InviteMember Privacy Policy

Your privacy is critically important to us. At InviteMember, we have a few fundamental principles:

Below is our Privacy Policy, which incorporates and clarifies these principles.

Who We Are and What This Privacy Policy Covers

We refer to (a) InviteMember LLC (a company incorporated and existing under the laws of the State of Delaware under the number 6979516, mailing address 16192 Coastal Highway, Lewes, Delaware 19958 USA), if User is located elsewhere in the world, except EU countries and the UK; or (b) DEV WAY LTD (a company incorporated and existing under the laws of the Republic of Cyprus under the number HE 437821, mailing address is 165, Spyrou Araouzou, Lordos Waterfront Court, Office 401, 3036 Limassol, Cyprus), if User is located in EU countries as well as the UK, as “InviteMember” or “we” throughout this Privacy Policy.

InviteMember Platform is membership bot platform designed to allow anyone – from bloggers, to podcasters, small business owners, and enterprises – to build and manage membership bots for Telegram. These membership bots allow charging a subscription fee in order to access private Telegram channels and supergroups. Our mission is to democratize publishing and community management.

This Privacy Policy applies to information that we collect about you when you use:

Throughout this Privacy Policy we’ll refer to our website and Telegram bots collectively as “Services”.

Please note that this Privacy Policy does not apply to any of our products or services that have a separate privacy policy. Below we explain how we collect, use, and share information about you, along with the choices that you have with respect to that information.

Creative Commons Sharealike License

This document is based upon the Automattic Privacy Policy and is licensed under Creative Commons Sharealike. Basically, this means you can use it verbatim or edited, but you must release new versions under the same license and you have to credit Automattic somewhere. Automattic is not connected with and does not sponsor or endorse InviteMember or its use of the work.

Information We Collect

We only collect information about you if we have a reason to do so, for example, to provide our Services, to communicate with you or to make our Services better. We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Let’s go over the information that we collect.

Information You Provide to Us

It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:

Information We Collect Automatically

We also collect some information automatically:

Information We Collect from Other Sources

Information We Do Not Collect

How And Why We Use Information

Purposes for Using Information

We use information about you as mentioned above and for the purposes listed below:

Legal Bases for Collecting and Using Information

A note here for those in the European Union about our legal grounds for processing information about you under EU data protection laws, which is that our use of your information is based on the grounds that:

For more understanding of how we collect your personal data we placed the conform information in table below:

Information Collected
Purpose of Collection of Data
Legal Basis for processing of Data

Data you provide to us, such as:

  • your e-mail
  • country
  • your billing address
  • VAT number
  • API keys from payment systems
  • your payment information:
    – 4 last numbers of the bank card;
    – period of validity of the bank card;
    – country issued the bank card;
    – type of the bank card
  • To provide our Services
  • To charge you for any of our paid Services
  • To resolve your claims
  • To communicate with you.
  • To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use.
  • To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition.
  • Technical and statistical purposes.

Performance of the contract or taking steps at your request prior to entering into a contract.

Legitimate interest

Your Telegram profile

To provide our Services, for example, to set up and maintain your membership bot.

  • To further develop and improve our Services, for example by adding new features that we think our users will enjoy or will help them to create and manage their membership bots more efficiently.
  • To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use.

Performance of the contract

Legitimate interest

Data we receive automatically, such as:

  • log information
  • IP-address
  • information about operational system
  • information about Internet browser
  • information about your device (unique device identifiers)
  • language preference
  • referring site
  • the date and time of access
  • mobile network information
  • usage information (actions that membership bot administrators and users perform)
  • information from cookies.
  • To provide our Services, for example, to set up and maintain your membership bot.
  • To resolve claims.
  • To further develop and improve our Services, for example by adding new features that we think our users will enjoy or will help them to create and manage their membership bots more efficiently.
  • To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use.
  • To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition.
  • To personalize your experience using our Services, provide recommendations, target our marketing messages to groups of our users and serve relevant advertisements.
  • Technical and statistical purposes.

Performance of the contract

Legitimate interest

Information about accounts in payment systems, transactions, recurrent subscription

To provide our Services, for example, to set up and maintain your membership bot, backup and restore your membership bot or charge you for any of our paid Services.

Performance of the contract

Information about your customers:

  • e-mail
  • Telegram profile
  • payment information:
    – 4 last numbers of the bank card
    – period of validity of the bank card
    – country issued the bank card
    – type of the bank card
    – address of the crypto wallet
  • IP-address
  • information about operational system
  • information about Internet browser
  • information about your device.
  • To provide our Services.
  • To resolve claims.

Performance of the contract

Statistical data not identifying you exactly, such as your region, country, city, town (without information about your exact location).

