MASTER PRIVACY POLICY
Effective Date: [TO BE DETERMINED AT LAUNCH]
Last Updated: 2026-01-31
Applicable To: All ASI Network Businesses (B1–B17)
1. Introduction
ASI Network ("we," "us," "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, store, and share your personal information when you use our Services across all business lines (B1–B17).
Scope: This policy applies to all ASI Network websites, products, services, and platforms.
Consent: By using our Services, you consent to the data practices described in this policy.
2. Information We Collect
2.1 Information You Provide
We collect information you voluntarily provide when you:
- Create an account
- Make a purchase
- Subscribe to newsletters
- Contact customer support
- Participate in community discussions
- Submit forms or surveys
Types of information:
- Name, email address, phone number
- Billing and shipping addresses
- Payment information (processed by third-party payment processors)
- Account credentials (username, password)
- Profile information (interests, preferences)
- Communication content (support tickets, messages)
2.2 Information Automatically Collected
When you use our Services, we automatically collect:
- Device information: IP address, browser type, operating system, device identifiers
- Usage data: Pages visited, features used, time spent, click patterns
- Cookies and tracking technologies: See Section 6 for details
- Location data: General location based on IP address (not precise GPS unless explicitly permitted)
2.3 Information from Third Parties
We may receive information from:
- Payment processors: Transaction confirmations (we do not store full credit card numbers)
- Analytics providers: Aggregated usage statistics
- Marketing partners: Opt-in email lists (with your consent)
- Social media platforms: If you connect accounts or share content
3. How We Use Your Information
We use collected information for the following purposes:
3.1 Service Delivery
- Process orders and transactions
- Deliver digital products and physical goods
- Provide customer support
- Send transactional emails (order confirmations, shipping updates, account notifications)
- Grant access to subscriptions and community features
3.2 Service Improvement
- Analyze usage patterns to improve Services
- Conduct research and development
- Test new features
- Monitor system performance and troubleshoot issues
3.3 Marketing & Communication (With Consent)
- Send promotional emails and newsletters (opt-in required)
- Provide personalized content recommendations
- Announce new products or features
- Conduct surveys and gather feedback
3.4 Legal & Security
- Prevent fraud and abuse
- Enforce Terms of Service
- Comply with legal obligations
- Protect intellectual property
- Respond to legal requests and court orders
4. Legal Basis for Processing (GDPR Compliance)
For users in the EU/UK, we process personal data based on:
- Consent: Marketing communications, optional features
- Contract performance: Order fulfillment, account management
- Legitimate interests: Service improvement, fraud prevention, system security
- Legal obligation: Tax compliance, regulatory requirements
5. Data Sharing & Disclosure
5.1 Service Providers
We share data with third-party service providers who assist with:
- Payment processing (Stripe, PayPal, etc.)
- Email delivery (email service providers)
- Hosting and infrastructure (cloud storage, CDNs)
- Analytics (usage tracking, performance monitoring)
- Shipping and fulfillment (for physical products)
Provider obligations: All service providers are contractually obligated to protect your data and use it only for specified purposes.
5.2 Business Transfers
If ASI Network is involved in a merger, acquisition, or asset sale, your information may be transferred to the acquiring entity. You will be notified of any ownership changes.
5.3 Legal Requirements
We may disclose information when required by law:
- Court orders or subpoenas
- Government investigations
- Legal claims or disputes
- Protection of rights, property, or safety
5.4 With Your Consent
We may share information with third parties when you explicitly consent (e.g., connecting accounts, public community posts).
5.5 We Do NOT Sell Personal Data
ASI Network does not sell your personal information to third parties for marketing purposes.
6. Cookies & Tracking Technologies
6.1 What Are Cookies?
Cookies are small text files stored on your device to enable functionality and track usage.
6.2 Types of Cookies We Use
- Essential cookies: Required for basic functionality (login, shopping cart)
- Analytics cookies: Track usage patterns to improve Services
- Marketing cookies: Deliver personalized content and ads (opt-in required)
6.3 Cookie Management
You can manage cookie preferences through:
- Browser settings (most browsers allow blocking cookies)
- Our cookie consent banner (where applicable)
- Opt-out tools provided by analytics providers
Note: Disabling essential cookies may limit functionality.
7. Data Retention
7.1 Retention Periods
We retain personal information for as long as necessary to:
- Fulfill the purposes described in this policy
- Comply with legal obligations (tax records: 7 years minimum)
- Resolve disputes and enforce agreements
7.2 Account Deletion
Upon account deletion or termination:
- Personal information is deleted within 90 days
- Some data may be retained for legal compliance (transaction records, tax documentation)
- Anonymized data may be retained for analytics
8. Data Security
8.1 Security Measures
We implement industry-standard security practices:
- Encryption in transit (HTTPS/TLS)
- Encryption at rest for sensitive data
- Access controls and authentication
- Regular security audits
- Employee training on data protection
8.2 No Guarantee
While we take reasonable precautions, no system is 100% secure. We cannot guarantee absolute security and are not liable for unauthorized access due to factors beyond our control.
