Privacy Policy

1. Who We Are

ProjecBot is a digital platform operated by Appecable Tech in Jamaica. ProjecBot provides tools for generating financial projections and related business documents and may facilitate optional services such as Accountant Verification, affiliate participation, programme earnings, withdrawals, disputes and customer support.

For personal information processed through ProjecBot, Appecable Tech determines the purposes and means of processing except where a third-party service provider acts independently under its own terms or legal obligations.

2. Information We Collect

The information we collect depends on how you use ProjecBot and may include:

2.1 Account and contact information

• Name, email address, telephone number and account identifiers.
• Authentication and account-status information.
• Communications sent to or through customer support or programme messaging features.

2.2 Business and financial projection information

• Business name, structure, industry, address and contact information.
• Directors, owners or other persons identified in a document.
• Revenue estimates, expenses, opening cash balances, growth assumptions, market information and other data used to generate financial projections.
• Generated documents, verification tokens, document status and review history.

2.3 Transaction and payment information

• Order identifiers, transaction identifiers, amount, currency, payment status, timestamps and payment-verification information.
• Limited payment metadata made available to us by the payment processor, such as masked card information or the last four digits where provided.

Where payment is completed on a third-party hosted payment page, the payment provider may collect card or banking information directly. ProjecBot does not need to store the full payment-card number simply to confirm the transaction.

2.4 Accountant Programme information

If you apply to participate as an accountant, we may collect:

• Full name, address, email address and telephone number.
• Professional designation, qualifications, experience and registration or ICAJ-related information.
• Government-issued identification submitted for identity and programme verification.
• Professional stamp image and electronic signature specimen.
• Application, approval, suspension and credential-verification status.

2.5 Affiliate, earnings and withdrawal information

• Affiliate IDs and referral codes.
• Referral, commission and earnings records.
• Withdrawal requests, bank name, account name and account number.
• Disputes, supporting descriptions, status and administrative responses.

2.6 Technical and security information

We and our technology providers may process information such as device/browser information, IP address, authentication events, security logs, error information and other technical data reasonably necessary to operate and protect the service.

3. How We Use Personal Information

We may use personal information to:

• Create and manage user accounts and authenticate users.
• Generate financial projections and related documents from information supplied by users.
• Process orders, verify payments and provide purchased services.
• Provide document verification features, including verification tokens and QR codes.
• Assign eligible documents to approved accountants for optional Accountant Verification.
• Allow accountants to review, approve, reject, request corrections and electronically sign eligible documents.
• Administer Affiliate and Accountant Programmes, commissions, earnings and withdrawals.
• Investigate disputes, suspected fraud, abuse and security incidents.
• Provide customer support and service communications.
• Maintain, secure, troubleshoot and improve ProjecBot.
• Comply with applicable legal, regulatory, accounting or record-keeping obligations.

4. Automated and AI-Assisted Processing

ProjecBot may use automated systems, calculations and artificial-intelligence-assisted features to help organize information, generate projections, descriptions, assumptions or document content.

Generated financial projections are based on user-provided information and modelled assumptions. Where applicable, users should review generated content before relying on it. Accountant Verification is a separate human review process and is not completed solely by automated processing.

5. When We Share Information

We do not sell personal information. We may disclose information when reasonably necessary to operate the platform, including to:

• Approved accountants: where a customer has requested Accountant Verification and information is needed to review the applicable document.
• Payment processors: to initiate, process, verify, refund or investigate transactions.
• Cloud, authentication, database and storage providers: used to host and operate ProjecBot.
• Communications or technical service providers: where needed to deliver emails, alerts, security services or platform functionality.
• Professional advisers: such as legal or accounting advisers where reasonably necessary.
• Government, regulators, courts or law-enforcement authorities: where disclosure is required or permitted by applicable law.

Accountants receive information relevant to the document assigned for review. Affiliate users should not receive private customer financial information merely because a referral generated a commission.

6. International Data Processing and Transfers

ProjecBot uses internet and cloud-based technology. Some service providers or infrastructure used to operate the platform may process or store information outside Jamaica.

Where personal information is transferred outside Jamaica, Appecable Tech will seek to handle the transfer in accordance with applicable requirements of the Data Protection Act, 2020, including applicable requirements concerning the protection afforded to personal information in the receiving jurisdiction and any other legally available safeguards.

7. Data Security

We use reasonable technical and organizational measures designed to protect personal information against unauthorized or unlawful processing, accidental loss, destruction, alteration or disclosure.

Measures may include authenticated access, access controls, secure cloud infrastructure, encryption provided by our technology providers, logging, restricted administrative access and other security controls appropriate to the service.

No internet service or electronic storage system can be guaranteed to be completely secure. Users are responsible for protecting their own passwords, authentication credentials and devices.

8. Data Retention

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including providing the service, maintaining transaction and document records, managing disputes, complying with legal obligations, preventing fraud and protecting legitimate business interests.

Retention periods may differ depending on the type of information. For example, payment records, signed document records, verification information, withdrawals, disputes and accountant approval records may need to be retained longer than temporary application or session information.

When information is no longer reasonably required, we may delete, anonymize or otherwise dispose of it subject to applicable law and technical limitations such as backups.

9. Your Privacy Rights

Subject to the Data Protection Act, 2020 and any applicable limitations or exemptions, individuals may have rights concerning their personal information, including rights to:

• be informed about the processing of their personal information;
• request access to personal information held about them;
• request correction or rectification of inaccurate information;
• request restriction or prevention of certain processing in circumstances provided by law;
• withdraw consent where consent is the applicable basis for processing;
• object to certain solely automated decisions and seek review where the law provides that right; and
• make a complaint regarding the handling of personal information.

We may need to verify your identity before fulfilling a privacy request. Some information may need to be retained where required by law or where another lawful basis for continued retention applies.

10. Children

ProjecBot is intended primarily for persons and businesses capable of entering into transactions for business-document services. We do not knowingly design the platform for children to independently purchase financial-document services. If we learn that personal information has been collected in circumstances that require additional consent or protection, we will take appropriate steps consistent with applicable law.

11. Cookies, Local Storage and Similar Technologies

ProjecBot may use browser storage, cookies or similar technologies where necessary to maintain sessions, remember preferences, support payment flows, improve usability or protect the service. Third-party services integrated into the platform may also use their own technologies according to their privacy practices.

12. Third-Party Services

ProjecBot may integrate with third-party services such as payment gateways, authentication providers, hosting, databases, file storage and communication services. Those providers may process information under their own privacy notices and contractual obligations.

When you leave ProjecBot for a third-party website or hosted payment page, that third party's privacy policy may apply to information collected directly by that provider.

13. Data Breaches and Security Incidents

If a security incident affects personal information, Appecable Tech will assess the incident and take steps required by applicable law, which may include notification to the Office of the Information Commissioner and affected persons where legally required.

14. Changes to This Privacy Policy

We may update this Privacy Policy when our services, technology, legal obligations or data-processing practices change. The updated version will display a revised “Last Updated” date.

Where a change materially affects how existing users' personal information is processed, we may provide additional notice through ProjecBot, email or another appropriate method.

15. Contact and Privacy Requests

To ask a privacy question, make a data-subject request or report a privacy concern, contact:

You may also have the right to raise a complaint with Jamaica's Office of the Information Commissioner.

16. Relationship With Our Terms

This Privacy Policy explains how personal information is handled. Your use of ProjecBot is also governed by our Terms & Conditions. If a provision of this Privacy Policy conflicts with a mandatory requirement of applicable law, the applicable law will prevail.