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Privacy Policy

Last updated: September 14, 2024

This privacy notice explains how and why OncuTECH ("Company", "we", "us", or "our") collects, stores, uses, and/or shares ("process") your information when you use the Chatswave mobile application ("Application"). We are committed to handling your information in accordance with this notice when you use our services. Our services include sending WhatsApp chats in zip format for analysis by ChatGPT and presenting the results through a widget.

Do you have any questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our services. If you still have questions or concerns, please contact us at [email protected].

CONTENTS

  • WHAT INFORMATION DO WE COLLECT?
  • HOW DO WE PROCESS YOUR INFORMATION?
  • WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  • WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  • WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?
  • DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  • IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
  • HOW LONG DO WE KEEP YOUR INFORMATION?
  • HOW DO WE KEEP YOUR INFORMATION SAFE?
  • DO WE COLLECT INFORMATION FROM MINORS?
  • WHAT ARE YOUR PRIVACY RIGHTS?
  • CONTROLS FOR DO-NOT-TRACK FEATURES
  • DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
  • DO WE MAKE UPDATES TO THIS NOTICE?
  • HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  • HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

We collect personal information that you provide to us. This includes the personal information you provide when you learn about us or our products and services, participate in activities on the Services, or otherwise communicate with us.

Personal Information Provided by You: The personal information we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include:

  • Texts extracted from WhatsApp chats (zip files)
  • Your email address and name (if you submit a support request)

Sensitive Information: We do not process sensitive information.

Information automatically collected

Some information, such as device and usage information, is collected automatically when you visit our Services. This information does not reveal your specific identity but may include device and usage information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect automatically includes:

  • Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and we record this in log files. This data may include your IP address, device information, browser type and settings, and information about your activities on the Services.
  • Device Data: We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. This data may include your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider or mobile carrier, operating system, and system configuration information.
  • Location Data: We collect location data, which may be precise or imprecise. How much information we collect depends on the type of device you use to access the Services and its settings. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location settings on your device.

2. HOW DO WE PROCESS YOUR INFORMATION?

We process your information to provide, improve, and manage our Services, communicate with you, ensure security and prevent fraud, and comply with the law. We may also process your information for other purposes with your consent. Depending on how you interact with the Services, we process your personal information for various reasons:

  • To provide and facilitate the delivery of services: We may process your information to provide you with the requested service.
  • To respond to user inquiries and offer support: We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  • To send you administrative information: We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  • To fulfill and manage your orders: We may process your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.
  • To request feedback: We may process your information to request feedback and to contact you about your use of our Services.
  • To protect our Services: We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
  • To identify usage trends: We may process information about how you use our Services to better understand usage patterns and improve our Services.
  • To determine the effectiveness of marketing and promotional campaigns: We may process your information to provide you with marketing and promotional campaigns that are tailored to your needs.
  • To save or protect an individual’s vital interest: We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

We only process your personal information when we believe it is necessary, and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like complying with our legal obligations, providing you with services, entering into or fulfilling our contractual obligations, or pursuing our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • Consent: We may process your personal information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.
  • Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
  • Legitimate Interests: We may process your personal information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.
  • Legal Obligations: We may process your personal information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
  • Vital Interests: We may process your personal information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to any person’s safety.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time. In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We may share your information in specific situations described in this section and/or with the following categories of third parties:

Vendors, Consultants, and Other Third-Party Service Providers: We may share your data with third-party vendors, service providers, contractors, or agents ("third parties") who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they can only use your personal information on our instructions, not share it with anyone else, and hold it securely and retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

  • Cloud Computing Services
  • Communication and Collaboration Tools
  • Performance Monitoring Tools
  • Payment Processors
  • Order Fulfillment Service Providers
  • Data Analytics Services
  • Product Engineering and Design Tools
  • Website Hosting Service Providers
  • Data Storage Service Providers
  • Finance and Accounting Tools

We may also need to share your personal information in the following situations:

  • Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • Business Partners: We may share your information with our business partners to offer you certain products, services, or promotions.
  • Offer Wall: Our applications may display a third-party-hosted "offer wall." Such an offer wall allows third-party advertisers to offer users virtual currency, gifts, or other items in return for accepting and completing an advertising offer. Such an offer wall may appear in our application and be shown to you based on certain data, such as your geographic area or demographic information. If you click on an offer wall, you will be redirected to an external website owned by other people and will leave our application. To prevent fraud and properly credit your account with the relevant reward, a unique identifier, such as your user ID, will be shared with the offer wall provider.

5. WHAT IS OUR STANCE ON THIRD-PARTY WEBSITES?

The Services and offer walls may contain links to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy notice. We are not responsible for the content, privacy, and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Services. You should review the policies of such third parties and contact them directly to respond to your questions.

6. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

We may transfer, store, and process your information in countries other than your own. Our servers are located in the United States. If you are accessing our Services from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information in the United States and other countries.

If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.

European Commission’s Standard Contractual Clauses:

We have implemented measures to protect your personal information, including by using Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information they process from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. HOW LONG DO WE KEEP YOUR INFORMATION?

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. HOW DO WE KEEP YOUR INFORMATION SAFE?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

10. DO WE COLLECT INFORMATION FROM MINORS?

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at [email protected].

11. WHAT ARE YOUR PRIVACY RIGHTS?

In some regions (like the European Economic Area (EEA), United Kingdom (UK), and Canada), you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. However, this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies and similar technologies: Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt-out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/.

If you have questions or comments about your privacy rights, you may email us at [email protected].

12. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

14. DO WE MAKE UPDATES TO THIS NOTICE?

Yes, we will update this notice as necessary to stay compliant with relevant laws. We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may email us at [email protected] or by post to:

OncuTECH
Inonu Boulevard
Famagusta, KKTC

16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances. To request to review, update, or delete your personal information, please fill out and submit a data subject request form, or contact us at [email protected].

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