> For the complete documentation index, see [llms.txt](https://themis-bot.gitbook.io/themis-docs/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://themis-bot.gitbook.io/themis-docs/legal-stuff/privacy-policy.md).

# Privacy Policy

Publication date: February 23, 2023

&#x20;

The Privacy Policy regulates the procedure for ensuring confidentiality and processing of Personal Data during your use of the Bot.

The Privacy Policy regulates the processing of the Personal Data of the Data Subject during its blocking.

This Privacy Policy indicates all legislative acts of international law regulating the processing of Personal Data during the use of the Bot

This Privacy Policy defines the categories of data that are not processed by the Bot.

The provisions of this Privacy Policy apply only to Personal Data obtained by the Bot in the ways described in its terms.

References to the words "you" or "your" (or words of similar meaning) mean our User or Data Subject, depending on the context of the Privacy Policy.

References to the words "we", "our" or "us" (or similar words) mean Themis Bot.

The words he/she and their derivatives in the text of the document can refer to either a male or a female person depending on the context of the document.

Use the Bot with security for your Personal Data.

1. **DEFINITIONS**

1.1 **User** - is an individual using the Bot Services using the Discord platform and receives the Services from the Company.

1.2 **Data Subject** - is a natural person or software (identifying itself as a natural person) that interacts with Discord Guild (server) and whose actions are recognised as rule violation and blocked by Bot.

1.3 **Controller** - means any natural or legal person, government agency, institution, or other body that independently determines the purposes and means of personal data processing.

1.4 **Processor** - is a natural or legal person, government agency, institution, or other body that processes Personal Data on behalf of and behalf of the Controller.

1.5 **Cookies** - are a piece of information in the form of text or binary data is transmitted to the browser from the site.

1.6 **User's Consent (hereinafter "Consent")** - means a voluntary, specific, informed, and unequivocal expression of will, in which the User using a statement or explicit affirmative action agrees to the processing of his Personal Data.

1.7 **Personal Data** - means any information that directly or indirectly allows identifying the User. For example, name, surname, phone number, contact phone.

1.8 **Statistical Data** - is information that allows the identification of the User, necessary for the provision of the Services and the use of the functions of the Bot, but is publicly available.

1.9 **Themis Bot (hereinafter "Themis" or "Bot")** - is an advanced security Discord bot that can be configured to prevent different kinds of attacks on Discord  Guild (server).&#x20;

1.10 **Themis website (hereinafter "Site")** - means a web page or a group of web pages on the Internet, which are located at [https://themisbot.com/](https://alwond.com/) , through which the User receives the Services.

1.11 **Third Party** - means a natural or legal person, government agency, institution, or body other than the User, Data Subject, Controller, Processor or Bot and persons authorized by the Controller or Processor under their direct supervision to process Personal Data.

1.12 **Services** - providing the User with access to the functions of the Bot, in order to protect his Guild (server) from raids, evil, and spam that could harm his Guild (server).

1.13 **Company** - is a LTD Alwond Limited, registered under the laws of Hong Kong, registration number: 74169119-000-06-22-2, legal address: Room 1308, Multifield Plaza, 13/F, 3 Prat Ave, Tsim Sha Tsui, Hong Kong, which owns all property and intellectual rights to the Bot software and content.

2. **GENERAL PROVISIONS**

2.1 The Bot processes and stores Personal  Data based on the following legal acts:

1. [General Data Protection Regulation (GDPR)](https://gdpr-info.eu/);
2. [California Consumer Privacy Act](https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=201720180SB1121);
3. [Federal Trade Commission ](https://www.ftc.gov/)Regulation, including [Section 5 of the FTC Act](https://uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title15-chapter2-subchapter1\&edition=prelim).
4. [Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO")](https://www.elegislation.gov.hk/hk/cap486?xpid=ID_1438403261084_001).

