Legal

Privacy Policy

Last updated: 2026-09-23

Ecbot (“we”, “us”, “our”) provides a customer-conversation automation platform for Southeast Asia, connecting businesses to Facebook Messenger, Instagram, Zalo Official Account, TikTok Shop, Shopee, and similar channels. This Privacy Policy explains what personal information we collect, how we use it, and the rights you have under applicable laws — including Vietnam Decree 13/2023/ND-CP on Personal Data Protection (PDPD), Decree 53/2022/ND-CP on local data storage, Singapore PDPA, Indonesia UU PDP, Thailand PDPA, the Philippines DPA 2012, Malaysia PDPA, the EU/UK GDPR, and the CCPA where each applies.

1. Personal Information We Collect

1.1 Information You Provide

We collect information you provide directly to us, including:

  • Account data: name, email address, phone number, company name, and password when you create an account.
  • Billing data: payment method details processed through our payment processors (VNPay, Momo, Sepay, and Payos). We do not store full card or bank account numbers.
  • Customer Content: data, documents, and materials you upload or connect to train your automations and AI agents, including past conversations, product catalogs, order histories, FAQ articles, and macros.
  • Communications: any messages you send us through email, chat, Zalo, or support channels.
  • Feedback: suggestions, feature requests, and other feedback you voluntarily provide.

1.2 Information We Collect Automatically

When you use the Service, we automatically collect certain information, including:

  • Device data: IP address, browser type, operating system, and device identifiers.
  • Usage data: pages visited, features used, actions taken, time spent, and navigation paths. We may use product analytics tools (such as PostHog) to understand how users interact with the Service and to improve the user experience.
  • Log data: server logs, error reports, and performance metrics.

1.3 Information from Connected Platforms

When you authorize Ecbot to connect to a third-party platform, we receive information from that platform on your behalf, including:

  • Messaging platforms: Facebook Messenger and Instagram (via the Meta Graph API), Zalo Official Account (via the Zalo OA API), and similar channels — including page/account metadata, conversation threads, end-user profile information (name, avatar, platform-scoped user ID), and message content sent through your connected accounts.
  • Commerce platforms: TikTok Shop (via the TikTok Shop Open Platform), Shopee (via the Shopee Open Platform) — including shop information, orders, order status, buyer messages, and product catalog data.
  • Other integrations as we expand: helpdesks, CRMs, knowledge sources, and project management tools.

We only access the data you authorize through OAuth or platform-specific authentication flows, and only to the extent necessary to provide the Service. Some Connected Platforms (notably Meta and TikTok) impose additional data use restrictions, which we honor — for example, we do not use Meta Platform Data for advertising or for unrelated purposes.

1.4 End-User Information

When your end customers message your business through a Connected Platform, we process their messages, profile information made available by the platform, and any attachments they send. We process this information as a data processor on your behalf. You are the data controller for your end-user data and are responsible for providing required notices and obtaining required consents under applicable law (see Section 8).

1.5 Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies for essential operation (authentication, session management, security), analytics, customer support, and marketing (where you have consented). On our public website, analytics cookies are set only after you accept them in the consent banner; until you choose, no analytics cookie or local storage entry is written. You can also control cookies through your browser settings. Disabling cookies may limit certain functionality of the Service.

2. How We Use Your Information

We use the information we collect to:

  • Provide and maintain the Service, including ingesting conversations, generating AI responses, routing messages, and delivering replies through your connected platforms.
  • Process payments and manage your subscription.
  • Improve and develop the Service, including using aggregated, de-identified data to enhance our product features. We do not use Customer Content to train general-purpose foundation models.
  • Communicate with you about updates, security alerts, and support inquiries.
  • Send marketing communications about new features and offerings, where permitted by applicable law (you can opt out at any time).
  • Prevent fraud, spam, and platform-policy violations, and ensure the security and integrity of the Service.
  • Comply with legal obligations and enforce our terms.

2.1 Legal Basis for Processing

Under Vietnam Decree 13/2023 and Indonesia UU PDP, consent must generally be specific, informed, and separable per purpose. Where applicable, we rely on the following legal bases:

PurposeGDPR / similar basisVietnam PDPD / Indonesia UU PDP
Provide and maintain the ServicePerformance of contractConsent / contract necessity
Process paymentsPerformance of contractConsent / contract necessity
Improve and develop the ServiceLegitimate interestConsent (separable)
Service updates and security alertsPerformance of contract / legal obligationConsent / legal obligation
Marketing communicationsConsentConsent (separable)
Prevent fraud and ensure securityLegitimate interestLegitimate interest / legal obligation
Comply with legal obligationsLegal obligationLegal obligation

3. How We Share Your Information

We do not sell your personal information. We may share your information with:

  • Service providers: cloud hosting (AWS), payment processing (VNPay, Momo, Sepay, Payos), email delivery, and analytics. These providers are bound by contractual obligations to protect your data.
  • AI model providers: Customer Content (including conversation snippets) may be sent to AI model providers such as OpenAI, Anthropic, and Google. These providers process data solely to generate responses and do not use Customer Content to train their general models, in accordance with their data processing terms.
  • Connected Platforms: data flows between Ecbot and the platforms you connect (Meta, Zalo, TikTok Shop, Shopee, etc.) as necessary to provide the Service.
  • Professional advisors: lawyers, accountants, and auditors as needed for business operations.
  • Legal requirements: when required by law — including lawful requests from Vietnam’s Ministry of Public Security (A05), Singapore’s PDPC, or comparable authorities in Indonesia, Thailand, the Philippines, and Malaysia.
  • Business transfers: in connection with a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity.

4. Data Hosting and Security

4.1 Data Hosting

Customer data is hosted on AWS in Singapore (ap-southeast-1) by default, chosen for low-latency access from Vietnam and the rest of Southeast Asia. Vietnam-resident storage is available on request to support Customer’s obligations under Decree 53/2022/ND-CP on local storage of certain user data. Additional regions may be available for Enterprise customers.

4.2 Security Measures

  • Encryption of data in transit (TLS 1.2+) and at rest (AES-256).
  • Access controls and role-based permissions.
  • Regular security audits and vulnerability assessments.
  • Optional PII redaction to strip personal identifiers (national ID numbers, card numbers, emails, phone numbers, OTPs, and similar) from content before processing or sending to AI providers.
  • Compliance roadmap including ISO 27001 and/or SOC 2 Type II — see our Trust Center for current status.

5. Data Retention

We retain your personal information for as long as your account is active or as needed to provide the Service. Upon termination of your agreement, we will delete Customer Content within 60 days of your request, except where retention is required by law (for example, accounting and tax records, which Vietnamese law generally requires to be retained for at least 10 years).

End-user conversation data ingested from Connected Platforms is retained according to your account’s retention settings (default: 24 months), subject to platform-specific retention restrictions (for example, Meta requires certain data to be deleted within 30 days of disconnection).

6. International Data Transfers

Your information may be transferred to, stored, and processed in Singapore, Vietnam, the United States, or other countries where our service providers operate.

  • Vietnam: For Customers and end users in Vietnam, certain cross-border transfers are subject to Decree 13/2023/ND-CP. Ecbot will support Customer in preparing and submitting a Cross-Border Transfer Impact Assessment (TIA) dossier to the Department of Cybersecurity and Hi-Tech Crime Prevention (A05) under the Ministry of Public Security.
  • Indonesia: Transfers are subject to UU PDP Art. 56, requiring adequacy or appropriate safeguards.
  • EEA / UK: For Personal Data transferred from the EEA or the United Kingdom, we rely on Standard Contractual Clauses (SCCs) approved by the European Commission and the UK International Data Transfer Addendum.
  • Other ASEAN jurisdictions: We rely on the data subject’s consent, contract necessity, or comparable legal mechanisms under Singapore PDPA, Thailand PDPA, Philippines DPA 2012, and Malaysia PDPA.

7. Your Rights and Choices

7.1 Account Information

You may access, update, or delete your account information at any time through the Ecbot dashboard. If you wish to delete your account entirely, contact us at privacy@ecbot.dev.

7.2 Marketing Communications

You can opt out of marketing emails or messages by clicking the “unsubscribe” link in any marketing email, replying STOP / HỦY to marketing messages where supported, or by contacting us. You will continue to receive transactional and service-related communications.

7.3 Rights of Data Subjects in Southeast Asia

Subject to the applicable law in your jurisdiction, you may have the right to:

  • Be informed about how your personal data is processed.
  • Access your personal data and obtain a copy.
  • Rectify inaccurate or incomplete data.
  • Request erasure or restriction of your personal data.
  • Object to or withdraw consent for certain processing (including automated decision-making).
  • Data portability.
  • Lodge a complaint with the competent data protection authority, including A05 (Vietnam), PDPC (Singapore), the Personal Data Protection Agency (Indonesia), the Office of the Personal Data Protection Committee (Thailand), the National Privacy Commission (Philippines), or the Personal Data Protection Department (Malaysia).

