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Privacy Policy Regarding Personal Data Processing

Privacy and Personal Data Protection Policy

Effective date: upon publication of this version. This Policy explains how 4go.tech, identification code 421235122224, located at 131 Pyrohova Street, Vinnytsia, Ukraine (the “Company”, “we”, “us”), processes personal data when you use https://fexsmm.com, the Telegram bot @fexsmm_robot and related services (together, the “Service”).

1. Scope and definitions
“Personal data” means information relating to an identified or identifiable person. “Processing” includes collection, recording, storage, adaptation, use, disclosure, restriction and deletion. “User” means any visitor, account holder, bot user or customer. This Policy applies to data collected through the website, the Telegram bot, user accounts, support channels and related communications. It does not apply to third-party websites, platforms or services that have their own privacy notices.

2. Data we may collect

  • name, email address and other contact details;
  • Telegram user ID, username, display name, language settings and messages you send to @fexsmm_robot;
  • IP address, browser and device information, operating system, language, approximate location derived from IP, timestamps, referrer and pages viewed;
  • account, order, payment-status, balance and support information;
  • links to social media profiles, posts or other public content you provide when placing an order;
  • information you choose to include in messages, forms, order fields or support requests;
  • cookie identifiers and similar technical data;
  • fraud-prevention, security and service-usage information.

Payment card details are normally processed directly by the relevant payment provider. We do not request or intentionally store full card numbers or security codes. We may receive payment status, transaction identifiers and the limited information we need for reconciliation, refunds, fraud prevention and legal records.

3. Purposes and legal bases
We process personal data in accordance with the Law of Ukraine “On Personal Data Protection” and other applicable legislation, including the EU General Data Protection Regulation (GDPR) where it applies. We process data where necessary to provide the Service, create and maintain accounts, process orders and payments, provide support through the website and the Telegram bot, communicate with users, secure the Service, prevent abuse and fraud, troubleshoot and improve the Service, comply with legal obligations, establish or defend legal claims, and protect our rights and property. Our legal bases are performance of the agreement with you, compliance with legal obligations, our legitimate interests and, where required by law, your consent. We rely on consent for optional marketing, non-essential cookies and similar activities. You may withdraw consent at any time. Withdrawal does not affect processing carried out before it.

4. Cookies, Google and analytics
We may use essential cookies for login, security, sessions, preferences and core functionality. Where the required permissions are in place, we may use Google services and other technical tools for analytics, performance, advertising measurement, security and service improvement. These providers may receive identifiers, technical information, events, pages and approximate location under their own terms and privacy policies. You can control cookies through your browser and, where available, through the website’s consent controls. Blocking non-essential cookies may affect some features. Browser “Do Not Track” signals are honoured only where the relevant tool supports them.

5. Payments, Telegram and service providers
To operate the Service we use third-party payment providers and vendors for infrastructure, hosting, email, security, analytics and communication. Messages and data you send through @fexsmm_robot are transmitted via Telegram, which processes them under its own Privacy Policy. We do not control independent providers, and their processing is governed by their own notices. We disclose only information reasonably necessary for the relevant purpose. Where applicable, providers may process data as independent controllers.

6. Disclosure
We may disclose data to:

  • processors and suppliers;
  • payment and financial-service providers;
  • professional advisers and insurers;
  • law-enforcement, judicial or other competent state authorities of Ukraine or other jurisdictions, where legally required;
  • parties involved in a merger, sale, restructuring or similar transaction.

We may also disclose information where necessary to protect users, the Company, the public or our legal rights. We do not sell personal data as a standalone product.

7. International transfers
Providers may process data outside Ukraine or outside the country where you are located. We carry out cross-border transfers in accordance with Article 29 of the Law of Ukraine “On Personal Data Protection”: to states that ensure an adequate level of personal data protection, or on another lawful basis, such as your consent or the need to perform an agreement with you. Where GDPR applies, we use appropriate safeguards, such as standard contractual clauses. No internet transmission or storage system can be guaranteed to be completely secure.

8. Retention
We retain account, order, payment, support, security and technical records while the account or service relationship exists. After that, we keep them for as long as reasonably necessary for security, fraud prevention, accounting, tax, dispute resolution, legal claims, enforcement and compliance. Some technical or analytics records may have shorter or longer retention periods, depending on their purpose and provider settings. We may keep anonymised or aggregated information for longer once it no longer identifies a person.

9. Security
We use reasonable technical and organisational measures, access controls and operational procedures to reduce the risk of unauthorised access, alteration, loss or disclosure. You are responsible for keeping your credentials and your Telegram account secure, and for telling us about any suspected unauthorised access. No service can promise absolute security. Where applicable law requires notice of a personal-data breach, we will notify the competent authority and/or affected persons within the legally required timeframe.

10. Your rights
Subject to applicable law, including Article 8 of the Law of Ukraine “On Personal Data Protection”, you may:

  • find out the sources of collection, location, purposes and recipients of your data;
  • request access, correction, deletion, restriction or portability;
  • object to processing;
  • withdraw consent.

Some requests may be limited where retention is legally required, where the request would affect another person’s rights, or where another exception applies. We may ask for information to verify your identity. We respond within the timeframes set by law.

Contact us at info@fexsmm.com or via Telegram @fexsmm_robot. You may also file a complaint with the Ukrainian Parliament Commissioner for Human Rights or with a court. Where GDPR applies, you may also complain to the supervisory authority in your EU member state.

11. Children
The Service is not intended for persons under 18 or for persons who cannot lawfully use it under applicable law. We do not knowingly collect children’s data for independent use. If you believe a child has provided data, contact us so we can assess the case and delete the data where required.

12. Third-party links and communications
Links, integrations and external platforms, including Telegram and the social networks to which orders relate, are controlled by third parties. Review their notices before using them. Where necessary, we may send service, security, transactional and support messages, including notifications through @fexsmm_robot. You can stop bot messages at any time by blocking the bot in Telegram, but you may then miss important transactional notices. We send optional promotional communications only where we have the required consent or another lawful basis, and they may include an unsubscribe option.

13. Changes and governing law
We may update this Policy to reflect changes in the Service, the law, our providers or our processing. The current version is published at https://fexsmm.com/privacy and takes effect upon publication unless a later date is stated. This Policy is governed by the laws of Ukraine, subject to mandatory rights and protections that cannot lawfully be excluded. Disputes are subject to the competent courts of Ukraine unless mandatory law provides otherwise.

14. Contact
Data controller (personal data owner): 4go.tech, identification code 421235122224, 131 Pyrohova Street, Vinnytsia, Ukraine.
Privacy contact: info@fexsmm.com.
Telegram: @fexsmm_robot.