  • To further develop and improve our Services, for example by adding new features that we think our users will enjoy or will help them to create and manage their membership bots more efficiently.
  • To monitor and analyze trends and better understand how users interact with our Services, which helps us improve our Services and make them easier to use.
  • Technical and statistical purposes.

Legitimate interest

Information you provide to our support team.

  • To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect our rights and property or protect others, which may result in us declining a transaction or the use of our Services.
  • To communicate with you, for example, through an email, about offers and promotions offered by us and others we think will be of interest to you, solicit your feedback, or keep you up to date on our products.
  • To verify your identity and to fulfil your support request, to provide you support, including to help identify and troubleshoot problems with your membership bot, to survey your opinions through surveys or questionnaires.
  • To investigate any complaints and to provide you with a more efficient Services.

Performance of the contract

Legitimate interest

Sharing Information

How We Share Information

We do not sell our users’ private personal information. We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:

Information Shared Publicly

Information that you choose to make public is disclosed publicly. That means, of course, that information like your membership bot name, URL and description, set of subscription plans with names, prices and list of included benefits, are all available to others. Public information may also be indexed by search engines or used by third parties. Please keep all of this in mind when deciding what you would like to share.

For more understanding of who can receive your personal data we placed the conform information in table below:

Information Collected
Source of Personal Data
Recipients of Personal Data
Purpose of Transfer to Recipients
Legal Basis for processing of Data

Data you provide to us, such as:

  • e-mail
  • billing address
  • country
  • VAT number
  • API keys from payment systems
  • your payment information:
    – 4 last numbers of the bank card
    – period of validity of the bank card
    – country issued the bank card
    – type of the bank card
  • your membership bot information, including content information.

From you directly

Amazon Web Services

Payment systems

Advertisement networks

Intercom entity

For storage purposes

To process your payment

To deliver targeted ads

Performance of the contract

Legitimate interest

Your Telegram profile

From Telegram LLC, Telegram FZ-LLC or any affiliate company

Amazon Web Services

Payment systems

Advertisement networks

All users of the Services

For storage purposes

To process your payment

To deliver targeted ads

Performance of the contract

Legitimate interest

Data we receive automatically, such as:

  • log information
  • IP-address
  • information about operational system
  • information about Internet browser
  • information about your device (unique device identifiers)
  • language preference
  • referring site
  • the date and time of access
  • mobile network information
  • usage information (actions that membership bot administrators and users perform)
  • information from cookies.

Directly from your device

Amazon Web Services

Advertisement networks

For storage purposes

To deliver targeted ads

Performance of the contract

Legitimate interest

Information about accounts in payment systems, transactions, recurrent subscription.

From payment systems

None

Performance of the contract

Information about your customers:

  • e-mail
  • Telegram profile
  • payment information:
    – 4 last numbers of the bank card
    – period of validity of the bank card
    – country issued the bank card
    – type of the bank card
    – address of the crypto wallet
  • IP-address
  • information about operational system
  • information about Internet browser
  • information about your device.

Directly from you

Amazon Web Services

Payment systems

Advertisement networks

For storage purposes

To process your customers’ payments

To deliver targeted ads

Performance of the contract

Statistical data not identifying you exactly, such as your region, country, city, town (without information about your exact location).

From statistic and advertisement networks, payment systems.

None

Legitimate interest

Information you provide to our support team.

Directly from you

Intercom entity

Performance of the contract

Legitimate interest

How Long We Keep Information

We generally discard information about you when we no longer need the information for the purposes for which we collect and use it, which are described in the section above on How and Why We Use Information, and we are not legally required to continue to keep it.

Security

While no online service is 100% secure, we work very hard to protect information about you against unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks. To enhance the security of your account, we encourage you to enable advanced security settings, like Two Step Authentication in Telegram.

Choices

You have several choices available when it comes to information about you:

Your Rights

If you are located in certain countries, including those that fall under the scope of the European General Data Protection Regulation, data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including:

Before we process any request, we may ask you for certain information in order to verify your identity. Where permitted by local law, we may reject requests that are unreasonable or impractical. We will respond to your requests in a reasonable timeframe.You can usually access, correct or delete your personal data using your account settings and tools that we offer, but if you aren’t able to do that, or you would like to contact us about one of the other rights, scroll down to How to Reach Us to, well, find out how to reach us.

