Privacy

2. How do we use your personal data?

2. How do we use your personal data?

We might use your personal data for the following purposes. These are examples and might not explain all the usages.

We strive to get explicit consent when possible, but might process information on the ground of 'legitimate interest'. As we however deeply care about your privacy we want to gain consent.

• Ensuring safety within the community
• Providing a leveling in the server
• Attempting to protect you from sharing your personal information
• Safeguarding a welcoming and open community
• To protect our services
• To provide economy features in the server
• All points that are mentioned in section 1.
• To respond to legal requests and prevent harm
• To report information to the Discord trust & safety team if deemed neccesary.
• To enforce the server rules.
• To add games to the server

3. How do we not use your personal data?

3. How do we not use your personal data?

We would like to explain what we do not use your personal data for.

• We do not use it for advertisement purposes
• We don't sell your data
• We don't use it for promotional material

4. Who do we share your data with?

4. Who do we share your data with?

In short:We collect data based on consent, legitimate interests, legal obligations and vital interest. We only share information with your consent, to comply with laws, to ensure safety, or to fulfill business obligations.

We aim to share your data with the minimal amount of third parties as possible, however for us to provide the SincerelyBot functionalities with you we do have to use some third parties.

For the following purposes we may process or share your data with third parties.

• Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.
• Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.
• Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements). Note that we will only do this under very particular circumstances, and will always inform you about this. We follow the laws in the Netherlands, and will not share information if it may result in human rights being broken.
• Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

We may share data with the following parties, to see what data we share and when see What data do we collect?

• DigitalOcean (Our hosting provider, all data is stored on their AMS3 servers)
• Sentry (Helps us find and resolve bugs)
• MongoDB (Database provider)
• Discord (All data comes through the Discord API)
• Goverments, law enforcements and other goverment agencies

Discord

While all data we process comes from Discord, and as such we aren't sharing new information with them directly. We do want to note that if a message poses a serious risk we reserve the right to share information with the Discord Trust and Safety team.

Depending on the situation we may choose to not inform you about this. If it's deemed that informing you about this poses a risk of harm to you or other people.

DigitalOcean

DigitalOcean is the hosting provider used by SincerelyBot, we use the servers located AMS. This means the data is stored on servers in The Netherlands. DigitalOcean acts as a Data Processor for SincerelyBot, as such all data that goes through our server is processed by DigitalOcean. This will always be the case for a hosting provider.

Because we encrypt most of the data on the client, DigitalOcean will only be able to see the encrypted content.

More information

• Terms of service
• Privacy Policy
• Data Processing Agreement
• GDPR
• Trust

Sentry

We use Sentry to catch errors that happen on the client, this allows us to see what problems users are running into and reproducing the bugs that they encounter. This allows us to prioritize resolving issues, and as a result provide a better user experience.

More information

• Privacy policy
• Terms of service
• Data processing addendum

MongoDB

We use MongoDB cloud as our Database hosting provider. These servers are hosted by AWS in Frankfurt. MongoDB acts as a Data Processor for SincerelyBot, as such all data that needs to be stored in our database goes through the MongoDB.

More information

• Privacy policy
• Terms of service
• Privacy Shield
• Law enforcement information request

Governments, law enforcements and other government agencies

We comply to legal requests for data from these entities. We however take the privacy of our users very serious, so we may deny a request from these entities if the request poses a threat to the safety of our users. We will always inform the users in question if their has been a request for their data unless a court order prohibits us from doing so.

If the request is likely to result in human rights being broken, then we will always reject the request.

SincerelyBot opperates under the laws of The Netherlands, and will only handle requests according to the Dispute resolution section of our terms of service.

Data collection that you are unable to opt-out of!

The following modules are modules that you can't opt out of. This is because these modules are part of data we collect based on Legitimate Interest. These modules are used to ensure the safety of you and other community members.

We are always open to a meaningful decision, so if you have any question please reach out.

General messages

We will always receive all messages, there is not much we can do about this as we listen for the message event. Build in privacy modules will however allow us to skip messages based on wether or not they have given consent.

We will however still receive the messages, sadly the only way you can opt-out of this is by not sending any messages in the community Discord.

AntiDox

This module aims to prevent you from sharing personal information in the Discord. We do this to ensure that you don't bring yourself or other members in danger. There are very serious risks associated with sharing personal information in a public space.

Toxicity module

This module processes messages to try and determine if the content is harmfull. If it deems it harmfull it will flag it to moderators. This module is key to enabling the moderation team to maintain a safe and welcoming community.

Banned words module

This module checks if a message contains a banned word. Banned words are words that we know are being used maliciously in the community. You to just opt-out of a check for a banned word. can't opt-out of this module because that would allow malicious actors.

5. How do we protect your information?

5. How do we protect your information?

We protect your information by making sure all traffic goes over an encrypted SSL connection. If we store data for a longer period of time (such as for the economy module), then we encrypt the data before we store it in the database.

We may access information using our administrator account or through a secure connection to the server. How third-parties protect your information may differ from ours, so we recommend you check out their respective policies to learn how they protect your information.

