Privacy Policy

Personal information you disclose to us

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about Algoramming Systems Ltd. or our products and Services, when you participate in activities on the Services (such as posting messages in our online forums or entering competitions, contests, or giveaways), or otherwise when you contact us.

Personal information provided by you

The personal information that 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 the following:

• Names, first and last
• Phone numbers
• Email addresses
• Mailing and shipping addresses
• Job titles and company affiliations
• Passwords (always stored hashed, never in plaintext)
• Usernames and contact preferences
• Contact or authentication data (e.g. multi-factor tokens)
• Billing addresses
• Debit/credit card numbers (handled by payment providers; we never store full PANs)

Sensitive information

When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• Health data (only when delivering health-tech projects under signed Business Associate Agreements)
• Biometric data (only in narrowly scoped authentication features you opt in to)
• Data about a person's sex life or sexual orientation
• Information revealing race or ethnic origin
• Student records (only for education-tech engagements)
• Credit worthiness data (only when relevant to a contracted service)
• Information revealing political opinions

Payment data

We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. All payment data is tokenised and stored by our payment processors, not by Algoramming Systems Ltd. You may find their privacy notices here:

• bKash: https://www.bkash.com/
• Nagad: https://nagad.com.bd/
• Stripe: https://stripe.com/
• SSLCommerz: https://sslcommerz.com/
• EPS: https://eps.com.bd/

Social media login data

We may provide you with the option to register with us using your existing social media account details, like your Facebook, X (formerly Twitter), Google, or other social media account. If you choose to register in this way, we will collect certain profile information about you from the social media provider, as described in Section 8: How do we handle your social logins?

Application data

If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

• Geolocation information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile device access. We may request access or permission to certain features from your mobile device, including bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.
• Mobile device data. We automatically collect device information such as your mobile device ID, model and manufacturer, operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model, Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
• Push notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.

Information automatically collected

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as:

• IP address (or proxy server)
• Browser and device characteristics
• Operating system and version
• Language preferences
• Referring URLs
• Device name
• Country and approximate geolocation
• Information about how and when you use our Services
• Server logs, error reports, and crash diagnostics
• Other technical information needed to keep the Services secure and reliable

Like many businesses, we also collect information through cookies and similar technologies. The information we collect includes Log and Usage Data (request metadata, pages viewed, searches), Device Data (device type, IP, hardware model, OS), and Location Data (precise or imprecise location based on the device you use).

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

We process your personal information for a variety of reasons, depending on how you interact with our Services. Specifically:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user enquiries 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 administrative information to you. 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 fulfil and manage your orders. We may process your information to fulfil and manage your orders, payments, returns, and exchanges made through the Services.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time.
• To deliver targeted advertising to you. We may process your information to develop and display personalised content and advertising tailored to your interests and location.
• 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 how they are being used so we can improve them.
• 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.

If you are located in the EU or UK

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

• Consent. We may process your 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 fulfil 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 information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests, fundamental rights, and freedoms.
• Legal obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as cooperating with law enforcement or regulatory agencies, exercising or defending our legal rights, or disclosing your information as evidence in litigation.
• Vital interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party.

If you are located in Canada

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, including for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If the information is publicly available and is specified by the regulations

We may 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 Algoramming Systems Ltd. to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API). Google Maps uses GPS, Wi-Fi, and cell towers to estimate your location. We obtain and store on your device ("cache") your location for one (1) month. You may revoke your consent anytime by contacting us at the details below.
• Payment processors. bKash, Nagad, Stripe, SSLCommerz, and EPS handle transaction details (card numbers, transaction IDs, billing addresses). Algoramming Systems Ltd. only receives confirmation of payment status, never your full card number.
• Hosting and infrastructure providers. We use reputable cloud providers (AWS, GCP, Vercel, Supabase) to host our Services. These providers process information strictly under our instructions and signed Data Processing Agreements.
• Email and communication providers. Customer-support mailboxes and transactional email delivery use established providers under TLS-encrypted connections.
• Business partners. We may share your information with our business partners to offer you certain products, services, or promotions you have asked about.
• Other users. When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity.
• With your consent. We may disclose your personal information for any other purpose with your consent.
• Legal or regulatory authorities where required by law, court order, or to protect the rights, property, or safety of Algoramming Systems Ltd., our clients, or others.

The Services may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with Algoramming Systems Ltd. and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications.

The inclusion of a link toward a third-party website, service, or application does not imply an endorsement by us. We cannot guarantee the safety and privacy of data you provide to any third-party websites. Any data collected by third parties is not covered by this Privacy Notice. You should review the policies of such third parties and contact them directly to respond to your questions.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences).

To the extent these online tracking technologies are deemed to be a "sale"/"sharing" under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described in Section 14: Do United States residents have specific privacy rights?

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include Google Analytics Demographics and Interests Reporting.

