Privacy Policy
Your privacy is important to us. We have prepared this Privacy Policy to explain how we collect, use, protect, and disclose Personal Information and Usage Data when you use the aiduck.org website, our Telegram bots, AI-powered course agents, and any related media (collectively, "Service"). This Privacy Policy also explains your choices for managing your information and your preferences.
This Privacy Policy may be revised from time to time. By using the Service, you agree to be bound and to abide by the most recent version of this Privacy Policy.
700 North Fairfax Str. STE 614, Alexandria, Virginia 22314, USA
Email: [email protected]
Information We Collect and How We Collect It
Personal Information
You can access public content of the Service without providing us with any information that identifies or may be used to directly identify you ("Personal Information").
We collect Personal Information when you register for or interact with the Service:
- Telegram user ID, username, and display name,
- email address (if provided during purchase),
- messages you send to our Telegram bots in private chats and course group chats ("PODs"),
- course interactions: homework logs, submitted artifacts, and completion data,
- AI-generated observations about your learning progress (e.g., strengths, preferences, milestones), used to personalize coaching.
We collect Personal Information when you pay for the Service:
- payment processor identifier.
We collect Personal Information only if you choose to share it with us. The decision to provide this information is optional. However, if you choose not to provide the requested information, you may not be able to use certain features of the Service.
Usage Data
We automatically collect usage information that does not directly identify an individual user ("Usage Data"). For example, each time you use the Service we may automatically collect the type of Web browser you use, your operating system, your Internet Service Provider, your IP address, the links you use, and the time and duration of your use of the Service. We use this Usage Data to help us understand how people use the Service and to enhance the services we offer.
Cookies and Tracking Technologies
We use cookies (a small text file placed on your computer to identify your computer and Web browser when you use the Service). We may also use Web beacons (electronic files placed on a website that monitors usage).
We use the following types of cookies:
- Essential Cookies: Required for the Service to function (e.g., session management, authentication). These cannot be disabled.
- Analytics Cookies: Used to understand how visitors interact with the Service. These collect anonymized usage data and do not identify you individually.
We do not use cookies or Web beacons to collect Personal Information. We use cookies and Web beacons to improve the quality of the Service. Most Web browsers are initially set up to accept cookies. You can reset your Web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Service may not work if you delete or disable cookies.
Storage of Information
The information we collect about you and your usage of the Service will be transmitted to and stored on servers located in the European Union.
How We Use Information and When We May Share Information
Generally
We generally use Personal Information only for purposes of providing and communicating with you about the Service, including responding to your requests, notifying you of new products or services, and otherwise communicating with you about the Service. We will not disclose Personal Information to third parties without your consent, except in cases explained in this Privacy Policy.
We use your information for the following purposes:
| Purpose | Legal Basis (GDPR) |
|---|---|
| Providing and operating the Service | Performance of contract |
| Processing payments | Performance of contract |
| Sending service-related communications | Performance of contract |
| Personalizing AI coaching using observations about your learning progress | Performance of contract |
| Sending marketing communications | Your consent (you may opt out at any time) |
| Analytics and service improvement | Legitimate interest |
| Security and fraud prevention | Legitimate interest |
| Complying with legal obligations | Legal obligation |
Service Providers
From time to time, we may establish a business relationship with other businesses whom we believe trustworthy and who have confirmed that their privacy practices are consistent with ours ("Service Providers"). We provide our Service Providers with only the information necessary for them to perform these services on our behalf. Each Service Provider must agree to use reasonable security procedures and practices, appropriate to the nature of the information involved, in order to protect your Personal Information from unauthorized access, use, or disclosure.
We share data with the following Service Providers:
| Service Provider | Data Shared | Purpose |
|---|---|---|
| Stripe | Email address, payment metadata | Payment processing |
| Telegram FZ-LLC | Telegram user ID, username, message content | Message delivery and bot operation |
| Google LLC (Gemini API) | Message content sent to AI agents | AI inference for automated coaching agents (per Google API Terms, content is not used to train Google's models) |
| EU-based hosting provider | All Service data | Server hosting |
When you make payments, your information is transmitted securely to Stripe, our trusted third-party payment provider. This provider handles the collection and processing of your payment information independently from us. We do not retain or store any payment card information provided by you.
When you first pay for the Service, your email address will be automatically provided to us by the payment provider. This is necessary for establishing your account and granting you access to the Service.
You can request anytime a report to learn whether and what Personal Information you provided has been shared with Service Providers.
Standard Analytics Information
We may use, and disclose to third parties, certain Usage Data regarding the Service. However, such information does not identify you individually.
Other Transfers
We may share Personal Information and Usage Data with businesses controlling, controlled by, or under common control with Pixel Rainbow Inc. If Pixel Rainbow Inc. is merged, acquired, or sold, or in the event of a transfer of some or all of our assets, we may disclose or transfer Personal Information and Usage Data in connection with such transaction. You will have the opportunity to opt-out of any such transfer if we determine, at our discretion, that the new entity plans to handle your information in a way that differs materially from this Privacy Policy.
Compliance with Laws and Law Enforcement
We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We may disclose Personal Information and any other information about you to the government or law enforcement officials or private parties if, at our discretion, we believe it is necessary or appropriate to respond to legal requests (including court orders and subpoenas); to protect the safety, property, or rights of Pixel Rainbow Inc., any user of the Service, or any third party; to prevent or stop any illegal, unethical, or legally actionable activity; or to comply with the law.