8.3 Breach Notification
In the event of a data breach, we will notify affected users as required by applicable law.
9. Your Rights & Choices
9.1 Access & Correction
You have the right to:
- Access your personal information
- Correct inaccurate information
- Request a copy of your data
How to exercise: Contact support or use account settings.
9.2 Deletion
You may request deletion of your personal information, subject to legal retention requirements.
9.3 Opt-Out of Marketing
You may opt out of promotional emails by:
- Clicking "unsubscribe" in any marketing email
- Updating email preferences in account settings
- Contacting support
Note: You cannot opt out of transactional emails (order confirmations, account notifications).
9.4 Do Not Track
Our Services do not currently respond to browser "Do Not Track" signals.
9.5 Rights for EU/UK Users (GDPR)
If you are located in the EU or UK, you have additional rights:
- Right to object: Object to data processing based on legitimate interests
- Right to restrict processing: Request temporary restriction of processing
- Right to data portability: Receive your data in a machine-readable format
- Right to withdraw consent: Withdraw consent for processing at any time
How to exercise: Contact our Data Protection Officer (contact details below).
9.6 Rights for California Users (CCPA)
If you are a California resident, you have the right to:
- Know what personal information is collected
- Know if personal information is sold or disclosed
- Opt out of the sale of personal information (we do not sell data)
- Request deletion of personal information
- Not be discriminated against for exercising rights
How to exercise: Contact support with "CCPA Request" in the subject line.
10. International Data Transfers
ASI Network operates globally. Your information may be transferred to and processed in countries other than your country of residence.
Safeguards: When transferring data internationally, we use:
- Standard contractual clauses (EU-approved)
- Adequacy decisions (countries with equivalent data protection)
- Service provider agreements requiring data protection
11. Children's Privacy
Our Services are not directed to individuals under 18. We do not knowingly collect personal information from children under 18. If we discover such collection, we will delete the information immediately.
Parental notice: If you believe your child has provided information without consent, contact us immediately.
12. Third-Party Links
Our Services may contain links to third-party websites or services. This Privacy Policy does not apply to third-party sites. We are not responsible for third-party privacy practices.
Recommendation: Review the privacy policies of any third-party sites you visit.
13. Business-Specific Data Practices
B1: Digital Product Purchases
Data collected:
- Email address (for delivery and support)
- Purchase history and product preferences
- Payment information (processed by payment provider, not stored by us)
Retention: Purchase records retained indefinitely for customer support and tax compliance.
B2: Ecommerce Products
Data collected:
- Shipping address and contact information
- Order details and customization preferences
- Payment information (processed by payment provider)
Retention: Shipping records retained for 2 years for warranty and support purposes.
Sharing: Shipping addresses shared with fulfillment partners and shipping carriers.
B3: Newsletter & Community Access
Data collected:
- Email address and communication preferences
- Content engagement metrics (opens, clicks, reads)
- Community activity (posts, comments, interactions)
Retention: Email list data retained until unsubscribe. Community posts may be retained indefinitely (anonymized if account deleted).
Sharing: Email delivery service providers only.
B4: Service Engagements
Data collected:
- Project requirements and deliverable specifications
- Communication history (emails, meetings, revisions)
- Payment information (processed by payment provider)
Retention: Project files retained for 1 year post-delivery for support purposes. Communication records retained for 3 years for dispute resolution.
Sharing: No third-party sharing except payment processing.
B5–B17: Future Services
Data practices for future business lines will follow the same principles outlined in this policy. Business-specific practices will be detailed upon launch.
14. Changes to This Policy
We may update this Privacy Policy to reflect:
- Changes in Services
- New legal requirements
- Improvements in data practices
Notification: Material changes will be communicated via:
- Email notification to account holders
- Prominent notice on website
- Updated "Last Updated" date at the top of this document
Continued use: Using Services after changes constitutes acceptance of the updated policy.
15. Contact Information
For privacy-related questions, requests, or concerns:
General Inquiries:
Email: [TO BE CONFIGURED AT LAUNCH]
Support Portal: [TO BE CONFIGURED AT LAUNCH]
Data Protection Officer (GDPR/EU inquiries):
Email: [TO BE CONFIGURED AT LAUNCH]
CCPA Requests (California residents):
Email: [TO BE CONFIGURED AT LAUNCH]
Subject line: "CCPA Request"
Mailing Address:
[TO BE CONFIGURED AT LAUNCH]
Document Status: PRE-LAUNCH DRAFT | REQUIRES LEGAL REVIEW BEFORE PRODUCTION USE
Compliance Notes
- GDPR compliance mechanisms in place (legal basis, data subject rights, DPO contact)
- CCPA compliance mechanisms in place (California resident rights, opt-out procedures)
- Cookie consent mechanisms required for EU users
- Data transfer safeguards documented
- Children's privacy protections implemented
Next Steps
- Engage legal counsel to review and finalize Privacy Policy
- Configure Data Protection Officer contact information
- Implement cookie consent banner for EU users
- Establish data subject rights request procedures
- Review business-specific practices for B5–B17 upon activation