1. PERSONAL DATA WE DO NOT COLLECTED

• WE DO NOT COLLECT NEITHER HAVE ACCESS TO THE CONTENTS OF YOUR TELEGRAM CHATS that you send and receive through the Service (“Telegram Content Data”). We use TDlib, the open-source infrastructure of Telegram for our app. As such, we are not manage messaging and encryption, telegram does it. More info here: https://core.telegram.org/tdlib

2. PERSONAL DATA WE COLLECT

When you contact us or interact with our Service, we may collect personal data as follows:

Personal Data You Provide

• Your handle & Telegram ID, when you register for our Service, sign up for our mailing list, or otherwise communicate with us; this information may include your name, email address, and phone number. We may also collect employment-related information if you are a representative of one of our business customers.
• Your payment information, when you enroll in one of our plans or otherwise make a purchase on the Service. This information is processed by our payment service provider, Stripe, which may handle your payment information in accordance with its own privacy policy (https://stripe.com/privacy). We do not have access to your full payment card information.
• Customer Support queries that we exchange with you, including when you participate in any interactive features of the Service, fill out a form, apply for a job, request customer support, or otherwise communicate with us or interact with the Service.
• Marketing information, such as your preferences for receiving our marketing communications and details about your engagement with them.

Personal Data You Provide

If you do not agree to any updates or modifications to the Privacy Notice, you may stop accessing and using the Linkko Service.  Your continued use of the Linkko Service after the applicable effective date of the revised Privacy Notice, signifies to us that you acknowledge and agree to be bound by the revised Privacy Notice.

Personal Data Collected Automatically

When you access or use the Service, we, our service providers may automatically log and combine information about you, your computer or mobile device, and your interactions over time with the Service, online resources, and our communications, including:

• TGPro content. We collect information from TGPro product features, including the content of notes, drafts, tags, or followups you create in the Service.
• Use of the Site and App. When you visit, use, and interact with the Site or App, we may receive certain information about your visit, use or interactions. For example, we may monitor the number of people that visit our Site or App, peak hours of visits, which page(s) are visited on our Site, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), which browsers people use to access and visit our Site (e.g., Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and Site-navigation pattern. In particular, the following information is created and automatically logged in our systems:

• Log data: Information that your browser automatically sends whenever you visit the Site (“Log Data”). Log data includes your Internet Protocol (“IP”) address (so we understand which country you are connecting from when you visit the Site), browser type and settings, the date and time of your request, and how you interacted with the Site.

• Cookies: Please see the Cookie Policy to learn more about how we use cookies on the Site.

• Device information: Includes the operating system and browser you are using. Information collected may depend on the type of device you use and its settings.

• Usage information: We collect information about how you use our Site and App, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency and duration of your activities.

3. HOW WE USE PERSONAL DATA

We use personal data for the following purposes or as otherwise described at the time of collection:

• To provide the Service and perform our contract with you under our Terms of Service, including:
• To authenticate users, provide the Service and related support, process transactions, and respond to your inquiries, requests, comments or feedback;
• To update and synchronize Service features across multiple devices (i.e., so a draft email you begin on one device will be available on your other device(s)); and
• To manage our relationship with you, which includes sending administrative information to you relating to our Service and changes to our terms, conditions, and policies and sending account verification or technical/security notices.
• To improve, monitor, personalize, and protect our Service for the following legitimate business interests:
• To analyze how you and others interact with our Service and provide, maintain and improve the content and functionality of the Service and our customer relationships and experiences, develop our business and inform our marketing strategy;
• To conduct research and aggregate personal data, to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.
• To enforce our agreements, comply with legal obligations, and to defend us against legal claims or disputes in our legitimate interests, including:
• To administer and protect our business and the Service, prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks (including troubleshooting, testing, system maintenance, support, and hosting of data); and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety or property, and/or that of our affiliates, you or other third parties, and recover debts due to us.
• For marketing and advertising purposes. We, our service providers, and our third-party advertising partners may collect and use personal data for the following marketing and advertising purposes:
• Direct marketing. We may send you direct marketing communications that we believe will be of interest to you, as permitted by law, on Telegram. For instance, promotional information about our products and Service. You may opt out of our marketing communications as by reaching out to us.

4. HOW WE DISCLOSE PERSONAL DATA

In certain circumstances we may disclose personal data to third parties without further notice to you, unless required by the law, as set forth below:

• Vendors and Service Providers. To assist us in meeting business operations needs and to perform certain services and functions, we may disclose personal data to service providers, including hosting, debugging services, email and productivity services, survey providers, database and sales/customer relationship management services, customer service providers, payment processors, web and app analytics services, and data brokers. We may also disclose personal information to AI service providers that provide AI-enabled features of the Service. Pursuant to our instructions, these parties will access, process, or store personal data in the course of performing their duties to us.
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
• Advertising partners. Third-party advertising companies, including for the interest-based advertising purposes described above.
• Business transferees. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your personal data and other information may be disclosed in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
• Authorities and others. Law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above, including to (i) comply with legal or regulatory obligations, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Site or the public, or (v) protect against legal liability.

5. PRIVACY RIGHTS AND CHOICES

Opt out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt out or unsubscribe instructions in the communications you receive from us or by contacting us here. You may continue to receive Service-related and other non-marketing emails.

