SUCH Privacy Policy
Your privacy is critically important to us. At SUCH, we have a few fundamental principles:
- We are thoughtful about the personal information we ask you to provide and the personal information that we collect about you through the operation of our services.
- We store personal information for only as long as we have a reason or legal basis to keep it.
- We aim for full transparency on how we gather, use, and share your personal information.
- We do not monetize your data.
- We collect any data only on lawful grounds.
Below is our Privacy Policy, which incorporates and clarifies these principles.
Who We Are and What This Privacy Policy Covers
We refer to (a) InviteMember LLC (a company incorporated and existing under the laws of the State of Delaware under the number 6979516, mailing address 16192 Coastal Highway, Lewes, Delaware 19958 USA), if User is located elsewhere in the world, except EU countries and the UK; or (b) DEV WAY LTD (a company incorporated and existing under the laws of the Republic of Cyprus under the number HE 437821, mailing address is 165, Spyrou Araouzou, Lordos Waterfront Court, Office 402, 3036 Limassol, Cyprus), if User is located in EU countries as well as the UK, as “SUCH” or “we” throughout this Privacy Policy.
SUCH Platform is a support bot platform designed to allow anyone – from bloggers, to podcasters, small business owners, and enterprises – to build and manage support bots for Telegram. These support bots allow charging a fee in order to delete Owner`s branding in Telegram channels and groups. Our mission is to democratize support bots.
This Privacy Policy applies to information that we collect about you when you use:
- Our website;
- Our Telegram bot (@SUCH or @SuchChatBot);
- Other user’s support Telegram bots that use our Services.
Throughout this Privacy Policy we’ll refer to our website and Telegram bots collectively as “Services”.
Please note that this Privacy Policy does not apply to any of our products or services that have a separate privacy policy, including services of third-parties’. Υou have to study their policies before commencement any work with them as we assume no responsibility for it. Within that we would like to separately pay your attention that we bear no responsibility for quality of their services, any money refunds or non-refunds and the way they process any confidential and/or private information about you. Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.
Creative Commons Sharealike License
This document is based upon the Automattic Privacy Policy and is licensed under Creative Commons Sharealike. Basically, this means you can use it verbatim or edited, but you must release new versions under the same license and you have to credit Automattic somewhere. Automattic is not connected with and does not sponsor or endorse SUCH or its use of the work.
Information We Collect
We only collect information about you if we have a reason to do so, for example, to provide our Services, to communicate with you or to make our Services better. We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
- Support Bot Information: If you use our Services to sell products or services to others through your support bot built with SUCH Platform, you will have to create an SUCH project (or several) and provide us with some information to make your support bot work. This may include project name, description, resources (like private Telegram channels and supergroups), subscription plans (names, description, prices, included resources). You may also provide us with some extra information about your account at 3rd-party payment provider to set up an integration.
- Content Information: Depending on the Services you use, you may also provide us with information about you in draft and published content (such as for your support bot). For example, if you write your support bot description that includes biographic information about you, we will have that information, and so will anyone with access to the Internet.
- Credentials: Depending on the Services you use, you may provide us with e-mail, country, credentials for your Telegram bot (API token) and your payment provider accounts.
- Communications With Us: You may also provide us information when you respond to surveys, communicate with our team about a support question, or post a question about your site in our public forums.
Information We Collect Automatically
We also collect some information automatically:
- Log Information: Like most online service providers, we collect information that web browsers, mobile devices, and servers typically make available, such as the browser type, IP address, unique device identifiers, language preference, referring site, the date and time of access, operating system, and mobile network information. We collect log information when you use our Services, for example, when you browse our website or create/make changes to your support bots with @SUCH.
- Usage Information: We collect information about your usage of our Services. For example, we collect information about the actions that support bot administrators and users perform, in other words, who did what, when and to what thing on our website, our Telegram bot (@SUCH) or support bots built with SUCH Platform (e.g., [Telegram user ID] created a new subscription plan “[title of plan]” at [time/date]). We use this information to, for example, provide our Services to you, as well as get insights on how people use our Services, so we can make our Services better.
