Privacy Policy

Ace Picks Privacy Policy

At Ace Picks, we are committed to protecting your privacy and ensuring the security of your personal data. This Privacy Policy explains why and how your personal information is collected through the use of our Website and Services. It is important for you to read this Privacy Policy carefully to understand our use of your Personal Data.

This Privacy Policy forms part of our General Terms and Conditions. Please make sure you familiarise yourself with the full Terms. By accessing our Website or App and using our Services, you agree to be bound by these Terms, including this Privacy Policy. 

We may update this Privacy Policy at any time and at our sole discretion. We will notify you when such changes are material in nature (including where they provide for the processing of your Personal Data for a new purpose or under a new basis). However, we urge you to review this Privacy Policy periodically to ensure that you are familiar with the latest version thereof. 

1. Who We Are

1.1. We are SINDERET LTD, a legal entity duly registered in Cyprus, having registration number HE452182, with registered office at Kallipoleos, 15, AMARAL 30 BUILDING, 4th floor, Flat/Office 402, 1055, Nicosia, Cyprus, trading as “Ace Picks” (hereinafter referred to as “we”, “us”, the “Website” or “App”). 

1.2. For any privacy-related inquiries, you can contact our Data Protection Officer at support@acepicks.ai. 

2. Personal Data We Collect and Use

2.1. We gather, process and use different types of Personal Data that you provide to us, or that is generated through your use of our Services. This data includes, but is not limited to, your registration information, your interactions with our customer support team, payment information, transactional information, device, tracking and other online information, as well as profiling and analytical information.

a) Registration information: When you register an account with us, you are required to provide us with your full name, date of birth, postal address, e-mail address, phone number, security questions, marketing preferences, and any other details as might be requested from you for the purposes of registration and/or continued use of our Services. 

b) Interactions with our Customer Support Team: When you interact with our customer support team via live chat, phone, email or social media platforms we will retain a record of your conversations with our team, as well as the conversation transcripts, notes relating to these interactions and their outcomes and details related to your inquiries.

Where you contact us via social media, we may receive and store details from your social media profile (such as your name, profile photo and other information) in addition to  the content of your messages to us.

c) Payment Information: We collect and process information regarding  your chosen payment method(s), including debit/credit card details, cardholder name, e-wallet details, or information in relation to your alternative payment method(s). All such information is processed in accordance with the Payment Card Industry Data Security Standard (PCI DSS).

d) Transactional Information: When you subscribe to one of our plans or purchase any one-time service(s), we retain detailed records of any and all such transactions, including the date and time of the transaction, the payment method utilised, and the corresponding amount(s). In addition, we record these details with respect to any failed, attempted, reversed and/or aborted/unsuccessful transactions. 

e) Device, Tracking, and Other Online Information: We collect detailed information relating to your device and communication data, including IP address, browser type, unique device identifier (UDID), IDFA, hardware model, operating system and version, software, preferred language, serial numbers, device motion information, mobile network information and location data. In addition, we collect information such as dates and times of access, the Website/App features or pages you view(ed), Website/App crashes and other system activity, and the third-party site or service you used immediately before visiting our Website/App.

When you access or use our content, products, and Services, we may collect information from your devices through the use of 'cookies' and similar technologies. These technologies can collect a wide variety of information about how you interact with our Services, such as your language preferences, pages visited and content viewed, links and buttons clicked, and URLs visited before and after you use our Services. For further details on cookies, please refer to our Cookie Policy https://acepicks.ai/cookie-policy . 

f) Profiling and Analytical Information: We may carry out profiling and analysis based upon your name, location data, age, transaction history and account activity, as well as any other relevant data points. This helps us better understand and enhance your experience and the Services we provide.

g) Other Information We May Collect: We may collect information and data about the way you contribute to, and communicate with/through, our Services, for example when you post comments via our social media channels or chat functionalities such as forums, and chat messaging channels with us or other users.

We may also collect your responses to any surveys or market research activities that we may conduct periodically. 

3. How and Why We Use Your Personal Data

3.1. We only use your Personal Data where necessary and where it is lawful to do so. Our use of your Personal Data is needed:

a) to deliver the Services to you;

b) to meet our legal or regulatory obligations;

c) to meet or protect your, our, the wider public’s, or third parties’ interests; and 

d) for other reasons only where we have your explicit consent to do so.

The following is an overview of the different categories of Personal Data we collect about you, along with the corresponding legal basis for their processing: 

4. Sharing of your Personal Data

4.1. Occasionally we may share your Personal Data with Third Parties in the course of providing you with our Services, including, but not limited to, the following: 

a) Other companies within our Group: to facilitate our operations and deliver Services across our group entities;

b) Third-party customer management software providers (Strapi.io): to manage and enhance your customer experience; 

c) Registered banks, e-wallet providers (including Apple Pay and Google Pay), and payment providers such as Stripe and Trustly, along with their appointed third parties: to process payments securely and efficiently;

d) Alternative Dispute Resolution (ADR) providers: to manage and resolve disputes that may arise in connection with our Services;

e) Social Media companies (including Meta and X): for account integration, marketing, and user interaction purposes;

f) External marketing agencies and ad service providers: for marketing, promotional, and advertising activities on our behalf;

g) Third-party advertisers: for the purposes of serving targeted advertisements and promotions relevant to your interests; and

h) Courts, law enforcement agencies, regulatory agencies, and other public and government authorities: we may disclose your Personal Data to these entities when required to do so by law or when necessary to protect our legal rights, ensure compliance with legal obligations, or safeguard the public interest.

4.2. In the event of a change in ownership of all or part of our business, or if we undergo a reorganisation or restructuring, we reserve the right to transfer your Personal Data to the new owner or successor entity. Such transfer will be conducted to ensure that the new owner or successor entity can continue to provide you with the Services.

