Privacy Policy

1. Personal Information We Collect and How We Collect It

We may collect personal information from you and about you. Some examples of the information we may collect, how we may collect it, how we may use it, and how we may disclose it are described below. Please note that we do not sell personal information or share personal information for targeted or cross-contextual advertising purposes.

• Account Data: If you create an account with us, we collect your name, contact information, and account credentials. If you use our Service in connection with a third-party service, that third-party will send your information to us at your direction.
  • How we may collect it: Directly from you or from a third-party
  • How we may use it: To provide, analyze, and maintain our Service; to provide support and assistance in relation to our Service; to develop and improve our Service and to conduct research; to communicate with you; to ensure the security and integrity of our Service; to ensure your identity; for legal and regulatory purposes.
  • How we may disclose it: To our contracted service providers; in connection with business transfers, for legal purposes; to our related companies; and to third-parties with which you interact or share information.
• Payment Data: Where payment is required to access the Service (e.g., if we should charge a fee to access the Platform), we may have third-party process payment information, such as a bank, credit card, or wallet information, and details regarding your transactions for us.
  • How we may collect it: Through a third-party processor (ex., Google, Apple, or a major cryptocurrency exchange or platform).
  • How we may use it: To provide, analyze, and maintain our Service; to provide support and assistance in relation to our Service; to ensure the security and integrity of our Service; for legal purposes.
  • How we may disclose it: To our contracted service providers; in connection with business transfers, and for legal purposes.
• Communication Data: If you communicate with us, such as by email, by our webpages, or on social media sites, we may collect personal information that you submit to us including your name, username, email address, any other information you voluntarily choose to provide us, and the contents of messages you send.
  • How we may collect it: Directly from you.
  • How we may use it: To provide, analyze, and maintain our Service; to provide support and assistance in relation to our Service; to develop and improve our Service and to conduct research; to communicate with you; to ensure the security and integrity of our Service; for legal purposes.
  • How we may disclose it: To our contracted service providers; in connection with business transfers, for legal purposes; and to our related companies.
• Feedback Data: Where applicable, we will collect your any information, comments, suggestions, or recommendations provided by users concerning our services, products, or overall user experience.
  • How we may collect it: Directly from you.
  • How we may use it: To provide, analyze, and maintain our Service; to provide support and assistance in relation to our Service; to develop and improve our Service and to conduct research; to ensure the security and integrity of our Service; for legal purposes.
  • How we may disclose it: To our contracted service providers; in connection with business transfers, for legal purposes; and to our related companies.
• Social Media Information: We have pages on social media sites like Instagram, Telegram, and X. When you interact with our social media pages, we collect personal information that you choose to provide to us. In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
  • How we may collect it: Directly from you or from companies that host our social media pages.
  • How we may use it: To provide, analyze, and maintain our Service; to provide support and assistance in relation to our Service; to develop and improve our Service and to conduct research; to communicate with you; to ensure the security and integrity of our Service; for legal purposes.
  • How we may disclose it: To our contracted service providers; in connection with business transfers, for legal purposes; to our related companies; and to third-parties with which you interact or share information.
• Technical Data: Technical data includes information such as your IP address, device type, country from which you access, analytics information, browser type and version, browser plug-in types and versions, and operating system. This may also include information about your use of the Service and how you interact with the Service, including the types of content you view or engage with, the features you use, pages you view and other performance-based metrics.
  • How we may collect it: Automatically when you use or interact with the Service, including through analytics tools and platforms.
  • How we may use it: To provide, analyze, and maintain our Service; to provide support and assistance in relation to our Service; to develop and improve our Service and to conduct research; to communicate with you; to ensure the security and integrity of our Service; for legal purposes.
  • How we may disclose it: To our contracted service providers; in connection with business transfers, for legal purposes; and to our related companies.
• Location data: We may determine the general area from which your device accesses our Services based on information like its IP address. Also, you may choose to provide more precise location information, such as your device’s GPS location or from third-party services that you use. We obtain your consent prior to collecting precise location information.
  • How we may collect it: Directly from you or from third-party services that you use.
  • How we may use it: To provide, analyze, and maintain our Service; to provide support and assistance in relation to our Service; to develop and improve our Service and to conduct research; to communicate with you; to ensure the security and integrity of our Service; for legal purposes.
  • How we may disclose it: To our contracted service providers; in connection with business transfers, for legal purposes; to our related companies; and to third-parties with which you interact or share information.

We do not aim to collect sensitive personal information (ex., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric data, criminal background, or trade union membership) and ask that you do not provide us with any such information.

2. How We Use Personal Information

We may use your personal information for a variety of purposes. Below, you will find examples and additional information regarding how we may use your personal information.

• To provide, analyze, develop, and maintain our Service.
• To provide support and assistance in relation to our Service.
• To develop and improve our Service and to conduct research.
• To communicate with you.
• To ensure the security and integrity of our Service.
• For legal purposes. This may include detecting what country you are located in so we can comply with relevant legal obligations.

We may also aggregate or de-identify your information so that it no longer identifies you and use this information for the purposes described above, such as to analyze the way our Service is being used, to improve and add features to them, and to conduct research. We will maintain and use de-identified information in de-identified form and will not attempt to reidentify the information, unless required by law.

3. How We Disclose Personal Information

We may disclose your personal information to others. Below, you will find examples and additional information regarding how we may disclose your personal information.