6. Where do we store your information?

6. Where do we store your information?

We store your personal information on our servers, our servers are hosted by DigitalOcean using the AMS3 servers. Some personal data is processed through third party providers such as Discord.

Furthermore data that is stored in the database is stored on the Mongo Cloud servers. These servers are hosted by AWS in Frankfurt.

7. How long do we store data?

7. How long do we store data?

We store information as long as that data is relevant to the SincerelyBot application, the exact durations and explenations can be found in the What data do we collect.

Generally speaking information in regards to your account is stored until you request us to delete it. While temporary data in regards to the application are stored for the duration of the execution plus the time it takes until the next Garbage Collection. While information in regards to issues in the application are stored until the issue is resolved.

Messages that where flagged to the moderation team are not stored on our servers, but are stored by Discord. Refer to Discord's privacy policy to view how long they retain data.

We are unable to delete your data from previous back-ups so your data will remain in back-ups. Our automated back-ups are kept for 4 weeks, so your data will be permanently deleted 4-5 weeks after your request for data deletion was processed. Meaning 4-5 weeks after we deleted the data

8. Children

8. Children

Protecting the privacy of the very young is especially important. For that reason, we never collect or maintain information at our site from those we actually know are under 13, and no part of our website is structured to attract anyone under 13. We also ask users under 13 to not use our services.

If you are under the age of 18, we require consent to be given or authorized by the holder of parental responsibility.

9. Use of 'machine learning' and computer-aided decisions

9. Use of 'machine learning' and computer-aided decisions

We use machine learning to process messages to try and determine if a message is possibly harmfull. For this the machine learning uses a trained model, it gives a message a score in 7 different categories. This score is between 0 and 1, 0 being that it's very sure that the message doesn't fall in the category, 1 being that it's extremely sure it does fall in the category.

If a message meets the treshold (which is subject to change, but currently is set at 0.6), it will send a message to a moderation channel showing that message is potentially harmfull. This threshold is subject to change over time, and will be adjusted based on the performance.

The machine learning model checks the message for the following 7 categories.

• Identity attack
• Insult
• Obscene
• Severe toxicity
• Sexual explicit
• Threat
• Toxicity

Based on what does the machine learning make a decision?

We use machine learning purely to parse the content of a single message. The machine learning itself only has access to the content of a message. It doesn't know who send it, or any info about the sender* (Unless the content of the message contains information about you, then it knows that for the duration of the parsing of that message).

What does it mean if a message gets flagged?

A message being flagged to the moderation team, doesn't necessarily mean that the message is actually toxic. Nor does it mean that the moderation team will act on it.

The machine learning is purely used to assist the moderation team in raising attention to messages that are potentially harmfull. The machine learning will never execute moderation actions on it's own. Meaning that it will not delete messages, ban users, kick users or otherwise sanction users based on the content of a message.

This task is solely in the hands of the moderation team. As again it aims to help the moderation team to focus on flostering a healthy community instead of reading chat logs all day.

Should I trust the machine learning?

We completely understand if a bot that uses machine learning to analyse messages sound scary. And we want to ensure you that the safety and trust of our community members is our number 1 priority.

During the pilot face of the machine learning, we have conducted an in dept internal research into the use of machine learning to keep a Discord community safe. Based on this report we are currently reworking the way we have implemented the machine learning.

Moving forward we will implement the machine learning according to the European guidelines: "Assessment List for Trustworthy AI (ALTAI)", you an read this guideline by downloading the PDF here.

We take concerns within the community extremely serious, and we are open to have meaningful discussion about the use of machine learning within the community. Both in private and openly. The trust of the community is of at most importance for ensuring succesfull use of machine learning.

The machine learning was developed with the sole goal of protecting the community members. We take great care in ensuring that it doesn't harm the members it was aimed to protect.

Transparency

We want to be very sure that we are transparant about the use of machine learning. We aim to do this by providing quarterly transparency reports. In these reports we aim to show the amount of messages the machine learning has flagged. The reason it flagged messages per category. And how many of those flags the moderation team has acted on.

Accountability

Another key part of ensuring trust in the machine learning is accountability. It is our duty to ensure the safety of the members. If we notice that the machine learning is starting to behave in a way that is worrisome and/or is starting to show a bias we will correct this and clearly communicate this to the community.

We will also reach out to any member that has been affected by this. We of course hope that we never have to do this, so we will do everything within our ability to ensure we prevent a situation that would require us to do this.

What to do if I don't agree with a decision that was made assisted by the Machine Learning?

The moderation team will not act based solely on a flag by the machine learning. They will always look into the context of the message at hand. And try to make a decision that is appropriate for a given situation. Including but not limited to, deciding no action is needed, warning a user, deleting a message, kicking, or banning members.

We however also recognize that moderators are also humans, and can make mistakes. So we want to allow you to request another review by our moderation team. This can be done through the "Moderation Appeal" form. We allow for 1 re-review per case. We aim to get back to you within 2 weeks, generally speaking in the re-review we will provide you with an explanation of how we came to the decision.