Data Retention
We will hold your Personal Information on our systems for as long as is necessary for the relevant activity. If you cancel your registration and your account is deleted, we will no longer use the Personal Information, but for administration purposes it will stay on our system for a period of one year by default before being deleted. Personal Information would be deleted immediately upon your request.
| Data Category | Retention Period |
|---|---|
| Account information (Telegram ID, username, email) | Duration of account, plus 1 year after deletion |
| Course messages, homework logs, and AI observations | Duration of the course, plus 6 months |
| Payment records | Up to 7 years (as required by tax and financial regulations) |
| Usage and analytics data | Up to 26 months |
After these periods, data is permanently deleted or anonymized.
Security
We are very concerned about safeguarding the confidentiality of your Personal Information. We employ reasonable physical and electronic measures designed to protect your information from unauthorized access, including:
- Encryption of data in transit (TLS/SSL)
- Access controls limiting data access to authorized personnel
- Regular monitoring of our systems for security vulnerabilities
However, no data transmission over the Internet or other network can be guaranteed to be 100% secure. While we strive to protect information transmitted on or through the Service, we cannot and do not guarantee the security of any information you upload, store, share, transmit, or provide on or through the Service, and you do so at your own risk.
Your Privacy Rights - California Residents (CCPA/CPRA)
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA/CPRA"), provides you with the following rights:
- Right to Know: You may request the categories and specific pieces of personal information we have collected about you, the sources, the purposes, and the third parties with whom we shared it.
- Right to Delete: You may request that we delete your personal information, subject to certain exceptions (e.g., legal obligations, ongoing transactions).
- Right to Correct: You may request correction of inaccurate personal information.
- Right to Opt-Out of Sale/Sharing: We do not sell your personal information and do not share it for cross-context behavioral advertising. Therefore, there is no need to opt out, but we honor opt-out requests as a matter of policy.
- Right to Limit Use of Sensitive Personal Information: You may request that we limit the use of sensitive personal information to purposes necessary to provide the Service.
- Right to Non-Discrimination: We will not discriminate against you for exercising any of your privacy rights.
How to Submit a Request:
Email us at [email protected] with the subject line "California Privacy Request." Please include your name and email address associated with your account.
Verification: To protect your privacy, we will verify your identity before fulfilling your request. We will match the information you provide with the information we have on file. If we cannot verify your identity, we may ask for additional information.
Response Time: We will respond to verified requests within 45 days. If we need additional time, we will notify you and may extend the response period by up to 45 additional days (90 days total).
Authorized Agents: You may authorize an agent to submit a request on your behalf by providing a signed written authorization or a power of attorney.
Disclosure for the Past 12 Months:
| Category | Collected | Sold | Shared for Advertising | Disclosed for Business Purpose |
|---|---|---|---|---|
| Identifiers (Telegram ID, email, username) | Yes | No | No | Yes (Stripe, Telegram, Google Gemini, hosting provider) |
| Commercial information (course purchases) | Yes | No | No | Yes (Stripe) |
| Internet/electronic activity (usage data, IP) | Yes | No | No | Yes (hosting provider) |
| Course content (messages, homework, AI observations) | Yes | No | No | Yes (Telegram, Google Gemini, hosting provider) |
Your Privacy Rights - EEA and UK Residents (GDPR)
If you are located in the European Economic Area (EEA) or the United Kingdom, the General Data Protection Regulation (GDPR) and UK GDPR provide you with the following rights.
Data Controller: Pixel Rainbow Inc. dba AppSign.me, 700 North Fairfax Str. STE 614, Alexandria, Virginia 22314, USA. Contact: [email protected].
Legal Basis for Processing:
We process your personal data based on the following legal grounds:
- Contract: Processing necessary to provide the Service you requested (account management, course delivery, AI coaching, payments)
- Consent: Marketing communications (you may withdraw consent at any time)
- Legitimate Interest: Analytics, security, fraud prevention, and service improvement
- Legal Obligation: Retention of financial records as required by law
Your Rights:
- Right of Access: Request a copy of your personal data.
- Right to Rectification: Request correction of inaccurate data.
- Right to Erasure ("Right to Be Forgotten"): Request deletion of your data, subject to legal retention requirements.
- Right to Restriction of Processing: Request that we limit how we use your data in certain circumstances.
- Right to Data Portability: Receive your data in a structured, commonly used, machine-readable format.
- Right to Object: Object to processing based on legitimate interest.
- Right to Withdraw Consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
- Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your country of residence.
How to Exercise Your Rights:
Email us at [email protected]. We will respond within 30 days.
Automated Decision-Making: We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on you.
International Data Transfers
Your personal data is primarily stored and processed on servers located in the European Union.
For transfers of personal data from the EEA/UK to the United States, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission as the legal mechanism to ensure an adequate level of protection for your data.
Children's Privacy
We do not knowingly collect Personal Information from users under the age of 18. By using our Services, you promise that you are at least 18 years old. If we become aware that a user is under the age of 18, we will terminate any account that the user may have with us. If we become aware that we have inadvertently received Personal Information from a user under the age of 18, we will delete such information from our records.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. If we make material changes, we will notify you by email and/or by posting a notice on the Service at least 15 days before the changes take effect. Your continued use of the Service after the effective date of the updated Privacy Policy constitutes your acceptance of the changes.
Managing Your Information Preferences
You can review, correct, update or delete your Personal Information, or opt out of any direct marketing in which we may engage, by emailing us at [email protected].
Contact Information
If you have questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact us at [email protected].