Astrix Beta Privacy Policy

1.1 About This Privacy Policy

This Privacy Policy explains how Astrix2u ("Company," "we," "us," "our") collects, processes, stores, and protects personal data from users ("User," "you," "your") of the Astrix Beta assessment tool ("Service").

This policy applies to all use of the Service, whether online via our website or through direct engagement with our team.

1.2 Data Controller & Processors

Astrix2u is the data controller responsible for your personal data, meaning we determine how and why your personal data is processed.

Key Data Processors We Use:

All processors are bound by Data Processing Agreements (DPAs) requiring data protection compliance.

1.3 Data Protection Officer

Astrix2u may appoint a Data Protection Officer (DPO) if required under Malaysia PDPA 2024 or UK GDPR regulations. For data protection inquiries, contact us through https://astrix2u.com/contact

1.4 Applicable Privacy Laws

This Privacy Policy complies with:

• Malaysia: Personal Data Protection Act 2010 (PDPA) and Personal Data Protection (Amendment) Act 2024
• United Kingdom: UK General Data Protection Regulation (UK GDPR) and Data Protection Act 2018
• Singapore: Personal Data Protection Act 2012 (PDPA) – where applicable
• United States: California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) – for California residents; state privacy laws where applicable
• Canada: Personal Information Protection and Electronic Documents Act (PIPEDA)
• Australia: Privacy Act 1988 and Australian Privacy Principles (APPs)

1.5 Geographic Availability

The Service is currently available only in the following Covered Countries:

Users from other regions may join our waitlist to be notified when we expand. Waitlist data (email and country) is processed under legitimate interest to facilitate service expansion.

2.1 Information You Provide Directly

2.2 Information We Collect Automatically

2.3 Geographic & Waitlist Data

2.4 Data from Third Parties

We may receive personal data from service providers, analytics platforms, payment gateway providers, and referral partners.

3.1 Legal Bases for Processing

Data Shared with Business Accounts:

If you are a sub-account managed by a Business reseller, the Business account holder may have access to:

• • Your username and email address
• • Credit balance and usage history
• • Assessment activity statistics (number of assessments, not content)
• • Account status (active, suspended)

Business Account Data We Collect:

For Business resellers, we additionally process:

• • Sub-account management activities
• • Credit distribution and approval records
• • Revenue and transaction analytics (aggregated)
• • Business performance metrics

Legal Basis:

Business account data is processed under Contract (providing reseller services) and Legitimate Interests (fraud prevention, platform integrity).

How Credit Expiry Notifications Work:

• When: 3 days before your credits expire
• Who: Users with packages having 33-100 day validity (not welcome credits)
• Content: Remaining balance, expiry date, and link to use credits
• Frequency: Maximum one notification per 24 hours per user

Data Processed for Notifications:

• • Email address (to send the notification)
• • Username/Full name (for personalization)
• • Credit balance and expiry date (notification content)
• • Notification history (to prevent duplicate emails)

Legal Basis:

Credit expiry notifications are sent under Contract (part of service delivery) and Legitimate Interests (helping you get value from your purchase).

Types of Emails We Send:

How to Unsubscribe:

You can unsubscribe from marketing emails at any time through:

• One-Click Unsubscribe: Click the "Unsubscribe" link in any marketing email footer
• Email Preference Center: Visit https://astrix2u.com/unsubscribe
• Contact Us: Email us through https://astrix2u.com/contact

Unsubscribe Process (GDPR/PDPA Compliant):

• Immediate Effect: Your request is processed immediately upon confirmation
• Token-Based Security: Unsubscribe links are secured with time-limited tokens (30-day validity)
• Confirmation Page: You'll see a confirmation page after unsubscribing
• Re-subscribe Option: You can re-subscribe at any time if you change your mind
• RFC 8058 Compliance: We support one-click unsubscribe as per email standards

Data We Collect for Unsubscribe Audit:

For compliance and fraud prevention, we log:

• • Email address (to enforce unsubscribe preference)
• • Reason for unsubscribing (optional, for service improvement)
• • Timestamp of unsubscribe request
• • IP address and user agent (for security audit)

Data Collected via Telegram:

How We Use Telegram Data:

Data Retention for Telegram:

Third-Party Data Sharing (Telegram):

Your Rights (Telegram Data):

• Unlink: Use /unlink command or web app to disconnect Telegram
• Access: Request a copy of your Telegram-related data via contact form
• Deletion: Request deletion of Telegram linking data
• Portability: Export your linked account information

Why We Retain Emails After Account Termination:

• You received welcome credits upon registration
• We must prevent re-registration using the same email to claim duplicate credits
• This protects our system integrity and other legitimate users

Retention Periods:

• Email address: Retained indefinitely (until re-registration risk has diminished)
• Account data and Inputs: Deleted after 30 days following termination
• All other personal data: Deleted as per Section 7

What This Means for Users:

• ✓ Your account profile, Inputs, and Outputs will be deleted
• ✓ Your personal information (name, phone, company) will be deleted
• ✓ Your email address will be retained for fraud prevention
• ✓ You cannot re-register using the same email address
• ✓ You can register using a different email address

What This Means:

• Nature: Astrix applies pre-defined, deterministic algorithmic rules to your Input to produce Outputs.
• No Machine Learning: Astrix does NOT use machine learning, neural networks, or AI models. It is rule-based and deterministic.
• No Profiling: Astrix does NOT create user profiles or build persistent behavioral models about you.
• Significant Effects: Assessments are informational only and do not have legal or similarly significant effects on you.

Your Rights:

You have the right to request human intervention, express your views, and challenge the decision. Contact us at https://astrix2u.com/contact with the subject line "Request for Human Review of Automated Assessment"

6.1 Third-Party Service Providers

6.4 International Data Transfers

Astrix2u operates in Malaysia, UK, and Singapore. Your data may be transferred internationally with appropriate safeguards including Standard Contractual Clauses (SCCs), encryption, and access controls.

Right to Erasure

You have the right to request deletion of your personal data. Submit a request through https://astrix2u.com/contact

Response Timeline: Malaysia PDPA: 30 days | UK GDPR: 30 days (extendable to 90 days)

How to Exercise Your Rights

Contact us at https://astrix2u.com/contact

Include: Your name, account details, which right you're exercising, and description of the data involved.

What Microsoft Clarity Collects:

• Session Recordings: Anonymous recordings of user interactions (clicks, scrolls, mouse movements)
• Heatmaps: Aggregated data showing where users click and scroll
• User Behavior Metrics: Page views, session duration, bounce rates
• Device Information: Browser type, screen resolution, operating system

Privacy Protections:

• Sensitive content (passwords, payment fields) is automatically masked
• Personal data in forms is not recorded
• IP addresses are anonymized
• No cross-site tracking is performed

Where Clarity is Used:

• ✓ Landing page (astrix2u.com)
• ✓ User application (console.astrix2u.com)
• ✗ NOT used on admin pages for privacy and security

Your Choices:

You can opt out of Microsoft Clarity tracking by:

• • Using browser privacy settings to block third-party scripts
• • Installing browser extensions that block analytics (e.g., uBlock Origin, Privacy Badger)
• • Contacting us to request exclusion from analytics tracking