- Information from Cookies & Other Technologies: A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Pixel tags (also called web beacons) are small blocks of code placed on websites and emails. SUCH uses cookies and other technologies like pixel tags to help us identify and track visitors, usage, and access preferences for our Services, as well as track and understand email campaign effectiveness and to deliver targeted ads.
Information We Collect from Other Sources
- Telegram Profile: When you open @SUCH (or one of our user`s support bots for the first time) or log in using Telegram Login Widget on our website, we collect information about your Telegram profile that we receive from Telegram. This includes your Telegram user ID and may include your first and last name, username and language code.
- Payment providers: We may also get information from payment providers that you integrate with SUCH Platform in order to accept payments from your customers with your support bot. For example, if you connect your payment provider account (like Stripe via Stripe Connect), we will receive information from that service (such as API keys, account ID) via the authorization procedures used by that service. The information we receive depends on which services you authorize and any options that are available.
- Amplitude Analytics: Trackers; Usage Data;
- Amazon Web Services (AWS): Various types of Data as specified in the privacy policy of the service.
Information We Do Not Collect
- Payment Information: SUCH does not process payments from users and instead relies on different payment providers around the world (like Stripe). It is the payment providers that handle and store your credit card details. Neither SUCH nor Telegram have access to this information. Although we work with payment providers they are completely independent from SUCH. Please study their relevant privacy policies before making your data available to them.
- We do not collect or process any sensitive data, that is also prohibited by Art. 9 GDPR, unless it is required by applicable law of jurisdiction, for example, in the event of court order. Under most circumstances, the types of data listed below will not be processed:
- race or ethnic origin;
- political opinions;
- religious or philosophical beliefs;
- trade union memberships;
- genetic or biometric data;
- health or mortality;
- sex life or sexual orientation.
How And Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
- To provide our Services, for example, to set up, host and maintain your support bot, backup and restore your support bot, or charge you for any of our paid Services;
- To further develop and improve our Services, for example by adding new features that we think our users will enjoy or will help them to create and manage their support bots more efficiently;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, for example, we may analyze how many individuals purchased a plan after receiving a marketing message or the features used by those who continue to use our Services after a certain length of time;
- To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of SUCH and others, which may result in us declining a transaction or the use of our Services;
- To communicate with you, for example, through an email, about offers and promotions offered by SUCH and others we think will be of interest to you, solicit your feedback, or keep you up to date on SUCH and our products; and
- To personalize your experience using our Services, provide recommendations, target our marketing messages to groups of our users (for example, those who have a particular plan with us or have been our user for a certain length of time), and serve relevant advertisements.
Legal Bases for Collecting and Using Information
A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:
- the use is necessary in order to fulfill our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account, for example, in order to enable access to our SUCH website on your device or charge you for a paid plan; or
- the use is necessary for compliance with a legal obligation;
- the use is necessary in order to protect your vital interests or those of another person; or
- we have a legitimate interest in using your information, for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
- you have given us your consent.
For more understanding of how we collect your personal data we placed the conform information in table below:
Information Collected
Data you voluntary provide to us, such as:
- your e-mail;
- country;
- your billing address;
- VAT number;
- API keys from payment systems;
- your payment information: -4 last numbers of the bank card; -period of validity of the bank card; -country issued the bank card; -type of the bank card;
your support bot information, including content information.
Your Telegram profile
Data we receive automatically, such as:
- log information:
- IP-address;
- information about operational system;
- information about Internet browser;
- information about your device (unique device identifiers);
- language preference;
- referring site;
- the date and time of access;
- mobile network information
- usage information (actions that support bot administrators and users perform);
- information from cookies.
Information about accounts in payment systems, transactions, recurrent subscription.
Information about your customers:
- e-mail;
- Telegram profile;
- IP-address;
- information about operational system;
- information about Internet browser;
information about your device.
Statistical data not identifying you exactly, such as your region, country, city, town (without information about your exact location).
Information you provide to our support team.