Controller and Responsible Company

(a) If User is located in EU countries as well as the UK:

DEV WAY LTD
165, Spyrou Araouzou, Lordos Waterfront Court, Office 402, 3036 Limassol, Cyprus
E-mail: info@dw.tech

(b) If User is located anywhere else in the world:

InviteMember LLC
16192 Coastal Highway, Lewes, Delaware 19958 USA
E-mail: info@invitemember.com

DATA PROTECTION OFFICER (DPO)

InviteMember LLC and Dev Way Ltd have appointed a Data Protection Officer for the purposes of the General Data Protection Regulation (EU) 2016/679 (GDPR) and the United Kingdom General Data Protection Regulation, Retained Regulation (EU) 2016/679 (UK GDPR), who you can contact using the details set out below:

RF PRIVACY MINDERS LTD
Address: 33 Konstantinou Paleologou, 6036-Larnaca, Cyprus
Email:
info@privacyminders.com

DATA PROTECTION REPRESENTATIVES

EU Representative for InviteMember LLC

InviteMember LLC has appointed an EU Representative based in Cyprus, in accordance with art. 27 of the General Data Protection Regulation (EU) 2016/679 (GDPR) who you may address if you are located in the European Union to ask any questions about our processing of your personal data, including any requests to exercise your rights provided by the GDPR. You can contact our EU Representative using the details set out below:

RF PRIVACY MINDERS LTD
Address: 33 Konstantinou Paleologou, 6036-Larnaca, Cyprus
Email:
invitemember.eu@privacyminders.com

UK Representative for InviteMember LLC

InviteMember LLC has appointed a UK Representative based in the United Kingdom, in accordance with art. 27 of the United Kingdom General Data Protection Regulation, Retained Regulation (EU) 2016/679 (UK GDPR), who you may address if you are located in the UK to ask any questions about our processing of your personal data, including any requests to exercise your rights provided by the UK GDPR. You can contact our UK Representative using the details set out below:


PRIVACY MINDERS (UK) LTD
71-75 Shelton Street, London WC2H 9JQ, United Kingdom
E-mail:
invitemember.uk@privacyminders.com

UK Representative for Dev Way Ltd

Dev Way Ltd has appointed a UK Representative based in the United Kingdom, in accordance with art. 27 of the United Kingdom General Data Protection Regulation, Retained Regulation (EU) 2016/679 (UK GDPR), who you may address if you are located in the UK to ask any questions about our processing of your personal data, including any requests to exercise your rights provided by the UK GDPR. You can contact our UK Representative using the details set out below:


PRIVACY MINDERS (UK) LTD
71-75 Shelton Street, London WC2H 9JQ, United Kingdom
E-mail:
devway.uk@privacyminders.com

Other Things You Should Know

Transferring Information

Because InvteMember’s Services are offered worldwide, the information about you that we process when you use the Services in the EU may be used, stored and/or accessed by individuals operating outside the European Economic Area (EEA) who work for us, other members of our group of companies, or third party data processors. This is required for the purposes listed in the How and Why We Use Information section above. When providing information about you to entities outside the EEA, we will take appropriate measures to ensure that the recipient understands the necessity to process your personal data only on legal basis and protects your personal information adequately in accordance with this Privacy Policy as required by applicable law. These measures include:

You can ask us for more information about the steps we take to protect your personal information when transferring it from the EU.

Ads and Analytics Services Provided by Others

Ads appearing on any of our Services may be delivered by advertising networks. Other parties may also provide analytics services via our Services. These ad networks and analytics providers may set tracking technologies (like cookies) to collect information about your use of our Services and across other websites and online services. These technologies allow these third parties to recognize your device to compile information about you or others who use your device. This information allows us and other companies to, among other things, analyze and track usage, determine the popularity of certain content, and deliver advertisements that may be more targeted to your interests. Please note this Privacy Policy only covers the collection of information by InviteMember and does not cover the collection of information by any third party advertisers or analytics providers.

Third Parties

Please note that InviteMember uses some 3-rd party software and services. We don’t own or control these third parties and they have their own rules about collection, use and sharing of information, which you should review.

Visitors to Our User`s Membership Bots

We also process information about visitors, customers and clients of our users’ membership bots, on behalf of our users. Please note that our processing of that information on behalf of our users for their membership bots isn’t covered by this Privacy Policy. We encourage our users to post a privacy policy that accurately describes their practices on data collection, use and sharing of personal information. In this situation our users are controllers and determine the personal data shall be processed and purposes of the processing. Our user shall take appropriate measures to process of its customers’ personal data only on legal basis and protect personal information adequately in accordance with applicable law.

Children

Protecting children's privacy is extremely important. Our Services are intended for general audiences and do not knowingly collect or process any personal information from or with respect to children under 16. Through our Services, children will be able to receive local in-app notifications, which do not collect any personal information.

We will: (1) not ask children to input their personal information, (2) collect certain information for limited purposes only (consistent with applicable law), (3) block or restrict the child from accessing relevant services, if applicable.

Privacy Policy Changes

Although most changes are likely to be minor, InviteMember may change its Privacy Policy from time to time. InviteMember encourages you to frequently check this page for any changes to its Privacy Policy. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on this page invitemember.com/privacy. Important changes made to this Privacy Policy will be notified to you via Telegram or Email.