Privacy Policy

Privacy Policy of Chaturbo Solutions

Chaturbo Solutions collects some Personal Data from its Users. This document contains a section dedicated to Californian consumers and their privacy rights. This document contains a section dedicated to Brazilian Users and their privacy rights. This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

Chaturbo Solutions – Level 23-1, Premier Suite One Mont Kiara, No 1, Jalan Kiara, Mont Kiara, 50480 Kuala Lumpur Owner contact email: [email protected]

Types of Data collected

Among the types of Personal Data that Chaturbo Solutions collects, by itself or through third parties, there are: Tracker; Usage Data; email address; first name; last name; phone number; payment info; Data communicated while using the service; various types of Data. Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Chaturbo Solutions. Unless specified otherwise, all Data requested by Chaturbo Solutions is mandatory and failure to provide this Data may make it impossible for Chaturbo Solutions to provide its services. In cases where Chaturbo Solutions specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner. Any use of Cookies – or of other tracking tools – by Chaturbo Solutions or by the owners of third-party services used by Chaturbo Solutions serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available. Users are responsible for any third-party Personal Data obtained, published or shared through Chaturbo Solutions and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Chaturbo Solutions (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies: Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law; provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof; processing is necessary for compliance with a legal obligation to which the Owner is subject; processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner; processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party. In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data. If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore: Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed. Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner. The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Access to third-party accounts, Analytics, Contacting the User, Hosting and backend infrastructure, Handling payments, Remarketing and behavioral targeting, Advertising, Registration and authentication, Tag Management and Interaction with live chat platforms. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Google API Services User Data Policy

Our app complies with the Google API Services User Data Policy, including the Limited Use requirements. We understand the importance of protecting user data and have implemented measures to ensure compliance with the policy. We only use user data for the purposes outlined in our privacy policy and do not share or sell user data to third parties. By using our app, you acknowledge and agree to our compliance with the Google API Services User Data Policy. Google Drive: We only read the list of Spreadsheets to allow you to select the Spreadsheet you want to work with. Google Sheets: We allow you to get data and update your Spreadsheet. Google Calendar: We read the list of events on your calendar to avoid overbooking. Also, we add events to your Calendar when a customer book an appointment. Dialogflow: we use Dialogflow to allow you to automate customer services using Dialogflow. We only use Dialogflow to detect user intents. Chaturbo use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy , including the Limited Use requirements.

Facebook permissions asked by Chaturbo Solutions

Chaturbo Solutions may ask for some Facebook permissions allowing it to perform actions with the User’s Facebook account and to retrieve information, including Personal Data, from it. This service allows Chaturbo Solutions to connect with the User’s account on the Facebook social network, provided by Facebook Inc. For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy. The permissions asked are the following: Basic information By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available. About Me Provides access to the ‘About Me’ section of the profile. Business Management API Read and write with Business Management API. Contact email Access the User’s contact email address. Instagram basic Allows reading an Instagram account profile information and media. Instagram manage comments Allows the creation, deletion and hiding of comments on behalf of the Instagram account linked to a Page. Also allows reading and responding to public media and comments that a business has been photo tagged in or @mentioned in. Manage Pages Enables the application to retrieve access_tokens for Pages and Applications that the User administrates. Managing Page Advertisements Allows managing advertisements associated with the Page. Page Messaging Send and receive messages through a Facebook Page. Pages manage engagement Allows creating, editing and deleting comments posted on the page. Pages manage metadata Allows subscribing and receiving webhooks about activity on the Page, and updating settings on the Page. Pages manage posts Allows the creation, editing and deletion of the User’s Page posts. Pages read engagement Provides access to content (posts, photos, videos, events) posted by the Page, access to followers data (including name, PSID), and profile picture, and access to metadata and other insights about the Page. Pages User locale Provides access to the User’s locale through the connected Page. Pages User timezone Grants access to a User’s time zone through the connected Page. Show List of Managed Pages Provides the access to show the list of the Pages that the User manages.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following: Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data. Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below. Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing. Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected. Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it. Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof. Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.