2.2 The Service acts as a Processor regarding the processing of Personal and Statistical Data that it receives during the provision of Services to the User, and the User acts as a Controller regarding the processing of Personal and Statistical data.

3. **PERSONAL DATA**

3.1 To access the Bot Services, the User does not need to register on a separate Site, and the Site will be accessed using Discord OAuth, using the User's Discord profile. The Bot does not purposefully process the User's Personal Data, but might  access the following types of Personal Data:

1. FULL NAME;
2. contacts: e-mail, work, and/or contact phone number;
3. place of residence;
4. Discord data: guild (server) id and id profile (user).

3.2 The Bot does not purposefully collect Personal Data about the Data Subject, but may receive the following Personal Data of the Subject during communication with him:

1. FULL NAME;
2. contacts: e-mail, work, and/or contact phone number.

3.3 The Bot may collect the following Statistics Data:\
\- a list of servers on which the User is participates and his role (to determine which of them he manages);\
\- User actions associated with the bot with subsequent output to the action log in the dashboard.

3.4 The Bot may collect the following data about the User's behavior while using the Bot:

1. number of created/modified/deleted webhooks;
2. number of created/modified/deleted channels;
3. number of created/changed/deleted roles;
4. the number of banned/kicked Data Subjects;
5. number of added/kicked bots;
6. the number of repeated messages and messages with the @everyone tag (message notification of which is sent to all server members).

3.5 The Bot does not purposefully process the User's banking data, and such data is processed exclusively by the payment system that is used to accept payments for the Services. The Bot might  process payment data solely to resolve disputes and/or to comply with the requirements of the legislature and/or the decision of the judicial/executive authority.

3.6 The Bot does not use Personal Data for advertising purposes, including sending promotional offers to the User.

3.7 The Bot does not use Personal Data for the purpose of sending promotional messages to the User, and the Bot does not send any messages to the User. Reports of violations of the Bot, or critical changes in the operation of the Bot or internal documentation of the Bot, can be sent by an employee of Themis.

3.8 **Themis does not collect or process sensitive Personal Data of Users of Data Subjects, such as race or ethnic origin, political views, religious or philosophical beliefs, union membership, genetic or biometric data, health information, sexual life or sexual orientation.**

3.9 When visiting the Site or receiving Services, Themis may collect the following Personal Data automatically:

1. IP address;
2. time zone and language settings;
3. browser type and version;
4. operating system, device type, and screen extension;
5. the country in which you are located;
6. data about your visit to the Site, including full URL information, routes to and from the Site (including date and time), page response time, data loading errors, length of stay on certain pages, page activity (such information such as scrolling and mouse movements, clicks), methods used to exit the page.

3.10 The Themis has the right to collect and receive Personal Data as follows:

1. when providing the Services;
2. using special questionnaires;
3. when interacting with Themis employees, by exchanging emails, communicating and making phone calls.

3.11 The Themis has the right to use Personal Data for the following purposes:

1. provision of the Service;

2. to ensure the security of the Site;

3. to administer the Site and conduct internal operations, including troubleshooting, data analysis, testing, and completing surveys;

4. to improve your navigation on the Site in accordance with your preferences;

5. communication with you;

6. respond to law enforcement requests;

7. to initiate responses to legal claims, investigations, or dispute resolution with you.

8. **TRANSFER OF PERSONAL DATA**

4.1 The Themis may transfer Personal and Statistical Data to entities with which the Bot cooperates in the implementation and provision of Services:

1. **Payment service.** To receive payment for the Services, Personal Data may be transferred automatically.

2. **Contractors and employees.** The Bot may transfer your Personal and Statistical Data to other entities with which it will start cooperation, including legal and tax consultants, as well as entities that provide accounting, logistics, marketing, and IT services.

3. **Counterparties.** The Themis has the right to disclose or transfer Personal and Statistical Data in the following transactions: acquisition or merger, financing, corporate reorganization, joint venture, including the sale of assets, or bankruptcy.

