Privacy Policy

Effective Date: 26 October 2022

Last Updated: 3 July 2024

Introduction

At Fullyst, we are committed to respecting your privacy and complying with any applicable law and regulation regarding any personal information we may collect about you, including across our website, https://fullyst.com, and other sites we own and operate.

Information We Collect

Fullyst collects the following types of information:

User Data: Usernames, types of messages sent, content of messages (stored for up to 3 days), first and last names (if provided in Telegram profile), images, videos, stickers, emojis, voice messages, and other media files (only if the corresponding functions are enabled), chat names, usernames, chat images, and all chat data provided by Telegram to the bots.
Sensitive Data: Any sensitive personal data sent directly to the bot or in chat, whether intentionally or unintentionally.
Automated Data: Data automatically collected via the Telegram API when the bot is added to a group chat.

Legitimate Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so. In this instance, we only collect personal information that is reasonably necessary to provide our services to you.

Collection and Use of Information

We may collect personal information from you when you do any of the following on our website:

Sign up to receive updates from us via email or social media channels
Use a mobile device or web browser to access our content
Contact us via email, social media, or any similar technologies
When you mention us on social media

We may collect, hold, use, and disclose information for the following purposes, and personal information will not be further processed in a manner that is incompatible with these purposes:

to enable you to customize or personalize your experience of our website
to contact and communicate with you
for analytics, market research, and business development, including operating and improving our website, associated applications, and associated social media platforms
for security and fraud prevention, and to ensure that our sites and apps are safe, secure, and used in line with our terms of use

We use the OpenAI API for some of our services. The OpenAI privacy policy is available here: OpenAI Privacy Policy.

General Data Protection Regulation (GDPR)

We are a Data Controller of your information.

Improvy OÜ’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect the information:

Improvy OÜ needs to perform a contract with you
You have given Improvy OÜ permission to do so
Processing your personal information is in Improvy OÜ’s legitimate interests
Improvy OÜ needs to comply with the law

Improvy OÜ will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you.
The right of rectification.
The right to object.
The right of restriction.
The right to data portability.
The right to withdraw consent.

Security of Your Personal Information

When we collect and process personal information, and while we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorized access, disclosure, copying, use, or modification.

Although we will do our best to protect the personal information you provide to us, we advise that no method of electronic transmission or storage is 100% secure, and no one can guarantee absolute data security. We will comply with laws applicable to us in respect of any data breach.

You are responsible for selecting any password and its overall security strength, ensuring the security of your own information within the bounds of our services.

How Long Do We Keep Your Personal Information

We keep your personal information only for as long as we need to. This time period may depend on what we are using your information for, in accordance with this privacy policy. If your personal information is no longer required, we will delete it or make it anonymous by removing all details that identify you.

However, if necessary, we may retain your personal information for our compliance with a legal, accounting, or reporting obligation or for archiving purposes in the public interest, scientific, historical research purposes, or statistical purposes.

Children’s Privacy

We do not aim any of our products or services directly at children under the age of 13, and we do not knowingly collect personal information about children under 13.

Disclosure of Personal Information to Third Parties

We may disclose personal information to:

our employees, contractors, and/or related entities
courts, tribunals, regulatory authorities, and law enforcement officers, as required by law of the Republic of Estonia, in connection with any actual or prospective legal proceedings, or in order to establish, exercise, or defend our legal rights
third parties, including agents or sub-contractors, who assist us in providing information, products, services, or direct marketing to you

International Transfers of Personal Information

The personal information we collect is stored and/or processed where we or our partners, affiliates, and third-party providers maintain facilities. Please be aware that the locations to which we store, process, or transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries: (i) we will perform those transfers in accordance with the requirements of applicable law; and (ii) we will protect the transferred personal information in accordance with this privacy policy.

Your Rights and Controlling Your Personal Information

You always retain the right to withhold personal information from us, with the understanding that your experience of our website may be affected. We will not discriminate against you for exercising any of your rights over your personal information. If you do provide us with personal information, you understand that we will collect, hold, use, and disclose it in accordance with this privacy policy. You retain the right to request details of any personal information we hold about you.

If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such a person’s consent to provide the personal information to us.

If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time. We will provide you with the ability to unsubscribe from our email database or opt-out of communications. Please be aware we may need to request specific information from you to help us confirm your identity.

If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this privacy policy. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading, or out of date.

If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Use of Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on the preferences you have specified.

Cookies are used to provide functionality on our website. Users can decline non-necessary cookies.

Limits of Our Policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

Changes to This Policy

At our discretion, we may change our privacy policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this privacy policy, we will post the changes here at the same link by which you are accessing this privacy policy.

If required by law, we will get your permission or give you the opportunity to opt in to or opt-out of, as applicable, any new uses of your personal information.

Contact Us

For any questions or concerns regarding your privacy, you may contact us using the following details:

Improvy OÜ
10151, Ahtri 12, Tallinn, Estonia
Reg. code 16377480
Email: [email protected]