5. Your Data Subject Rights

5.1. As a Data Subject, you have the right to know how and where your Personal Data is being used, as well as to request access to such data, request that it be removed or modified, and complain wherever you feel that we are not complying with our legal or regulatory obligations. 

a) Right of Access: You have the right to request a copy of the Personal Data that we hold about you. Should you wish to make such a request, you should submit a request to datacompliance@acepicks.ai. We may ask you to identify yourself prior to processing your request. We shall have thirty (30) days to respond to your request, which may be extended in the event of a particularly complex request, upon submission of a notice to this effect from us to you. 

b) Right of Rectification: You can request us to rectify and correct any Personal Data that we are processing about you that you believe is incorrect. While we provide you with the ability to modify certain Personal Data yourself through your User Account management system, you can also request modification and/or correction of your details by submitting a request to datacompliance@acepicks.ai. 

We will rectify such inaccuracies within thirty (30) days. If we take the decision not to make a change you have requested, we will inform you of this, along with any associated reasons. If you disagree with our decision, you have the right to file a complaint with the appropriate regulatory authority.

c) Right of Erasure: You have the right to request us to erase your Personal Data where there are no compelling reasons for us to continue storing or processing your data, and specifically, where one of the following grounds applies:

• Where the processing of your Personal Data has been deemed by a court or competent authority to be unlawful;
• Where our original purpose for collecting the Personal Data has been fulfilled, and no other valid legal basis justifies its retention; or
• Where you have withdrawn your consent for processing and requested deletion of your Personal Data, or successfully exercised your ‘right to object’, and there are no overriding legitimate grounds to continue processing.

You can request erasure of your Personal Data by submitting a request to datacompliance@acepicks.ai. We shall have thirty (30) days to respond to your request. 

We have the right to refuse to erase your Personal Data if we need to retain it in furtherance of our legitimate interests, and for as long as this remains to be the case. “Legitimate Interests” may include, without limitation, compliance with legal and regulatory obligations, defence of legal claims, and the processing of our internal financial information and calculations for taxation purposes. 

If we take the decision not to erase your Personal Data, we will inform you of this, along with any associated reasons. If you disagree with our decision, you have the right to file a complaint with the appropriate regulatory authority.

d) Right of Restriction: In certain instances, you have the right to request that we suspend our processing of your Personal Data, where one of the following grounds applies:

• The accuracy of the Personal Data is contested by you, for a period enabling us to verify the accuracy of such data;
• The processing of your Personal Data has been deemed unlawful by a court or competent authority, and you oppose the erasure of such data and request the restriction of its use instead;
• We no longer need your Personal Data for the purposes of processing, but it is required by you for the establishment, exercise or defence of legal claims; or
• You have objected to our processing of your Personal Data on the basis of our legitimate interests, and we are verifying whether our legitimate grounds override yours as a Data Subject.

Where we suspend our processing of your Personal Data, we will still be permitted to store your Personal Data, but any further processing of such data will require your consent, subject to certain exemptions. Where you have obtained the restriction of processing, you will be informed by us before such restriction is lifted.

We have the right to refuse to restrict processing of your Personal Data if we determine that your request is manifestly unfounded or excessive. 

You can request restriction in the processing of your Personal Data by submitting a request to datacompliance@acepicks.ai. We shall have thirty (30) days to respond to your request. If we take the decision not to restrict processing of your Personal Data, we will inform you of this, along with any associated reasons. If you disagree with our decision, you have the right to file a complaint with the appropriate regulatory authority.

e) Right of Data Portability: You have the right to re-use some of your Personal Data online by making it available in a commonly-used, machine-readable format that can be passed to and used by other organisations. This right applies to data that you have provided to us with your consent, or which was necessary for us to provide you with our products and Services. Where technically feasible, you also have the right to have your Personal Data transferred by us directly to another organisation.

You can exercise your right of Data Portability by submitting a request to datacompliance@acepicks.ai. We shall have thirty (30) days to respond to your request. If we take the decision not to accede to your request, we will inform you of this, along with any associated reasons. If you disagree with our decision, you have the right to file a complaint  with the appropriate regulatory authority.

f) Right of Objection: You have the right to object to our use of your Personal Data which is processed on the basis of our legitimate interests. However, we may continue to process your Personal Data, despite your objection, where there are compelling legitimate grounds to do so or where we need to process your Personal Data in connection with any legal claims.

You can object to our processing of your Personal Data by submitting a request to datacompliance@acepicks.ai. We shall have thirty (30) days to respond to your request. If we refuse to stop processing your Personal Data, we will inform you of this, along with any associated reasons. If you disagree with our decision, you have the right to file a complaint with the appropriate regulatory authority. 

g) Right Relating to Automated Decision-Making: You have the right not to be subject to a decision which is based solely on automated processing (i.e. without human involvement), where that decision produces a legal effect or has a similarly significant effect on you. This right does not apply where you have provided your explicit consent for us to use your Personal Data in this way, where the decision is needed to enter into or perform a contract with us (for example, the terms and conditions of our Services), or where the decision is needed to meet our legal or regulatory obligations.

Where decisions are made based on your explicit consent, or they are needed to enter into or perform a contract with us, you have the right to request human involvement in the decision, express your point of view, or contest the decision made.

You can exercise this right at any time by submitting a request to datacompliance@acepicks.ai. 

5.2. If you disagree with any aspect of our processing of your Personal Data or any decision we take in connection with the exercise of any of your rights outlined in this Section 5, you may file a complaint with the relevant data protection authority in your jurisdiction within the European Economic Area (EEA).