I have more questions regarding the Machine Learning

If you have any questions left that you would like answered, please reach out to AnxySlender#1337 on Discord. She will be more then happy to answer any questions you have in regards to the machine learning.

11. Third-party disclosure

11. Third-party disclosure

We do not share data with third parties with exception of the partners named above. To see what data is shared with third parties by our partners you can view their respective policies.

12. Third-party links

12. Third-party links

Our Website may contain links to other websites which are outside our control and are not covered by this Privacy Policy (“Third-Party Websites”). If you access Third-Party Websites using the links provided, the operators of such sites may collect information from you which will be used by them in accordance with their own privacy policies, which may differ from ours. We encourage you to review the privacy policies of those Third-Party Websites so that you understand if/how they collect and/or use information from you or your computer.

13. Your rights

13. Your rights

In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information.You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please contact us on Discord. We will consider and act upon any request in accordance with applicable data protection laws.

If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent. If you are a resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

Account information

If you would at any time like to review or change the information in your account or terminate your account, you can:

• Contact AnxySlender#1337 on Discord
• Use the associated commands in the SincerelyBot

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

If you wish for full account data deletion, we will need to kick you out of the Discord. If you only want partial data then for most cases this can be done without removal of Discord. (Modules that you can't opt out of require you to be removed from the server)

There might be cases where we are unable to delete your data such as:

• Data can't be deleted if there is an open government request for the data
• We reserve the right to refuse your request for data deletion, under certain circumstances. If we refuse your request we will contact you informing you why and suggesting steps moving forward.

Do California residents have specific privacy rights?

In short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with a Service, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the Discord ID address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

CCPA Privacy Notice

The California Code of Regulations defines a "resident" as: (1) every individual who is in the State of California for other than a temporary or transitory purpose and(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose All other individuals are defined as "non-residents." If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

What categories of personal information do we collect?

We have collected the following categories of personal information in the past twelve (12) months, we first name the category. Then give an example of what data could fall under this. And then finally if we collected it or not.

A. Identifiers

Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name

Yes we have collected this

B. Personal information categories listed in the California Customer Records statute

Name, contact information, education, employment, employment history and financial information

Yes we have collected this

C. Protected classification characteristics under California or federal law

Gender and date of birth

NOT INTENTIONALLY (IF YOU STATE IT IN MESSAGES IT WILL BE COLLECTED)

Note we do collect pronouns, but pronouns don't equal gender 💖

D. Commercial information

Transaction information, purchase history, financial details and payment information

No we have not collected this

E. Biometric information

Fingerprints and voiceprints

No we have not collected this, as we have zero use for this

F. Internet or other similar network activity

Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements

Yes we have collected this

G. Geolocation data

Device location

No we have not collected this

H. Audio, electronic, visual, thermal, olfactory, or similar information

Images and audio, video or call recordings created in connection with our business activities

Yes we have collected this

I. Professional or employment-related information

Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us

No we have not collected this

J. Education Information

Student records and directory information

No we have not collected this

K. Inferences drawn from other personal information

Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics

Yes we have collected this

Other

We may also collect other personal information outside of these categories instances where you interact with us in-person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

How do we use and share your personal information?

More information about our data collection and sharing practices can be found in this privacy notice. You may contact us through Discord, or by contact AnxySlender#1337 on Discord. If you are using an authorized agent to exercise your right to opt-out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal data.

SincerelyBot has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding 12 months. SincerelyBot will not sell personal information in the future belonging to website visitors, users, Discord community members and other consumers.

Your rights with respect to your personal data

Right to request deletion of the data - Request to delete You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

Right to be informed - Request to know Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights We will not discriminate against you if you exercise your privacy rights.

Verification process Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

Other privacy rights

• you may object to the processing of your personal data
• you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data
• you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

To exercise these rights, you can contact us through Discord, or by contacting AnxySlender#1337 on Discord. If you have a complaint about how we handle your data, we would like to hear from you.

14. Your acceptance of these terms

14. Your acceptance of these terms

By using our services, you agree to this policy. If you do not agree with this policy, then please do not use our services. If you don't agree to this policy and have existing data please request data deletion with the above process.

If you continue using our services after changes are made to this policy, then that is deemed as acceptance of those changes. If you at any point stop agreeing with the terms please follow the process for data deletion and stop using our services.

15. Do we make updates to this privacy policy?

15. Do we make updates to this privacy policy?

We may update this privacy notice from time to time. The updated version will be indicated by an updated "Revised" date and the updated version will be effective as soon as it is accesible. We will inform you by Discord when we make changes to the privacy policy. We encourage you to review this privacy notice frequently to be informed of how we are protection your information.

For transparancy sake, we will also keep an archive of previous versions online. At the top of this document a previous version will be linked (if there are previous versions).

16. Questions?

16. Questions?

We tried to make this privacy policy as easy to understand a spossible. If you have any questions that are unanswered or are unsure about parts of this policy. Don't hesitate to get in touch AnxySlender#1337.