Purpose or Collection of Data
- To provide our Services;
- To charge you for any of our paid Services;
- To resolve your claims;
- To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use;
- To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition;
- Technical and statistical purposes.
- To further develop and improve our Services, for example by adding new features that we think our users will enjoy or will help them to create and manage their support bots more efficiently;
- To personalize your experience using our Services, provide recommendations, target our marketing messages to groups of our users and serve relevant advertisements;
- To provide our Services, for example, to set up and maintain your support bot, backup and restore your support bot or charge you for any of our paid Services.
- To provide our Services;
- To communicate with you, for example, through an email, about offers and promotions offered by SUCH and others we think will be of interest to you, solicit your feedback, or keep you up to date on SUCH and our products;
- To verify your identity and to fulfil your support request, to provide you support, including to help identify and troubleshoot problems with your support bot, to survey your opinions through surveys or questionnaires;
- To investigate any complaints and to provide you with a more efficient Services.
Legal Basis for processing of Data
Performance of the contract
Legitimate interest
Sharing Information
How We Share Information
We do not sell our users’ private personal information. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
- Subsidiaries, Employees, and Independent Contractors: We may disclose information about you to our subsidiaries, our employees, and individuals who are our independent contractors that need to know the information in order to help us provide our Services or to process the information on our behalf. We require our subsidiaries, employees, and independent contractors to follow this Privacy Policy for personal information that we share with them.
- Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (like payment providers that process your credit and debit card information, fraud prevention services that allow us to analyze fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you, registrars, registries, and data escrow services that allow us to provide domain registration services, those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns), those that help us understand and enhance our Services (like analytics providers), and companies that make products available on our websites, who may need information about you in order to, for example, provide technical or other support services to you. We require vendors to agree to privacy commitments in order to share information with them. Other vendors are listed in our more specific policies.
- Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.
- To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of SUCH, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
- Business Transfers: In connection with any merger, sale of company assets, or acquisition of all or a portion of our business by another company, or in the unlikely event that SUCH goes out of business or enters bankruptcy, user information would likely be one of the assets that is transferred or acquired by a third party. If any of these events were to happen, this Privacy Policy would continue to apply to your information and the party receiving your information may continue to use your information, but only consistent with this Privacy Policy.
- With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties with which you authorize us to do so.
- Aggregated or De-Identified Information: We may share information that has been aggregated or reasonably de-identified, so that the information could not reasonably be used to identify you. For instance, we may publish aggregate statistics about the use of our Services.
Information Shared Publicly
Information that you choose to make public is disclosed publicly. That means, of course, that information like your support bot name, URL and description, set of subscription plans with names, prices and list of included benefits, are all available to others. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share.
For more understanding of who can receive your personal data we placed the conform information in table below:
Information Collected
Data you voluntary provide to us, such as:
- your e-mail;
- your billing address;
- country;
- VAT number;
- API keys from payment systems;
- your payment information:
- 4 last numbers of the bank card;
- period of validity of the bank card;
- country issued the bank card;
- type of the bank card;
- your support bot information, including content information.
Data we receive automatically, such as:
- log information:
- IP-address;
- information about operational system;
- information about Internet browser;
- information about your device (unique device identifiers);
- language preference;
- referring site;
- the date and time of access;
- mobile network information
- usage information (actions that support bot administrators and users perform);
- information from cookies.
Information about accounts in payment systems, transactions, recurrent subscription.
Information about your customers:
- e-mail;
- Telegram profile;
- IP-address;
- information about operational system;
- information about Internet browser;
- information about your device.
Statistical data not identifying you exactly, such as your region, country, city, town (without information about your exact location).
Information you provide to our support team.
Source of personal data:
From you directly
Amazon Web Services
Payment systems
Advertisement networks
Intercom entity
Your Telegram profile
Directly from your device
From payment systems
From Telegram LLC, Telegram FZ-LLC or any affiliate company
Recipients of personal data
Amazon Web Services
Payment systems
Advertisement networks
All users of the Services
Legal Basis for processing of Data
Performance of the contract
Legitimate interest
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it, which are described in the section above on How and Why We Use Information, and we are not legally required to continue to keep it.
