“JTCG (Raccoon AI)” (hereinafter referred to as the “Service”) is provided by James Tech Consulting Co., Ltd.(hereinafter referred to as “JTCG,” “we,” or “us”). We highly value the privacy of users of the Service and protect the security of your personal data in accordance with the Personal Data Protection Act and applicable laws and regulations.

This Privacy Policy (hereinafter referred to as the “Policy”) explains how JTCG collects, processes, and uses your personal data. To safeguard your rights and interests, please read this Policy carefully. By visiting or using the Service, you acknowledge and agree that JTCG may collect, process, and use the personal data you provide to JTCG and/or the personal data relating to you that JTCG possesses in accordance with this Policy.

​

1. Scope of Application

This Policy applies to all personal data collected by JTCG for purposes related to providing the Service, including:

• Information you provide to us when using the Service;

• Information about you provided to us by third parties;

• Information collected by us when you use the Service.

In most service scenarios, JTCG provides the Service in accordance with customer instructions and acts as a Processor in processing the personal data of the customer’s end users, while the customer acts as the Controller responsible for determining the purposes and means of collection and processing of such data. JTCG will process such data solely as necessary to provide the Services and will not use it for any purpose outside the scope of the Services, including the development or training of general-purpose AI models, unless otherwise agreed or required by applicable law.

In most service scenarios, JTCG processes personal data pursuant to the customer’s written or electronic instructions, including but not limited to service interface settings, API instructions, or other electronic methods, and uses such data only to the extent necessary to provide the Service.

Unless otherwise required by law or agreed between the parties, JTCG does not sell, share, or use customer service data for purposes unrelated to the provision of the Service.

Customer service data and all associated rights remain the property of the customer.

​

2. Purposes of Personal Data Collection

JTCG collects, processes, and uses personal data for purposes including but not limited to:

1. Providing, operating, managing, and improving the Service;

2. Creating and managing user accounts, identity verification, and account security management;

3. Providing customer support, service notifications, troubleshooting, and technical maintenance;

4. Providing AI automated responses, data analysis, and related service functionalities;

5. Analyzing Service usage, conducting statistical research, and optimizing product functionality;

6. Conducting marketing, event notifications, business communications, and customer relationship management (where required by applicable law, consent will be obtained where necessary);

7. Maintaining information security and preventing abuse, fraud, unauthorized access, or other conduct that may compromise Service security;

8. Performing contractual obligations, complying with legal requirements, handling disputes, and protecting the lawful rights and interests of JTCG, customers, or third parties.

In addition, in most service scenarios, JTCG acts as a Processor in processing data in accordance with customer instructions. AI technologies process data solely for purposes of providing automated responses, data analysis, and related service functionalities and shall not use customer data for purposes unrelated to the provision of the Service without authorization.

​

3. Categories of Personal Data Collected

3.1 Categories of Data Collected

When you use the Service, we collect the following categories of information:

(1) Identity and Contact Information

For example:

• name

• company name

• job title

• email address

• telephone number

• or other contact information.

(2) Personal Description Information

For example:

• date of birth

• gender

• or other descriptive information voluntarily provided by users.

(3) Account and Security Verification Information

For example:

• account information

• login credentials

• passwords

• or other information related to account security and identity verification.

(4) AI and Service Interaction Data

For example:

• user-input conversation content

• queries and instructions

• AI-generated responses

• interaction records

• feedback information

• and related communication metadata.

(5) Other Information Provided by Users

For example:

• contact form submissions

• customer support interaction information

• event registration information

• survey responses

• attachments

• or other information voluntarily provided by users.

(6) Third-Party Platform and Integration Service Data

Where the Service integrates with third-party platforms or services, JTCG may process relevant:

• account information

• configuration information

• service interaction records

• or statistical information

based on customer authorization or service requirements.

​

3.2 Automatically Collected Data

We collect records of your activities when using the Service, as well as information relating to the devices you use to access the Service.

When you browse or search within the Service, the Service will automatically record information including:

• IP address

• browser type

• operating system

• device information

• access time

• browsing records

• and related connection information.

Such information is used solely for purposes of:

• statistical analysis;

• and service optimization,

and will not be linked to specific individuals.