To exercise these rights, contact us at privacy@ecbot.dev.

7.4 EEA, UK, and Swiss Residents

If you are located in the EEA, UK, or Switzerland, you additionally have the rights described in the GDPR (access, rectification, erasure, restriction, portability, objection, and the right to lodge a complaint with your local supervisory authority).

7.5 California Residents (CCPA)

If you are a California resident, you have the right to know, delete, correct, opt out of the sale or sharing of personal information (we do not sell or share personal information), and to non-discrimination for exercising your privacy rights.

8. Customer’s Role as Data Controller

When you use Ecbot to handle conversations with your end customers, you are the data controller (under Vietnam Decree 13/2023, the Data Controller or Data Controller-Processor) for the end-user personal data, and Ecbot acts as the data processor. As the controller, you are responsible for:

  • Providing a privacy notice to your end customers.
  • Establishing a valid lawful basis (typically consent) for processing under the applicable law in their country.
  • Honoring data subject requests, including requests originating through the Connected Platform.
  • Complying with anti-spam and marketing-consent rules (including Vietnam Decree 91/2020/ND-CP, Singapore PDPA Do Not Call, Thailand PDPA marketing rules, and equivalent rules in other ASEAN markets).
  • Complying with the messaging and content policies of each Connected Platform.

9. Data Processing Agreement

For customers subject to data protection laws that require a data processing agreement, our DPA is incorporated into our Terms of Service. The DPA is based on the Common Paper DPA Standard Terms Version 1.0 and covers:

  • Our role as a data processor (or sub-processor) of Customer Personal Data.
  • Processing instructions and permitted purposes.
  • Sub-processor management, including advance notice of changes.
  • Data subject rights and breach notification obligations.
  • International transfer mechanisms (Standard Contractual Clauses, Vietnam Decree 13/2023 TIA support, and similar).

For Enterprise customers, we offer a comprehensive Cloud Service Agreement with a full DPA, liability caps, indemnification terms, security exhibits, and custom terms. Contact privacy@ecbot.dev to get started.

9.1 Approved Sub-processors

Sub-processorPurposeLocation
Amazon Web ServicesCloud infrastructureSingapore (ap-southeast-1) primary, with Vietnam-resident storage on request
CloudflareCDN, WAF, DDoS protectionGlobal edge
OpenAIAI model providerUnited States
AnthropicAI model providerUnited States
Google (Vertex AI / Gemini)AI model providerUnited States / Singapore
VNPayPayment processing (cards, QR, domestic bank transfer)Vietnam
MomoPayment processing (e-wallet)Vietnam
SepayPayment processing (bank transfer reconciliation)Vietnam
PayosPayment processing (multi-method aggregator)Vietnam
Meta PlatformsConnected messaging platform (Messenger, Instagram)Global
Zalo (VNG Corporation)Connected messaging platform (Zalo OA)Vietnam
TikTok Shop Open PlatformConnected commerce platformSingapore / United States
Shopee Open PlatformConnected commerce platformSingapore
Resend / PostmarkTransactional email deliveryUnited States / European Union
PostHogProduct analyticsUnited States
SentryError monitoringUnited States / European Union
VercelFrontend hosting and serverless computeGlobal edge

10. Children

The Service is not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). Under Vietnam Decree 13/2023, processing the personal data of children (under 16) requires verifiable consent from a parent or legal guardian; we do not knowingly process such data through the Service. If we learn that we have collected personal information from a child without proper consent, we will take steps to delete that information promptly.

11. Third-Party Services

The Service contains links to and integrations with third-party websites and services, including the Connected Platforms (Meta, Zalo, TikTok, Shopee, etc.). We are not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you connect to Ecbot.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy on this page and updating the “Last updated” date above. Where required by applicable law (for example, Vietnam Decree 13/2023 requires re-consent for material changes to purpose of processing), we will obtain renewed consent before applying such changes. Your continued use of the Service after any changes constitutes acceptance of the updated policy.

13. Contact Us

For privacy questions or to exercise your rights, contact us at privacy@ecbot.dev.