Personal data requests. We offer you choices that affect how we handle the personal data that we control. Depending on your location and the nature of your interactions with our Service, you may request the following in relation to your personal data:

• Information about how we have collected and used personal data. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal data that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
• Correction of personal data that is inaccurate or out of date.
• Deletion of personal data that we no longer need to provide the Service or for other lawful purposes.
• Opt out of selling or sharing your personal data for interest-based advertising. We share personal data with advertising partners that display targeted advertisements to users around the web. This may constitute “selling” or “sharing” personal information or “targeted advertising” under applicable laws. You can opt-out of our use or sharing of personal information for these purposes as described in our Cookie Policy, by enabling the Global Privacy Control setting within the browser that you use to access our Service. Learn more at the Global Privacy Control website. Please note that your opt out will be specific to the device and browser you use when you opt out. We do not have actual knowledge that we have sold or shared the personal information of children under the age of 16.
• Additional rights, such as to object to and request that we restrict our use of personal data.

To exercise these privacy rights, or if you have any questions about we handle your personal data, please contact us here. Depending on your jurisdiction, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

6. DATA RETENTION

We keep personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, in accordance with our retention policies, applicable laws, and regulatory obligations, or until you withdraw your consent (where applicable).

To determine the appropriate retention period for your personal data, we will consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we use your personal data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

7. CHILDREN'S PRIVACY

Our Service is not directed to children who are under the age of 16. TGPro does not knowingly collect personal data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided personal data to TGPro through the Service please contact us here.

7. DATA TRANSFERS

You will provide personal data directly to our website based in Singapore. We may also transfer personal data to our partners and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country.

When we engage in cross-border data transfers, we will ensure that relevant safeguards are in place to afford adequate protection for personal data and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of personal data.

8. CHANGES TO THE PRIVACY POLICY

The Service and our business may change from time to time. As a result, we reserve the right to modify this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with personal data after we have posted an updated Privacy Policy, you consent to the revised Privacy Policy and practices described in it.

9. CONTACT US

Responsible entity. TGPro is the entity responsible for the processing of personal data under this Privacy Policy (as a controller, where provided under applicable law).

Contact us. If you have any questions about our Privacy Policy or the information practices of the Site, please feel free to contact us here.

10. COOKIE POLICY

This Cookie Policy explains how TGPro uses cookies and similar technologies in connection with our Service.

If you have any questions or concerns about the Cookie Policy, please contact us here.

What are cookies and similar technologies?

• Cookies are text files that websites store on a visitor's device to uniquely identify the visitor's browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand activity, and patterns and facilitating online advertising.
• Local storage technologies, like HTML5, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked. There are various types of web beacons or pixels, including image pixels (which are small graphic images) and JavaScript pixels (which contains JavaScript code). When you access a service that contains a pixel, the pixel may permit us or a separate entity to drop or read cookies on your browser, or collect other information about your visit.

How do we use cookies and other similar technologies?

We use both persistent cookies and session cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. We use persistent cookies, for example, to record your choice of language and country location. The cookies placed through your use of our website are either set by us (first-party cookies) or by a third party at our request (third-party cookies).

We also allow our advertising partners to collect this information through our Site.

What types of cookies do we use?

We use the following categories of cookies:

• Essential cookies. These cookies are required to enable basic website functionality. They cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Service may not work.
• ‍Marketing cookies. These cookies are used to deliver advertising that is more relevant to you and your interests. They may also be used to limit the number of times you see an advertisement and measure the effectiveness of advertising campaigns. Advertising networks usually place them with the our permission.We work with agencies, advertisers, ad networks, and other technology services to place ads about our products and services on other websites and services. For example, we place ads through Google and Facebook that you may view on their platforms as well as on other websites and services.
  
  As part of this process, we may incorporate tracking technologies into our own Service as well as into our ads displayed on other websites and services. Some of these tracking technologies on our Website and within our emails and advertisements may track your activities across time and services for purposes of associating the different devices you use, and delivering relevant ads and/or other content to you.
• Personalization cookies. These cookies allow the website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. For example, a website may provide you with local weather reports or traffic news by storing data about your current location.
• Analytics cookies. We use analytics cookies that allow us to recognize and count the number of visitors and to see how visitors move around the Website when they are using it. This helps us to improve the way our Website works, for example by making sure users are finding what they need easily. The collected data provides us only with anonymous traffic statistics (like number of page views, number of visitors, and time spent on each page). Examples of the third-party analytics cookies we use include Google Analytics. Specifically, we use Google Analytics to collect information about how users use our services, which we then use to compile reports that disclose trends without identifying individual visitors and help us improve our services. For more information on Google Analytics, click here. For more information about Google's privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

How can you control the use of cookies?

Depending on the location from where you access the Service, you may be presented with a cookie banner or other tool to provide permissions prior to non-Essential cookies being set. In this case, we only set these non-Essential cookies with your consent.

You can also limit online tracking by:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Use the following links to learn more about how to control cookies and online tracking through your browser:
• ‍Firefox; Chrome; Microsoft Edge; Safari (Mac); Safari (Mobile/iOS)
  
• Blocking advertising ID use in your mobile settings. Your mobile device settings can provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave,or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin,and configuring them to block third-party cookies/trackers.
• Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
• Digital Advertising Alliance for Websites: outout.aboutads.info
• Network Advertising Initiative: optout.networkadvertising.org
• Platform opt-outs. Some of our advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising, including:
• Google
• Facebook

Note that, because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.