1. Introduction
Pawer Ltd. (“we”, “us”, or “our”) respects the importance of protecting the personal data of users who interact with the Pawer platform and related services (“you” or “your”).
This Privacy Policy explains how we collect, use, disclose, and safeguard your personal data in accordance with the Law on Cybersecurity and applicable data protection regulations of Vietnam.
2. Personal Data We Collect
We collect personal data only as necessary for the purposes described in this Privacy Policy. The types of personal data we collect include:
- Account Information: Name, username, email address, account ID
- Authentication Data: Login records, hashed passwords, OTP verification data
- Usage and Technical Data: System logs, session activity, test case data, device and browser information, IP addresses
- Payment Information: Subscription tier, credit balance, and transaction records (we do not store credit card numbers directly)
- User-Uploaded Content: Application files (APK), screenshots, test artifacts, and context documents uploaded to the platform
3. Purposes of Data Collection
We collect, use, and/or disclose your personal data for the following purposes:
- To manage user registration and maintain your account on the Pawer platform
- To provide, operate, and administer the Pawer testing services
- To verify your identity during registration or authentication
- To communicate with you regarding system usage, updates, and support
- To monitor, maintain, and improve platform performance, security, and functionality
- To detect, prevent, and resolve technical issues, security threats, or misuse
- To process payments and manage subscription billing
- To comply with applicable laws, regulations, and legal obligations
4. Legal Bases for Processing
We process your personal data based on one or more of the following legal bases:
- Performance of a contract to which you are a party (your use of the Pawer platform)
- Legitimate interests necessary for platform operation, security, and service improvement
- Compliance with legal obligations under Vietnamese law
- Your consent, where required by applicable law
5. Data Sharing and Disclosure
We may disclose or transfer your personal data to third parties only as necessary and subject to appropriate safeguards:
- Infrastructure Providers: Cloud service providers (AWS, Cloudflare), database hosting, and CDN services that support our platform operations
- AI Service Providers: AI model providers used to power the automated testing agents. Test data may be processed by these providers to execute test sessions
- Integration Partners: Third-party services you choose to connect, such as Jira, Google OAuth, or webhook endpoints
- Legal and Regulatory Authorities: Where disclosure is required to comply with laws, court orders, or legal processes
- Professional Advisers: Legal, accounting, or technical advisers supporting business operations
6. Cross-Border Data Transfers
Your data may be processed and stored on servers located outside Vietnam, including in the United States or other jurisdictions where our infrastructure providers operate. Where personal data is transferred internationally, we ensure that appropriate safeguards are in place to protect your data in accordance with applicable laws.
7. Data Retention
We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by law. Specifically:
- Account data is retained for the duration of your account and for a reasonable period after account closure
- Test session data, including screenshots and test results, is retained for 90 days after session completion unless you request earlier deletion
- Log data and system records are retained for up to 12 months for security and troubleshooting purposes
- Payment and transaction records are retained as required by Vietnamese tax and accounting regulations
8. Data Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- Encryption of data in transit (TLS/SSL) and at rest
- Secure authentication with hashed passwords and OTP verification
- Role-based access controls and audit logging
- Regular security reviews and infrastructure monitoring
- Bot protection via Cloudflare Turnstile
9. Your Rights
Subject to applicable law, you have the following rights regarding your personal data:
- Access: Request access to the personal data we hold about you
- Correction: Request correction of inaccurate or incomplete data
- Deletion: Request deletion of your personal data, subject to legal retention requirements
- Portability: Request a copy of your data in a structured, commonly used format
- Withdrawal of Consent: Withdraw consent at any time where processing is based on consent
- Objection: Object to the processing of your data based on legitimate interests
To exercise your rights, please contact us at the details provided below.
10. Cookies and Tracking
The Pawer platform uses essential cookies for authentication and session management. We use Cloudflare Turnstile for bot protection, which may set its own cookies. We do not use advertising or tracking cookies.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated “Last updated” date. We encourage you to review this page periodically.
12. Contact Us
If you have any questions about this Privacy Policy or wish to exercise your data rights, please contact: