation within 30 business days from receipt of the related complaint. If, however, an investigation requires additional time to be thoroughly completed, then Paloma’s Privacy Officer will provide the complainant with a timeline for completion.

If Paloma is unable to address a complaint to the satisfaction of the complainant, then they may contact the Office of the Privacy Commissioner of Canada by phone (1-800-282-1376) or by filling out a complaint form available at https://www.priv.gc.ca/en/report-a-concern/ and submitting the form by mail to:

Office of the Privacy Commissioner of Canada 12 Kent Street Place de Ville, Tower B, Third Floor Ottawa, ON K1A 1H3

14. Changes to the Privacy Policy.

Although most changes are likely to be minor, Paloma may change Paloma’s Privacy Policy from time to time, and in Paloma’s sole discretion. Paloma encourages visitors and users to frequently check this page for any changes to the Privacy Policy. Your continued use of Paloma’s Widgets, Websites and/or Services after any change in this Privacy Policy will constitute your acceptance of such change.

15. Additional Rights.

Applicable laws may give you additional rights that are not described in the Privacy Policy.

Additional European Privacy Policy

The following Additional European Privacy Policy applies to you if you reside in the European Union, the European Economic Area or Switzerland.

Personal Data and Processing. For the purposes of this European Privacy Policy:

• “Personal Data” means any information relating to an identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of such natural person; and
• “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Purposes and Legal Basis for Processing Personal Data. Paloma processes data for the purposes as set forth in Paloma’s Privacy Policy, including to provide the Services and as explained in the sections of the Privacy Policy titled “How Paloma Uses the Information it Collects” and “How Paloma Shares Information it Collects”. To fulfill these purposes, Paloma may access data, including Personal Data, to provide the Services, to correct and address technical, service or security problems, or in response to contractual requirements. Please see Paloma’s Privacy Policy for additional details on how Paloma collects, uses, discloses and shares data, make automated decisions, and retain data, including Personal Data, about individual users.

Paloma’s legal bases for the processing of Personal Data are: (i) consent or (ii) any other applicable legal basis, such as Paloma’s legitimate interest in engaging in commerce, offering products and services of value to the customers of the Services, preventing fraud, complying with applicable governmental requirements, ensuring information and network security, direct marketing and advertising, and complying with industry practices.

Additional Rights for European Residents. As a resident of the European Union or a country following substantially similar legislation regarding the protection of Personal Data, individuals may have one or more of the following additional rights:

• Access. To request a copy of the Personal Data Paloma has collected about you by contacting us.
• Rectification & Erasure. To request that Paloma rectifies or deletes any of the Personal Data about you that is incomplete, incorrect, unnecessary or outdated.
• Objection. To object, at any time, to Personal Data about you being Processed for direct marketing purposes.
• Restriction of Processing. To request restriction of Processing of Personal Data about you for certain reasons, such as, for example, if you consider Personal Data about you collected by Paloma to be inaccurate or you have objected to the Processing and the existence of legitimate grounds for Processing is still under consideration.
• Data Portability. To request and receive the Personal Data Paloma has collected about you in a commonly used and machine-readable form.
• Right to Withdraw Consent. If Personal Data about you is processed solely based on your consent and not for any other legitimate interest, to withdraw your consent at any time, without affecting the lawfulness of Paloma’s Processing based on such consent before it was withdrawn, including Processing related to existing contracts for Paloma’s products and services.
• Right to Lodge a Complaint with a data protection authority. If you believe Paloma’s Processing of Personal Data about you is inconsistent with the applicable data protection laws, to lodge a complaint with your local supervisory data protection authority.

To exercise any of the above listed rights, please contact Paloma as set forth below and provide sufficient details so that Paloma can respond appropriately. Paloma will process any requests in accordance with applicable law and within a reasonable period of time. Paloma may need to verify the identity of the individual submitting a request before it can address such request.

Compelled Disclosures. Paloma may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Protection Contact. Unless otherwise specified, Paloma is the data controller with respect to the data provided through Paloma’s Widgets, Website and/or Services. Paloma’s Data Protection Contact for the Personal Data collected in connection with Paloma’s Widgets, Website and/or Services is:

Paloma Software Corporation Attention: Privacy Officer contact@palomaparties.com

California Privacy Rights — For California Residents Only

Sales of Information. Paloma has not disclosed and/or sold personal information to third parties for a business or commercial purpose in the preceding 12 months. Paloma does not sell the personal information of minors under 16 years of age without affirmative authorization.

If you wish to change personally identifiable information that you have provided us, please Contact Us.

Your Rights. You have the right to request that Paloma discloses to you what information it collects, uses, discloses, and sells. You also have the right to request that a business deletes any personal information about you which the business has collected about you. To submit either of the above requests, you contact Paloma via Email at contact@palomaparties.com. Also, please note that Paloma only deletes accounts with a valid “from” Email address (i.e. you must request your data deletion from the same Email used for your account). You have the right to direct Paloma not to sell your information.

If you opt to exercise your privacy rights, Paloma is required to verify your identity to prevent unauthorized access to your data. This may require Paloma to ask you certain questions to confirm your identity or require you to provide government issued identification. Requests to exercise these rights may be granted in whole, in part, or not at all, depending on the scope and nature of the request and applicable law. Where required by applicable law, Paloma will notify you if it rejects your request and notify you of the reasons Paloma is unable to honor your request.

Right to Know and Access Information. You may access information Paloma maintains about you using the methods provided below. If Paloma grants your request, Paloma will provide you with a copy of the personal information it maintains about you in the ordinary course of business. This may include what personal information Paloma collects, uses, or discloses about you. Paloma may not fulfill some or all of your request to access as permitted by applicable law.

Deletion of Information. You may request that Paloma delete your personal information. Depending on the scope of your request, Paloma may refrain from granting your request, as permitted by applicable law. For example, Paloma may be legally required to retain your information in Paloma’s business records. You may submit a deletion request via Email to contact@palomaparties.com.

Paloma shall not discriminate against you for exercising any of your above rights.

You may designate an authorized agent to make a request to exercise your rights on your behalf. For your protection, Paloma reserves the right to deny any request from an agent who does not submit proof that they have been authorized to act on your behalf.