Privacy Policy
Last updated: September 20, 2023
The Privacy Policy explains how the Bot Administration ("we") collects, uses, and shares Users' Personal Data ("you") when you use the Bot. Personal Data refers to your information.
The processing of Personal Data is regulated by the European Union General Data Protection Regulation EU 2016/679 (hereinafter referred to as the “GDPR”) and applicable privacy laws.
Please read the Privacy Policy carefully. By continuing to use the Bot, you confirm that you have read and understood the Privacy Policy. You also agree to let us process your Personal Data as described in the Privacy Policy.
The User Agreement assigns meanings to terms used with capital letters.
Data Controller
AppKeeper PTE. LTD is a company responsible for managing your data, duly registered under the laws of Singapore; Registration number: 202321930C. Registered address and the principal place of business: 68 Circular Road #02-01, 049422, Singapore. For support, contact Telegram @chatagov.
To contact the Administration, you can use the following support service: Telegram @chatagov.
Data Collection
We collect Personal Data or any information that can directly identify you (e.g. your name) or indirectly associate with you (e.g. chosen language).
We gather data directly from you or obtain it from third parties, such as Telegram.
Data we collect
- Account name (ChatID) and nickname on Telegram;
- First name and last name on Telegram;
- Telegram account language
- Presence of a Premium subscription
- Bot ID generated by the Administration
- Chat history (requests and responses)
- Correspondence with the Administration
- Purchase history
- Subscription status
When you make a purchase or request a refund, you provide your payment information directly to the corresponding payment service provider. The payment service processes your payment information according to its privacy policies.
We receive a portion of your credit card number (Masked PAN) and information about the issuer of your bank card from our payment partners, which we process.
Purposes and Legal Basis of Use of Personal Data
If we process your Personal Data based on your consent, you have the right to withdraw it at any time. You can let us know via Telegram.
We may combine, compile, and analyze any information we collect for the purposes stated. We anonymize aggregated information and may use and disclose it for any purpose. Anonymized information does not identify you and is not governed by this Privacy Policy.
Individuals to whom we transfer data
We may transfer information to the following categories of individuals:
Data Storage
We keep your Personal Data for the duration required to provide you with the Bot, follow legal and contractual obligations, and pursue our legitimate interests. We may keep the data for the duration of your consent as stated in this Privacy Policy. Once the information is no longer needed for these purposes, we delete it. We keep the history of the Bot (requests and responses) for 3 months.
If you delete your account or request deletion, we will delete or anonymize your Personal Data within 30 days, except in cases where we have a lawful permission or requirement to store it, such as:
- If there is an unresolved issue related to your account, such as an outstanding claim or dispute, we will keep the necessary Personal Data until the issue is resolved.
- If we need to store Personal Data to fulfill our legal, tax, auditing, and accounting obligations and/or any other legal obligations, we will store the necessary Personal Data for the required period.
- If it is necessary to pursue our legitimate interests, such as preventing fraud or ensuring the safety of our Users.
Your Rights
Right to access your Personal Data – You may request a copy of your Personal Data and/or how we store your Personal Data.
Right to rectification – you may request to change some of your Personal Data and/or correct your Personal Data if this is inaccurate.
Right to erasure – you may request to delete all or some of your Personal Data. For example, if:
- they are no longer needed for any processing purposes;
- consent has been used as a legal basis for their processing;
- there is no legitimate interest in the further processing of Personal Data.
Right to object – you may object to processing your Personal Data on grounds relating to your particular situation and/or to object processing your Personal Data for direct marketing purposes.
Right to object to automated processing – you may object to a decision based on automated processing. It means that you may request to review your Personal Data manually if you believe that automated processing of your Personal Data may not consider your unique situation.
Right for data portability – you may request to provide you a copy of your Personal Data in a structured, commonly used, and machine-readable format (e.g, XML, CSV). Furthermore, you have the right to request to transmit the said Personal Data directly to another controller.
Right to lodge a complaint – you have the right to lodge a complaint with a supervisory authority, particularly to the European Union member state of your habitual residence, place of work, or place of the alleged infringement.
Violations of Personal Data Processing
A violation of Personal Data processing may pose a physical, material, or immaterial risk to your rights and freedoms. We will notify the Data Protection Officer immediately, but no later than within 72 hours, if we become aware of such a violation, except in cases where it does not pose a risk to your rights and freedoms. If we are unable to notify within 72 hours, we will state the reasons for the delay in the notification.
Sensitive Data Collection
We do not intentionally collect sensitive Personal Data such as racial origin, political views, health information, and biometric data. However, you may voluntarily provide such data to the Bot when making requests, and we will process them as part of fulfilling our obligations under the Agreement. Please note that we cannot request your consent for such processing as we are not aware in advance of the potentially sensitive nature of the Personal Data you may provide to the Bot.
We do not intentionally collect Personal Data of children under 14 years old and do not process such information without the consent of parents. If you are a parent or legal guardian and believe that your child has provided us with Personal Data without your consent, please contact us by Telegram.
How we protect Personal Data
Our system processes Personal Information automatically, without any of our employees accessing it. However, in some cases, our employees may need to access Personal Information to perform their tasks. To ensure the confidentiality of data, all employees must follow internal rules and procedures regarding the processing of Personal Information. They must also follow all technical and organizational security measures in place to protect Personal Data.
We have implemented technical and organizational measures to protect Personal Data from unauthorized destruction, loss, alteration, use, disclosure, or access. These measures take into account the modern level of technology, the cost of their implementation, the risks associated with processing, and the nature of Personal Data.
Changes to the Privacy Policy
We may change this Privacy Policy without notifying Users, except in cases where the changes significantly affect the rights of Users. In such cases, we will notify you through the Bot. We will promptly publish any changes in the Bot's menu. By continuing to use the Bot, you confirm that you have read the updated Privacy Policy.