Effective Date: April 30, 2024
Welcome to the Privacy Policy of Techprom Limited Company (address :15/F, RADIO CITY, 505 HENNESSY ROAD CAUSEWAY BAY, HONG KONG) and its subsidiaries and affiliated entities, collectively referred to as ” Techprom Limited,” “we,” “us,” or “our.” We are dedicated to ensuring the security and appropriate utilization of information, herein referred to as “Personal Information.” This document, known as the “Policy,” outlines our approach to privacy regarding the processing of Personal Information within Techprom Limited solutions and platforms, as well as on our official website (https://aclservice.io ), referred to as the “Site.” Or “Website” or “ACL” and Telegram Bot (@Aslservice_bot) referred to as the “ACL Bot”.
This Policy applies to various types of information we might handle:
Information concerning visitors who access, utilize, or engage with the Site, as well as individuals who communicate with us for inquiries.
Information regarding Customers and personnel (including contractors or other points of contact) associated with our Customers.
Information about individuals who explore the websites and/or applications of our Customers (“End Users”), collectively referred to as “you” or “users.”
Special privacy conditions regarding ACL Bot in Telegram
The ACL Bot (Telegram based service bot) operates with a strict policy of user anonymity and data protection. It does not track or store any user information or actions taken within the bot. Additionally, the bot does not have access to banking or other financial gateways, nor is it associated with any payment methods.
Furthermore, the ACL Bot lacks the technical capability to disclose any information to external requests, including government or non-government regulatory authorities.
Users can use the ACL Bot with complete anonymity; no data is collected or stored within Telegram when interacting with the bot.
The bot adheres to a policy of not sharing any data with third parties and upholds the privacy rights of all individuals.
It’s important to note that all information provided by the ACL Bot is advisory in nature. Users independently decide to utilize the bot and assume any associated risks.
1. Definitions
“Site” or “Website” refers to the Techprom Limited website available at https://aclservice.io
“Privacy Policy” means the latest version of the Company’s Privacy Policy describing our policies and procedures concerning the collection, use, and disclosure of your Personal Data.
“Personal Data” means any information relating to the User that identifies or may identify the User.
“User” refers to an individual or a legal entity that has read and agreed to the Terms of Use and the Privacy Policy and uses the services of ACL provided by the Company through the Website, referred to as “you” or “yours” hereinafter.
“Services” means the services of ACL provided by the Company and available to Users via the Website.
2. Collection of Personal Information
Techprom Limited engages in the processing of personal data, which we obtain from our Customers, yourself, or a representative acting on your behalf (such as your employer) within the framework of our business operations. Additionally, as required to deliver our Service and adhere to our contractual, policy, and other commitments, we may process personal information obtained from publicly accessible sources. When using ACL Bot in Telegram, no user data is collected or processed.
2.1. Visitors to Our Site and Individuals Contacting Us with Inquiries:
We, or designated third parties acting on our behalf, gather and employ personal information that may encompass:
Personal Information belonging to visitors of our Site, particularly when they establish communication or engage with the Site.
Details pertaining to your queries and/or general aspects of your interest in our Service.
First and last name, email address, contact number, or any other details shared by visitors during interactions conducted via email, facsimile, telephone, or alternate means.
Upon visiting our Site, our servers register specific “traffic/session” particulars originating from your device, such as your user agent and Internet Protocol (IP) address.
While utilizing our Site, we may amass information related to your activities, encompassing log-in and log-out times, session durations, accessed web pages, specific content within web pages, activity metrics, and the geographical location of your device.
The Site also incorporates links to third-party social media platforms such as Facebook®, Twitter®, LinkedIn®, accompanied by associated social media features and scripts, like the Facebook® “like” button and widgets. These elements and scripts are designed to collect your IP address, determine the page you are visiting on the Site, and establish a cookie to facilitate their proper functionality. Social media features and widgets are hosted either by the relevant third-party social media platforms or directly on the Site.