• To our contracted service providers: To assist in providing the Service to you or performing business operations, we provide your personal information to service providers including providers of hosting, cloud, analytics, content delivery, support and safety monitoring, payment and transaction, and other technology services, for the purposes described above.
• In connection with business transfers: In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company. If required by applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third-party.
• For legal purposes: To (i) comply with laws or to respond to lawful requests and legal process, (ii) protect the our rights and property and our agents, customers, and others, including to enforce our agreements, policies, and terms of service, (iii) to protect against legal liability, or (iv) to protect the our personal safety, our customers, or any person.
• To our related companies: To our related companies to the extent such sharing is necessary to fulfill a request you have submitted via our Service or for customer management, customer support, technical operations, or the purposes described above.
• To third-parties with which you interact or share information:Certain features may allow you to share information with third-parties, such as through a social media platform. Information you share with third-parties is governed by that third-party’s terms and policies.

4. Retention of Personal Information

We retain your personal information where we have an ongoing legitimate business need to do so. In certain circumstances, we will retain your information for legal reasons after our contractual relationship has ended. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement. For example, we may retain your personal information:

• When we have a legal obligation to do so (e.g., if we receive a court order, we would retain your information for longer than our usual retention periods);
• To address and resolve requests and complaints (e.g., if there is an ongoing complaint about you);
• To protect the safety, security, and integrity of our business and the Service, as well as to protect our rights and property and those of others (e.g., if we detect misuse of our Service or otherwise detect unusual activity on your account or in your interactions with us); and
• For litigation, regulatory or other legal matters (e.g., we would retain your information if there was an ongoing legal claim and the information was relevant to the claim).

5. Marketing

Except as described herein, we do not collect and use your personal information for marketing purposes and do not share your personal information with third-parties for the purpose of marketing. We may use your personal information to send you marketing emails, such as newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt-out of receiving any, or all, of these marketing communications from us by following the unsubscribe link or instructions provided in any email we send, or by contacting us.

6. Security

We implement commercially reasonable technical, administrative, and organizational measures designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security measure or method of data transmission over the internet is 100% secure. In addition, you are solely responsible for protecting your log-in and password, limiting access to your devices, and signing out of websites and accounts after your sessions.

7. Links to Other Sites

Our Service contains links to external websites or social media platforms that are not operated by us. Third-party websites and services have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to them.

8. Users Must Be At Least 18

Users of our Services must be at least 18 years old; any user under 18 is not authorized. Our Platform is not targeted to children under age 18. Additionally, we do not knowingly collect any personal information from children under 18 years of age. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases. ‍

9. Privacy Rights and Choices

Depending on where you are located and subject to applicable legal exceptions, you may have certain rights in relation to your personal information.

• You may have the right to request to access, correct, update or delete your personal information, subject to certain applicable legal exceptions.
• If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• The right to submit certain privacy requests through an Authorized Agent.
• The right to be free from discrimination for exercising the rights afforded to you under applicable privacy laws.
• The right to appeal a decision we make about your rights request.

Exercising your rights: To exercise your rights you must submit a request to legal@apso.tech and include your full legal name, date of birth, email address and username. Once you have submitted your request, we will respond within the time frame permitted by applicable privacy laws.

Please note, however, that your personal information may be exempt from such requests in certain circumstances, for example if we need to keep using your information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will inform you when responding to your request.

Verification: In order to protect your personal information, your ability to exercise some of the rights detailed in this Privacy Policy may be subject to your ability to verify that you are the person about whom your request pertains. For example, we may require you to verify your identity by validating your account credentials or submitting additional information to allow us to verify your identity.

Authorized Agents: To exercise your rights using an Authorized Agent (as defined under applicable law), you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. We reserve the right to deny a request from an Authorized Agent that does not submit proof that they have been authorized by you to act on your behalf.

Appeals: If we refuse to take action on a request within a reasonable period of time after receiving your request, you may appeal our decision by emailing us at legal@apso.tech. In such an appeal, you must (1) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (2) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under applicable law. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

Do Not Track: Please note that because the effect of "Do Not Track" signals remains unclear, and because there continues to be no consistent industry understanding of how to respond to such a signal, we do not alter our privacy practices when we detect a "Do Not Track" signal from your browser.

10. Changes

We may update our Privacy Policy from time to time. When we do, we will publish an updated version and effective date on this page, unless another type of notice is required by applicable law. If you use the Service after any changes to the Privacy Policy have been posted, all of the changes made will apply to your use of the Service.

11. European Economic Area, United Kingdom, and Switzerland Users

If you are located in the European Economic Area ("EEA"), United Kingdom ("UK") or Switzerland (collectively, "Europe") the following disclosures apply:

12. California Users

Under California Civil Code Section 1798 (“California's Shine the Light”), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes. After thorough analysis, we have determined that we are exempt from the California Consumer Privacy Act of 2018, and the later, California Privacy Rights Act of 2020 (collectively, “CCPA”).

If you'd like to request more information under the California Shine the Light law or other laws, and if you are a California resident, you can contact us using the contact information provided below.

13. Nevada Users

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us as described below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

14. Contact Us

If you have any queries or complaints about our collection, use, or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact our Data Protection Officer at legal@apso.tech or by mail using the following contact details:

Office 317, Via Ricardo J. Alfaro, PH The Century Tower, Betania, Panama, Panamá, 07095- Panama.