4. **Courts, law enforcement, and state bodies.** The Bot has the right to transfer Personal Data in case of fulfillment of any legal obligations, including in accordance with a court order.

5. **Instant messaging Discord platform.** The Bot may transfer your Personal and Statistical data, if necessary, to provide the Services to the User or upon request from Discord.

6. **USER CONSENT**

5.1 The following actions are considered consent to the processing of Personal and Statistical Data specified in this Privacy Policy:

1. payment for services;
2. installation of the bot, using Discord.

5.2 By agreeing to the terms of this Privacy Policy, the User provides his consent to processing his Personal and Statistical Data, according with this Privacy Policy;

5.3 The Bot reserves the right to obtain the User's Consent via the Pop-up form. The Pop-up form may contain a Consent form in the сheckbox view.

6. **DATA STORAGE AND PROTECTION**&#x20;

6.1 The Bot uses all necessary security and protection measures for Personal Data to ensure their confidentiality and prevents loss or improper disclosure.

6.2 The Bot protects and stores Personal Data from:

1. losses;
2. unlawful use, transfer, disclosure, modification, deletion, and/or destruction.

6.3 We may use the following methods to protect Personal Data in accordance with the[ article "Security of processing" 32 GDPR](https://gdpr-text.com/ru/read/article-32/?col=1\&lang1=en\&lang2=en\&lang3=uk):

1. pseudonymization and encryption of Personal Data;
2. ability to ensure constant confidentiality, integrity, availability and fault tolerance of Personal Data processing systems;
3. regular testing, evaluation and measurement of the effectiveness of technical and organizational measures to ensure the security of processing Personal Data.

6.4 The Bot does not store the User's Personal Data in the event of a request to delete Personal Data on his behalf in accordance with the right to delete, as provided in[ Article 17 of the "Right to Erase" GDPR](https://gdpr-text.com/ru/read/article-17/?col=1\&lang1=en\&lang2=en\&lang3=uk).

6.5 In case of termination of the relationship between the User and the Bot and the receipt of the Services, the Personal and Statistical data of the User will be permanently and irrevocably deleted.

7. **GROUNDS FOR PERSONAL DATA PROCESSING**

7.1 The Bot processes Personal Data based on the following legal grounds:

1. User's Consent;
2. receiving Services from the Themis;
3. to comply with the provisions of applicable law, for the proper level of our business, the conclusion, and execution of corporate transactions (sale of shares/stocks, mergers, acquisitions), to fulfill your obligations to you and/or the Third Party.

7.2 In cases where the basis for the processing of Personal and Statistical Data is Your Consent, You have the right to withdraw it at any time. To withdraw your Consent, You may send an email to:<hello@alwond.com> and/or to the official Discord server:<https://discord.gg/themisbot> and/or to the social network Twitter account:<https://twitter.com/ThemisBot> If Your Consent is withdrawn, the Themis has the right to terminate the provision of the Services and terminate all relations with You. If Consent is withdrawn, your Personal and Statistical Data will be permanently deleted.

7.3 The Themis undertakes to stop processing Personal and Statistical Data within 15 (fifteen) business days from the date of receipt of the withdrawal of Consent.

8. **USER RIGHTS**

8.1 During the processing of Personal and Statistical Data, the Bot grants the User the following rights:

1. **Right of access.** The User may contact us directly to request access to the Personal and Statistical Data we hold about them, as well as to any information.
2. **Right to erasure.** The User has the right to delete Personal and Statistical Data about himself. Personal and Statistical Data in this case will be permanently deleted.
3. **Right to data portability.** We may send the Personal and Statistical Data of the User to third parties at the request of the User.
4. **Right to rectification.** The User has access to Personal and Statistical Data that needs to be updated, corrected, and supplemented at any time.&#x20;
5. **Right to object.** The User has the right to object to the processing of his/her Personal and Statistical Data at any time.
6. **Automated individual decision-making, including profiling.** The User has the right not to be subject to a decision that is based solely on the automated processing of his Personal and Statistical Data, including profiling, which has legal consequences for him or similarly significantly affects him.