2.2. Your interactions with these social media features, widgets, and the social media platforms themselves are subject to the privacy policies of the respective social media sites. If you provide Personal Information in a comment on a blog post or on any related social media platform, it’s important to recognize that this information may be read, gathered, or used by others, potentially leading to unsolicited messages or unauthorized contact without your consent or intent.
It’s important to note that the submission of Personal Information in these forums is your responsibility, and we are not accountable for the Personal Information you choose to disclose.
During your interactions with us, whether initiated by you or by us, any Personal Information you provide will be received and processed.
2.3. In addition to other endorsements, we showcase personal testimonials from contented Customers on the Site. With your consent, we may publish your testimonial accompanied by your name.
3. Information We Collect
3.1 When you engage with us, we collect and process your Personal Data, which includes as follows:
Personal identification information, including: name, e-mail address, phone number, country, full address, date of birth, registered address, banking details;
Data collected in connection with “Know Your Customer” (KYC) compliance, “Anti-Money Laundering” (AML) compliance and “Counter-Terrorist Financing” (CTF) compliance;
Device and website usage data, including: IP addresses; language preferences and other device identifiers; information relating to your access to the Platforms, such as device characteristics, date and time.
3.2 The Company subjects the personal data to automated reading, verification of the authenticity and other automated processing of photos and scanned copies of documents and with further check against the data in multiple databases, including inter alia International politically exposed persons (PEPs) and Sanctions, Country Specific Sanctions Lists, Criminal Lists and Financial Lists. Once the personal data is not any more necessary for the purposes of applicable compliance rules, the Company shall erase the data completely off its servers without leaving any backup copies or, based on the same condition, transfer the data to the relevant Controller.
4. Responsibilities
4.1. Techprom Limited Responsibilities:
Techprom Limited is responsible for establishing policies and procedures to comply with the EU GDPR.
Data Protection Officer’s Responsibilities:
The Data Protection Officer holds responsibility for:
Drawing up guidance and promoting compliance with this policy.
Ensuring appropriate compliance with subject access rights.
Ensuring that any data protection breaches are resolved, catalogued and reported appropriately.
Investigating and responding to complaints regarding data protection.
4.2. Staff Responsibilities:
Staff members who process personal data must comply with the requirements of this policy.
Software and Network Security:
4.3. The Company holds regular vulnerability scans against our full infrastructure. We also have external, independent, penetration tests conducted on a periodic basis. Our dashboard supports several regimes of secrecy, so that our clients could monitor the status of processing without learning any personal data of their customers. Code changes are always peer reviewed and static source code reviews are performed systematically and at a high frequency. All engineering and development operations staff are regularly trained on system, application, and network security. Our IT and container infrastructure is continuously monitored and audited for change. Critical systems and information are protected with strong authentication mechanisms. All networks connections are protected by firewalls and are monitored by cybersecurity solutions to detect intrusions and suspicious activity. Machine learning is used to discover malicious behavior of network endpoints and applications. All our computers, laptops, and servers utilize full disk/volume encryption and are installed with antivirus/malware protection which is automatically updated to the latest version and signatures available.
5. How We Collect Your Data
We collect Personal Data directly from you when you use our Website or services, communicate with us, or interact directly with us. For example, when you complete the contact form on our Website or Application or when you contact us via email. We use industry standards for automatically collecting certain information about visitors to our Website. We also may collect information about you from third-party sources, including but not limited to marketing partners, advertising partners, analytics providers, public databases, credit bureaus, ID verification partners, and social networks.
6. Sharing Personal Information with Others
6.1. We may share your Personal Information with our Customers, service providers, and other third parties when necessary to fulfill the stated purposes of collecting such information. Furthermore, we may disclose Personal Information to affiliated companies, organizations, or entities associated with us. We might also reveal your Personal Information to third parties as part of our legitimate business interests, which include running, expanding, and enhancing our operations.
6.2. Please note that in these scenarios, we will exercise due diligence to ensure that any sharing of Personal Information is carried out in accordance with applicable laws and regulations.