​

3.3 Advertising, Marketing and Third-Party Platform Data

The Company may obtain statistical and technical information related to advertising placement, marketing analysis, or service promotion through third-party platforms or API services, including but not limited to:

• Meta (Facebook) Marketing API

• Google Ads API

• and other authorized platform services.

Such information may include:

• advertising campaign performance metrics (such as impressions, clicks, advertising spend, conversions, etc.);

• advertising campaign configuration information (such as campaign names, status, and campaign types);

• advertising creative information;

• and other statistical information related to advertising placement, service analysis, or platform integrations.

Unless otherwise specified, the foregoing information primarily consists of aggregated statistics, service operational information, or platform technical information and does not necessarily include personal data of users of Meta, Google, or other third-party platforms.

The Company shall not use data obtained through the foregoing APIs to develop, improve, or train general AI/ML models.

​

3.4 Data You Provide to JTCG

This may include:

• name, email address, company name, and other information submitted through contact forms;

• information provided during interactions with our customer support;

• and information provided when participating in online events or surveys organized by the Company.

​

3.5 AI Service Interaction Data

For purposes of providing AI-related services, JTCG may process information related to AI interactions, including but not limited to:

• user-input conversation content, queries, and instructions;

• AI-generated response suggestions;

• conversation records and interaction logs;

• and communication metadata (such as time, device, and connection information).

The foregoing information shall be processed solely within the scope necessary for:

• providing the Service;

• maintaining system security;

• improving functionalities;

• and performing contractual purposes.

​

4. Retention Period, Geographic Region, Recipients, and Methods of Data Use

4.1 Retention Period

JTCG shall retain your personal data for the period necessary to provide the Service and fulfill relevant contractual purposes.

Unless otherwise required by law or necessary for legitimate business purposes (including but not limited to dispute resolution, taxation, or legal compliance requirements), relevant personal data shall be deleted or de-identified following termination of the Service or disappearance of the applicable purpose, depending on the nature of the data and the processing environment.

For service data stored within cloud environments directly controlled by JTCG, deletion or de-identification shall in principle be completed within thirty (30) days following Service termination.

For data involving third-party platforms or integration services, deletion procedures and timelines may be subject to the data deletion policies and service terms of such platforms.

​

4.2 Geographic Region of Use

The geographic regions of use include:

• Taiwan

• Japan

• Thailand

• and other regions necessary for providing the Service.

JTCG may process and store data through cloud service providers, data processing services, or third-party platforms located in different countries or regions.

The core data processing environment of the Service is primarily deployed within cloud infrastructure maintaining appropriate security and data protection standards, including:

• Japan

• or other Asia-Pacific data centers.

Actual storage and processing locations may vary depending on:

• service architecture;

• system functionality;

• or third-party service requirements.

Where cross-border transfer of personal data is involved, JTCG shall implement appropriate safeguards in accordance with applicable laws and data protection requirements, including but not limited to:

• transfer to countries or regions with adequate protection standards;

• application of Standard Contractual Clauses (SCCs);

• or other legally permissible cross-border transfer mechanisms.

Such measures are implemented to ensure secure and lawful processing of personal data.

Customers further understand and agree that the processing and storage locations of certain third-party service providers or AI model services may vary according to their global infrastructure deployment and privacy policies.

​

4.3 Recipients of Data Use

Unless otherwise provided by law or this Policy, JTCG shall use your personal data only within the scope of the Service purposes consented to by you and for purposes of improving and enhancing the Service.

JTCG will not arbitrarily provide your personal data to third parties or use such data for unrelated purposes.

​

4.4 Methods of Data Use

In addition to use within the scope of the foregoing collection purposes, your personal data may also be used according to your actual needs as follows:

Statistical Analysis
Analyzing advertising performance, generating internal business analysis reports, and improving and enhancing service quality.

Marketing and Services
Sending service notifications or using your information when you contact us and request a response.

Legal or Governmental Requirements
Providing relevant information in accordance with laws or governmental requests.

For the purpose of providing the Services, facilitating implementation, delivering technical support, troubleshooting issues, performing system maintenance, responding to information security incidents, or otherwise fulfilling obligations related to the Services, authorized personnel of JTCG may, to the extent necessary, access data created, uploaded, or processed by the Customer through the Services, including but not limited to conversation records, knowledge base content, system configurations, and other data related to the Services. JTCG will adhere to the principle of least privilege and will access such data only to the extent necessary for the provision of the Services. JTCG will implement appropriate access controls and security measures and will not use such data for any purpose unrelated to the provision of the Services.