To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can also opt out of Google Analytics Advertising Features through:

• Ads Settings
• http://optout.networkadvertising.org/
• http://www.networkadvertising.org/mobile-choice

For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

As part of our Services, Algoramming Systems Ltd. offers products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, "AI Products"). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including OpenAI. Your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI products

Our AI Products are designed for the following functions:

• AI chat-bots and assistants
• Document summarisation and classification
• Content generation for internal workflows

How we process your data using AI

All personal information processed using our AI Products is handled in line with this Privacy Notice and our agreements with third-party AI Service Providers. We do not opt our customers' data into model training by default.

How to opt out

• Log in to your account settings and update your user account preferences
• Contact us using the contact information provided at the end of this notice

Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook, X, or Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this Privacy Notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal 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). No purpose in this notice will require us to keep your personal information for longer than the period of time in which users have an account with Algoramming Systems Ltd.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise 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.

Algoramming Systems Ltd. has implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. Specifically:

• Transport encryption (TLS). All traffic to our Services and contact form submissions is encrypted in transit.
• Least-privilege access. Mailboxes, databases, and admin tooling are restricted to named personnel on the project, with permissions reviewed quarterly.
• Reputable infrastructure. We use established cloud providers and follow their security best practices.
• Secrets management. Credentials and tokens are stored in encrypted vaults, never in source control or shared documents.
• Logging and monitoring. Authentication events, admin actions, and security-relevant changes are logged and reviewed.
• Incident response. We follow a documented incident-response procedure and notify affected customers and regulators within the legally required windows.

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. 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.

Algoramming Systems Ltd. does not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. 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 support@algoramming.com.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right:

1. To request access and obtain a copy of your personal information
2. To request rectification or erasure of inaccurate or no-longer-needed information
3. To restrict the processing of your personal information
4. To data portability, receiving your information in a structured, commonly used format
5. Not to be subject to fully automated decision-making that produces legal or similarly significant effects
6. To object to processing for direct marketing or where we rely on legitimate interests

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 Member State data protection authority or UK data protection authority. If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent

If we are relying on your consent to process your personal information, which may be express and/or implied depending on the applicable law, you have the right to withdraw your consent at any time. Withdrawal will not affect the lawfulness of the processing before the withdrawal.

Opting out of marketing and promotional communications

• Click the unsubscribe link in any marketing email we send
• Reply "STOP" or "UNSUBSCRIBE" to SMS messages
• Email us using the details below, we honour requests within 24 hours

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can contact us using the contact information provided, or log in to your account settings and update your user account. Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms, and/or comply with applicable legal requirements.

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 to reject cookies. If you choose to remove or reject cookies, this could affect certain features or services of our Services.

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 recognising and implementing DNT signals has been finalised. 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.

Categories of personal information we collect

We have collected the following categories of personal information in the past twelve (12) months:

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels
• Participation in customer surveys or contests
• Facilitation in the delivery of our Services and to respond to your inquiries

We will use and retain the collected personal information as needed to provide the Services or for: Category K, as long as the user has an account with us; Category L, as long as the user has an account with us.

Sources of personal information

Learn more about the sources of personal information we collect in Section 1: What information do we collect?

How we use and share personal information

Learn more about how we use your personal information in Section 2: How do we process your information?

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in Section 4: When and with whom do we share? We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

Your rights

• Right to know whether we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of: (a) targeted advertising, (b) the sale of personal data, (c) profiling that produces legal or similarly significant effects

How to exercise your rights

To exercise these rights, you can contact us by emailing support@algoramming.com or by referring to the contact details at the bottom of this document. We will honour your opt-out preferences if you enact the Global Privacy Control (GPC) opt-out signal on your browser. Under certain US state data protection laws, you can designate an authorised agent to make a request on your behalf, we may deny a request from an authorised agent that does not submit proof of valid authorisation.

Request verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. If we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verification.

Appeals

If we decline to take action regarding your request, you may appeal our decision by emailing support@algoramming.com. We will inform you in writing of any action taken or not taken in response to the appeal.

California "Shine the Light" law

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits 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. To make such a request, please submit it in writing to support@algoramming.com.

Australia and New Zealand

We collect and process your personal information under the obligations and conditions set by Australia's Privacy Act 1988 and New Zealand's Privacy Act 2020. This Privacy Notice satisfies the notice requirements defined in both Privacy Acts. At any time, you have the right to request access to or correction of your personal information. If you believe we are unlawfully processing your personal information, you have the right to submit a complaint to the Office of the Australian Information Commissioner or the Office of New Zealand Privacy Commissioner.

Republic of South Africa

You have the right to request access to or correction of your personal information. If you are unsatisfied with the manner in which we address any complaint, you can contact the Information Regulator (South Africa). General enquiries: enquiries@inforegulator.org.za. Complaints (complete POPIA/PAIA form 5): PAIAComplaints@inforegulator.org.za and POPIAComplaints@inforegulator.org.za.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. 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 Algoramming Systems Ltd. is protecting your information.

If you have questions or comments about this notice, you may email us at support@algoramming.com, call +880 1400 629698, or write to us by post at:

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, email us at support@algoramming.com with the words "Data Subject Access Request" in the subject line.