Privacy Policy

Introduction

Welcome to ChatCGM. This Privacy Policy explains how TechForce OÜ (“we”, “us”, “our”) collects, uses, and discloses your information when you use our AI-powered platform for diabetes management. By accessing or using ChatCGM, you agree to this Privacy Policy.

1. Information We Collect

1.1 Personal Data

When you use ChatCGM, we collect the following personal data:

• Telegram Username and ID: To identify and interact with you on the Telegram platform.
• User Email: Collected only during the payment process.
• Nightscout Account Data: Including language, timezone, treatments, notes, sugar readings, and other relevant data provided within your Nightscout account.

1.2 Messages

• User Messages: Messages sent through Telegram to the OpenAI API are also stored on our servers. These messages may be used in anonymized form to train our algorithm and enhance features.

1.3 Payment Information

We use Stripe to process payments. When you make a payment, Stripe collects your payment information. We do not store your payment card details on our servers.

2. How We Use Your Information

We use your information to:

• Provide and improve our services.
• Process payments and manage subscriptions.
• Respond to your inquiries and support requests.
• Enhance and personalize your experience.
• Use anonymized messages for training algorithms and enhancing features.

3. Lawful Basis for Processing

We process your personal data based on the following lawful bases:

• Consent: When you have given explicit consent for us to process your data.
• Contract: When processing is necessary for the performance of a contract with you.
• Legal Obligation: When processing is necessary to comply with legal obligations.
• Legitimate Interests: When processing is necessary for our legitimate interests, provided these interests are not overridden by your rights and interests.

4. Third-Party Providers

We use third-party providers to facilitate our services:

• Telegram: For message delivery and user interaction.
• OpenAI API: For processing and analyzing user messages.
• Stripe: For payment processing. Stripe collects and processes your payment information. For more information on how Stripe handles your data, please review their Privacy Policy.
• Infrastructure Hosting Providers: For storing and managing data securely.

5. Data Security

• Encryption: Your Nightscout URL and token are stored in encrypted form and are never shared with any third party.
• Data Protection: We implement industry-standard security measures to protect your personal data.

6. Data Sharing

We do not share your personal data with third parties, except:

• With your consent.
• As required by law.
• To protect our rights and safety and those of our users.

7. International Data Transfers

Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country.

We ensure that appropriate safeguards are in place to protect your data in accordance with this Privacy Policy, including standard contractual clauses or other lawful mechanisms for international data transfers.

8. Data Retention

We retain your personal data only for as long as necessary to provide our services and fulfill the purposes described in this Privacy Policy.

9. Your Rights Under GDPR

Under GDPR, you have the following rights:

• Access: You have the right to request access to your personal data.
• Rectification: You have the right to request correction of any inaccurate or incomplete data.
• Erasure: You have the right to request the deletion of your personal data.
• Restriction: You have the right to request restriction of processing your personal data.
• Data Portability: You have the right to request transfer of your personal data to another entity.
• Objection: You have the right to object to the processing of your personal data.

To exercise any of these rights, please contact us at support@chatcgm.com.

10. Automated Decision-Making and Profiling

We do not use your personal data for automated decision-making or profiling.

11. Complaints

If you believe that your data protection rights have been violated, you have the right to lodge a complaint with the supervisory authority in your country.

12. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. Your continued use of ChatCGM after such changes constitutes your acceptance of the new Privacy Policy.

13. Contact Us

If you have any questions about this Privacy Policy, please contact us at support@chatcgm.com.