For instructions on how to opt out based on your device, please consult device-specific information:
Android – https://support.google.com/ads/answer/2662922
iOS – https://support.apple.com/en-il/HT205223
7. Notice to Residents of the EEA, Switzerland, and UK: Data Subject Rights
7.1. This section applies to individuals located in the European Economic Area (“EEA”), Switzerland, or the United Kingdom (“UK”) and supplements the practices described in this Privacy Policy. It describes certain rights and protections under applicable law regarding the processing of Personal Information.
7.2. Please note that if you are an EEA resident, the General Data Protection Regulation applies to the processing of your personal data. We also apply substantially the same standards of data protection to all of our users. In certain jurisdictions, specific rights concerning your Personal Information may apply. Subject to eligibility, you might possess certain rights, such as:
Requesting the rectification of incorrect or incomplete Personal Information.
Objecting to the processing of your Personal Information for direct marketing purposes.
Objecting to automated decision-making under specific conditions.
Requesting the erasure of your Personal Information under certain circumstances.
Receiving your Personal Information or asking us to transfer it to another organization.
Lodging a complaint with the data protection supervisory authority.
For more details about your rights under EU data protection laws, please refer to the EU Commission’s website.
7.3. Please note that we will need to authenticate your identity and location when you submit a request to exercise your rights.
8. Legal Necessity
We process personal data when necessary to comply with applicable laws and regulations. For example, we may need to collect user IP addresses for identification or understanding the jurisdiction of the information and its origin.
9. Other Territories Data Subject Rights
9.1. UK Data Subject Rights:
The UK now has its own version of data protection regulations known as the UK-GDPR. Individuals in the UK can exercise various rights under this regulation, including the right to be informed, right of access, right to rectification, right to erasure, right to restrict processing, right to data portability, right to object to processing, and rights in relation to automated decision making and profiling.
9.2. Data Protection Rights of Residents of Brazil:
Techprom Limited adheres to the principles and requirements of data processing under the Lei Geral de Proteção de Dados Pessoais (LGPD). Residents of Brazil have various rights under this legislation, including confirmation, access, rectification, data portability, anonymization, deletion, information, revocation, complaint, opposing processing, and request review.
9.3. Data Protection Rights of Residents of Virginia and Colorado:
Techprom Limited fully complies with all principles and requirements of data processing under the Colorado’s Consumer Data Protection Act (CPA) and the Virginia Consumer Data Protection Act (VCDPA). Residents of Virginia and Colorado have specific rights under these legislations, including access, correction, deletion, and opposition to processing.
9.4. Data Protection Rights of The Residents of China:
Techprom Limited is fully compliant with all principles and requirements of data processing under the Personal Information Protection Law (PIPL). Residents of China have various rights under this legislation, including the right to knowledge, decision, refusal, limitation, access and copy, correction or completion, explanation, deletion, data transfer, and request review.
10. Aggregated and Analytical Information
We employ standard analytics tools and utilize anonymous, statistical, or aggregated information for legitimate business purposes. We may share this information with partners, ensuring privacy is maintained.
11. Storage and Deletion of Personal Data
We retain your Personal Data for as long as necessary to enable you to use the Website and to provide Services to you, comply with applicable laws, resolve disputes, and conduct our business. When we no longer need to keep your Personal Data, we securely delete or destroy it.
12. Protection of Personal Data
We follow standard practices within the industry to protect the Personal Data that we collect and maintain. While we implement technology and security policies and procedures to reduce risks, no data transmission over the Internet can be guaranteed to be 100% secure.
13. . Changes to the Privacy Policy
This Policy may be updated periodically. Minor updates will come into effect after 7 days of notice, while substantial changes will be effective after 15 days of notice. If adjustments are required to meet legal obligations, the new Policy will take effect immediately or as mandated by law.
14. Contact Information
If you have any questions regarding this Agreement, please contact us at info@aclservice.io