Security
While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks. To enhance the security of your account, we encourage you to enable advanced security settings, like Two Step Authentication in Telegram.
Choices
You have several choices available when it comes to information about you:
- Limit the Information that You Provide: If you have an account with us, you can choose not to provide the optional account information and optional profile information. Please keep in mind that if you do not provide us with information, which is obligatory need to provide you Services, certain features of our Services, for example, payment integration, may not be accessible, because we have no opportunity to provide such services to you.
- Opt-Out of Electronic Communications: You may opt out of receiving promotional messages from us. Just follow the instructions in those messages. If you opt out of promotional messages, we may still send you other messages, like those about your account and legal notices.
- Set Your Browser to Reject Cookies: At this time, SUCH does not respond to “do not track” signals across all of our Services. However, you can usually choose to set your browser to remove or reject browser cookies before using SUCH’s website, with the drawback that certain features of SUCH’s website may not function properly without the aid of cookies.
- Close Your Account: While we’d be very sad to see you go, if you no longer want to use our Services, you can close your SUCH account. To do that, delete all the projects you've created with @SUCH. Please, keep in mind that we may continue to retain your information after closing your account, when that information is reasonably needed to comply with (or demonstrate our compliance with) legal obligations such as law enforcement requests, or reasonably needed for our legitimate business interests, or we have other legal basis to process this information.
Your Rights
If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation, data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including:
- Right to access your personal information: at any time, you can ask us about what your personal data do we have, what do we do with them, why do we process them, who we have told about you, etc. You also can ask us to give you a copy of the personal data processing, if you like;
- Right to rectify your personal information: at any time, you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or there is no need to proceed it anymore;
- Right to erasure: at any time, you can ask us to delete all the personal data that we have about you – it is your right to be forgotten. We will also deactivate your account. If you do so, you will no longer have access to the Services associated with your account;
- Right to restrict the use of your personal information: for example, if you think, that your personal data is not accurate and we need time to check it, we can make a pause in processing of your personal data enough to clarify, is it so or not. If you do not request deletion, then it is possible to request the reactivation of your account if it was accidentally or wrongfully deactivated. Please, note, that we cannot restore permanently deleted accounts*;*
- Right to object to processing of your personal information: at any time, you can tell us to stop and we will no longer process your personal data, but we can still keep them if there is legitimate basis (ground) for that;
- Right to data portability (in certain specific circumstances): if you wish, you can ask us to download (export) all personal data that we have in the format acceptable to give it to someone else or ask us to give them your data directly;
- Right not to be subject to an automated decision: if we process your personal data automatically and we take some decisions according to it, and it affects you in any serious way, you can express your point of view and contest such decision;
- Right to lodge a complaint with a supervisory authority: you always can complain about us and about the way, we are processing your personal data.
Before we process any request, we may ask you for certain information in order to verify your identity. Where permitted by local law, we may reject requests that are unreasonable or impractical. We will respond to your requests in a reasonable timeframe. You can usually access, correct or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.