8.2 The terms of this clause apply to U.S. residents: The Bot does not support Do Not Track ("DNT") as required by the California Online Protection Act (CalOPPA). Do Not Track is an option you can set on your web browser to tell websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting your web browser settings page.

8.3 Also, you may appoint an authorized agent to make a request on your behalf if:

1. An authorized agent is an individual or entity registered with the California secretary of state;
2. You sign a written statement that you authorize the authorized agent to act on your behalf;
3. If you are using an authorized agent to request to exercise your right to information or right to erasure, please send a certified copy of your written statement authorizing the authorized agent to act on your behalf using the contact information provided below.

8.4 The Bot processes Personal and Statistical data based on the following principles (hereinafter to us "Data Protection Principles" or "DPP"):

1. **DPP1 Purpose and Manner of Collection.** Personal Data is collected only for legitimate purposes directly related to the function or activity of the Bot.
2. **DPP2 Accuracy and Duration of Retention.** Personal Data is stored no longer than is necessary for the provision of the Services. In the event of termination of the Services, Personal Data will be permanently deleted.
3. **DPP3 Use of Data.** Personal Data is used solely for the purposes specified in the Privacy Policy. And the User has the right to revoke his Consent at any time.
4. **DPP4 Data Security.** The Bot makes every effort to ensure the safety and security of Personal Data, using minimization, pseudo-minimization and data encryption.
5. **DPP5 Openness and Transparency.** The Bot makes publicly available, on its Site, its Privacy Policies and Terms of Service to ensure the provision of the Services and the processing of Personal Data.
6. **DPP 6 Access and Correction.** The User has the right to request access to and rectification of his personal data.

8.5 The conditions specified in this section also apply to the Data Subject and the Data Subject can obtain the same rights as the User by writing a request to the Bot describing the problem and providing information that identifies him. If such information is not provided by the Data Subject, the Bot will not be able to identify the Data Subject and grant him the rights provided for in this section.

9. **JURISDICTIONS OF OTHER COUNTRIES**

9.1 The Themis makes every effort to legally process Personal and Statistical Data in accordance with international standards.

9.2 This Privacy and Statistical Policy contains the main legal acts related to the processing of Personal Data.

9.3 Unfortunately, we can not list all the laws regarding the processing of Personal and Statistical Data in every jurisdiction in the world.

9.4 The terms of this Privacy Policy describe the basic rights of the User or Data Subject, which are provided for by the main provisions of the main legislative acts regulating the processing of Personal and Statistical Data.

9.5 If you believe that the provisions of this Privacy Policy violate and/or in any way limit Your rights regarding the processing of Personal and Statistical Data, please contact us by e-mail: <hello@alwond.com> and/or to the official Discord server:<https://discord.gg/themisbot> and/or to the social network Twitter account:<https://twitter.com/ThemisBot> and we will do our best to resolve the matter within a reasonable time.

10. **SUBMISSION OF REQUEST**

10.1 User or Data Subject in any jurisdiction has the right to submit a request to the Themis if he believes that his rights have been violated by writing a request in writing to the support of the Themis at the address: <hello@alwond.com> and/or to the official Discord server:<https://discord.gg/themisbot> and/or to the social network Twitter account:<https://twitter.com/ThemisBot>

10.2 The User's or Data Subject’s request must contain accurate information about the requirements for the Bot. If the exact requirements are not specified in the request, the Bot has the right to refuse to fulfill the request.

10.3 We will not be able to respond to your request or provide you with Personal Data unless we can verify your identity and confirm that the Personal Data belongs to you. In case of receiving a request with inaccurate information and/or in case of inability to confirm the User's or Data Subject’s identity, the Bot has the right not to process the received request and contact the User or Data Subject for clarification. In case of receiving a response to a request for clarifications, the User or Data Subject must provide a new corrected request or submit a new request.

