This policy sets out what the ALTCONN service processes about its users, and the purposes and periods of that processing. It applies together with the Terms of Service and the Privacy Policy.
Operator
Processing is carried out by the ALTCONN service, which provides its services on the conditions of the Public Offer. Requests are accepted in the service's Telegram bot: the /support command or the "Support" button. The service has no other channel for requests.
What the service does not ask for
Using the services does not require a name, an email address, a phone number or identity document details. The service does not ask for them, does not store them and does not check them. An account is identified by the user's Telegram account id.
What is processed
The full list is given in the Terms of Service, section "What we do count and store". It covers: the Telegram account id and the username (@username) where one exists; the chosen language; the subscription and payment history; the internal balance; keys and the places of connection they are placed on; devices added by the user; counters of the volume of data passed.
Purposes of processing
Processing serves the delivery of the services: issuing a key, placing it on the places of connection, tracking the subscription's term, accepting payment and considering requests. The data is not used for advertising or profiling.
Legal basis
Processing rests on performance of the contract concluded by paying for a tariff, and on the user's consent, given by accepting the Terms of Service in the bot. Consent is withdrawn by ceasing to use the services and asking support to delete the account.
Where processing takes place
The service's places of connection are located in different countries. A user's key is placed on the places of connection in service; the place used for a connection is chosen by the user's application. The places of connection hold the key and the volume counters. Account and payment data is processed separately from the places of connection.
Retention periods
Account data is kept for as long as the account exists. Payment data is kept after a subscription ends: it is required to consider requests about payments and to return money. The key is removed from the places of connection once the subscription ends. A device's key is not stored, only its hash; the record of a device's revocation is kept.
User rights
A user may obtain information about the data processed about them, require its correction, or require deletion of the account. Such a requirement is submitted in the bot. Deleting the account ends the subscription and makes the keys invalid.
Passing data to third parties
The service does not sell the data it processes and does not pass it to third parties. The exception is the payment providers through which payment takes place: they receive only the amount, the currency and our own payment identifier — nothing about you is in that — and return the amount, the method, the state of the payment and its id on their side. Card and wallet details are not passed in either direction.
Changes
The edition in force is published on this page.