Controller and Responsible Company
(a) If User is located in EU countries as well as the UK:
DEV WAY LTD
165, Spyrou Araouzou, Lordos Waterfront Court, Office 402, 3036 Limassol, Cyprus
E-mail: info@dw.tech
(b) If User is located anywhere else in the world:
InviteMember LLC
16192 Coastal Highway, Lewes, Delaware 19958 USA
E-mail: info@invitemember.com
DATA PROTECTION OFFICER (DPO)
InviteMember LLC and Dev Way Ltd have appointed a Data Protection Officer for the purposes of the General Data Protection Regulation (EU) 2016/679 (GDPR) and the United Kingdom General Data Protection Regulation, Retained Regulation (EU) 2016/679 (UK GDPR), who you can contact using the details set out below:
RF PRIVACY MINDERS LTD
Address: 33 Konstantinou Paleologou, 6036-Larnaca, Cyprus
Email address: info@privacyminders.com
DATA PROTECTION REPRESENTATIVES
EU Representative for InviteMember LLC
InviteMember LLC has appointed an EU Representative based in Cyprus, in accordance with art. 27 of the General Data Protection Regulation (EU) 2016/679 (GDPR) who you may address if you are located in the European Union to ask any questions about our processing of your personal data, including any requests to exercise your rights provided by the GDPR. You can contact our EU Representative using the details set out below:
RF PRIVACY MINDERS LTD
Address: 33 Konstantinou Paleologou, 6036-Larnaca, Cyprus
E-mail: invitemember.eu@privacyminders.com
UK Representative for InviteMember LLC
InviteMember LLC has appointed a UK Representative based in the United Kingdom, in accordance with art. 27 of the United Kingdom General Data Protection Regulation, Retained Regulation (EU) 2016/679 (UK GDPR), who you may address if you are located in the UK to ask any questions about our processing of your personal data, including any requests to exercise your rights provided by the UK GDPR. You can contact our UK Representative using the details set out below:
PRIVACY MINDERS (UK) LTD
71-75 Shelton Street, London WC2H 9JQ, United Kingdom
E-mail: invitemember.uk@privacyminders.com
UK Representative for Dev Way Ltd
Dev Way Ltd has appointed a UK Representative based in the United Kingdom, in accordance with art. 27 of the United Kingdom General Data Protection Regulation, Retained Regulation (EU) 2016/679 (UK GDPR), who you may address if you are located in the UK to ask any questions about our processing of your personal data, including any requests to exercise your rights provided by the UK GDPR. You can contact our UK Representative using the details set out below:
PRIVACY MINDERS (UK) LTD
71-75 Shelton Street, London WC2H 9JQ, United Kingdom
E-mail: devway.uk@privacyminders.com
Other Things You Should Know
Transferring Information
Because SUCH’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient understands the necessity to process your personal data only on legal basis and protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:
- In the case of US based entities, entering into European Commission approved standard contractual arrangements with them, or ensuring they have signed up to the EU-US Privacy Shield; or
- In the case of entities based in other countries outside the EEA, entering into European Commission approved standard contractual arrangements with them.
You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.
Ads and Analytics Services Provided by Others
Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by SUCH and does not cover the collection of information by any third party advertisers or analytics providers.
Third Parties
Please note that SUCH uses some 3-rd party software and services. We don’t own or control these third parties and they have their own rules about collection, use and sharing of information, which you should review.
- SUCH uses Telegram: Please refer to Telegram Privacy Policy.
- SUCH uses Amazon Web Services: Please refer to Amazon Web Services Privacy Policy.
- SUCH uses Stripe: Please refer to Stripe Privacy Policy.
- Other 3rd-parties: If you’d like to use other third party plugins, extensions that enable services provided by third parties, or other third party software, please keep in mind that when you interact with them you may provide information about yourself (or your site visitors) to those third parties.
Visitors to Our User`s Support Bots
We also process information about visitors, customers and clients of our users’ support bots, on behalf of our users. Please note that our processing of that information on behalf of our users for their support bots isn’t covered by this Privacy Policy. We encourage our users to post a privacy policy that accurately describes their practices on data collection, use and sharing of personal information. In this situation our users are controllers and determine the personal data shall be processed and purposes of the processing. Our user shall take appropriate measures to process of its customers’ personal data only on legal basis and protect personal information adequately in accordance with applicable law.
Children
Protecting children's privacy is extremely important. Our Services are intended for general audiences and do not knowingly collect or process any personal information from or with respect to children under 16. Through our Services, children will be able to receive local in-app notifications, which do not collect any personal information.
We will: (1) not ask children to input their personal information, (2) collect certain information for limited purposes only (consistent with applicable law), (3) block or restrict the child from accessing relevant services, if applicable.
Privacy Policy Changes
Although most changes are likely to be minor, SUCH may change its Privacy Policy from time to time. SUCH encourages you to frequently check this page for any changes to its Privacy Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on this page https://such.chat/. Important changes made to this Privacy Policy will be notified to you via Telegram or Email.