10.4 The Bot must respond to the request or fulfill the conditions set forth in the request within 21 (twenty one) business days from the moment of its receipt.

11. **RESPONSIBILITY**

11.1 The processing of Personal and Statistical Data is carried out automatically by the Bot, but is controlled by Themis employees and any decision of the Bot can be verified by a Themis employee.

11.2 The Bot informs the User that Personal Data may be used to provide the Services, and in case of disagreement with this, the User is not entitled to receive the Services.

11.3 If the User provides inaccurate Personal and Statistical Data, the responsibility for the result of such provision, including the use of the Bot functions, lies entirely with the User.

11.4 The Bot is not responsible for any damage caused to the User as a result of the use of his Personal and Statistical Data by a Third Party without his knowledge.

11.5 The Bot may link to other websites or services. The privacy practices of these websites and services are not governed by this Privacy Policy and the Bot, and the Bot cannot be held responsible for the processing of User's Personal and Statistical Data by Third Party websites and services.

11.6 Themis is not responsible for:

1. loss of Personal Data in the event of a hacker attack, hacking of the Site software, illegal actions of Third Parties, illegal actions of Third Parties, and actions that violate the terms of the Privacy Policy;
2. impossibility to provide the Services or low-quality provision of the Services if the User has provided inaccurate Personal Data, statistical data or any other information;
3. providing false information by the User.

11.7 Unfortunately, the transmission of information over the Internet cannot be completely secure. Although we make every effort to protect personal data, we cannot guarantee the secure process of transferring personal data to the site. In this regard, you are solely responsible for possible failures when transferring your Personal and  Statistical Data to the Bot.

12. **COOKIE**

12.1 The Bot does not use Cookies because it is not a web client and does not access the User's website.

12.2 A Bot is an automated program that interacts with online services through APIs or other protocols and does not use cookies to store information

12.3 But while visiting the Site, Cookies may be used for the following purposes:

1. authentication and identification;
2. storage of personal preferences and settings;
3. access session tracking;
4. storage of statistical data;
5. website analysis.

12.4 The Bot does not use web analytics services, except for its own analytics in the form of surveys of Users.

13. **ADULTS POLICY**

13.1 Bot services are intended for persons who have reached the age of majority, in accordance with the laws of the country of residence of such a person. The Bot does not process Personal or Statistical Data of minors.

13.2 Themis does not track the age of the User, but has the right to delete the Personal and Statistical data of a person who has not reached the age of majority, without warning and any consequences for Themis, and also to terminate the provision of the Services to such a person.

13.3 If you have information about the receipt of the Services by a person under the age of majority, please contact support by sending an email to: <hello@alwond.com> and/or to the official Discord server: <https://discord.gg/themisbot> and/or to the social network Twitter account: <https://twitter.com/AlwondStudio>

14. **PRIVACY POLICY CHANGE**

14.1 We have the right to amend the Privacy Policy, Security of Personal and Statistical Data and compliance with the laws of the jurisdiction in which we operate from time to time.

14.2 The User is obliged to read the new terms of the Privacy Policy and Themis is not responsible if the User has not read the new terms of the Privacy Policy.

14.3 Themis updates the modification date of the current version of the Privacy Policy in the "Updated" line at the top of the document.

14.4 Our electronic or otherwise stored copies of the Privacy Policy are believed to be true, complete, valid, valid and in effect at the time you visit the Site or install the Bot.

15. **CONTACTS**

15.1 The User has the right to contact the Themis support service at: <hello@alwond.com> and/or to the official Discord server:<https://discord.gg/themisbot> and/or to the social network Twitter account:<https://twitter.com/ThemisBot> to ensure his rights, in accordance with the terms of this Privacy Policy, or in case of violation of his rights, or to leave feedback or ask a question.

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