​

4.5 AI Data Usage and Model Training Restrictions

JTCG uses AI technologies solely for purposes necessary to:

• provide automated responses;

• conduct data analysis;

• improve system functionalities;

• and perform the Service.

Unless prior written consent is obtained from the customer, JTCG shall not use:

• customer personal data;

• service data;

• or content provided through the Service

including but not limited to:

• conversation content;

• FAQs;

• prompts;

• or agent configuration data,

for purposes of:

• training general AI models (Base Models);

• or improving services provided to other customers.

​

5. Personal Data Security Maintenance

With respect to your personal data files, JTCG shall implement appropriate security measures and adopt technical and organizational measures that meet reasonable industry standards in accordance with applicable laws and regulations to prevent your personal data from being:

• stolen;

• altered;

• damaged;

• lost;

• disclosed;

• or otherwise harmed in a manner that may affect your rights and interests.

JTCG will continuously review and update relevant measures in response to technological developments and evolving cybersecurity risks.

Relevant security measures include but are not limited to:

• encrypted data transmission and secure communication mechanisms;

• cloud infrastructure security and encryption key management;

• identity authentication mechanisms (certain scenarios may support multi-factor authentication or third-party authentication mechanisms);

• least-privilege principles and access control management;

• security logging, anomaly monitoring, and periodic security reviews;

• security management of vendors and sub-processors;

• logical segregation measures between AI systems and customer data processing environments.

If an incident occurs that may affect the security of personal data, JTCG shall take reasonable response measures in accordance with applicable laws and the nature of the incident and shall notify affected customers or users where legally required or reasonably necessary.

​

6. Special Categories / Sensitive Personal Data

As a general principle, the Service is not intended to collect, process, or use sensitive personal data.

Users and customers should avoid entering unnecessary sensitive information, including but not limited to:

• health information;

• medical information;

• biometric information;

• religious beliefs;

• political opinions;

• or other information specially protected under applicable laws,

and should implement appropriate de-identification or protective measures.

Unless otherwise required by law, expressly agreed between the parties, or necessary for providing the Service, JTCG will not proactively request sensitive personal data.

​

7. Rights and Methods for Exercising Rights Regarding Personal Data

7.1 Rights You May Exercise

You may exercise the following rights with respect to your personal data by contacting JTCG:

• request inquiry or review;

• request copies;

• request supplementation or correction;

• request cessation of collection, processing, and use;

• request deletion.

​​

7.2 Methods for Exercising Rights

Please contact us via email at:

support@j-tcg.com

The Company will complete processing within thirty (30) days after receiving your request.

​

8. Use of Cookies

To provide you with the best possible service, the official JTCG Raccoon AI website may place and access Cookies on your computer.

If you do not wish to accept Cookies, you may set your browser privacy settings to a higher level to refuse Cookies.

However, doing so may result in certain website functions being unavailable or unable to operate properly.

​

9. Impact of Not Providing Personal Data

You may freely decide whether to provide relevant personal data and the completeness of the information provided.

However, if you refuse to provide relevant personal data, or fail to provide accurate and complete personal data, JTCG may be unable to conduct certain business operations, which may result in your inability to use all or part of the Service functionalities.

To the extent necessary to provide the Services, JTCG may engage trusted third-party cloud service providers, AI service providers, and other technology vendors to process data on its behalf. JTCG requires such providers to implement appropriate technical and organizational security measures and to process such data solely as necessary to provide the Services.

​

10. Information Sharing and Disclosure

10.1 General Principle

Except as otherwise provided by this Policy, JTCG will not provide your personal data to third parties.

​

10.2 Third-Party Service Providers and Sub-Processors

JTCG may engage certain trusted third-party companies and individuals to assist us in providing, analyzing, and improving the Service, including but not limited to:

• data storage;

• data management and analytics;

• and service functionality improvement.

These third parties may have access to your information only to the extent necessary to perform such functions on our behalf.

JTCG may engage trusted third-party service providers (Sub-processors) to assist in providing, maintaining, analyzing, and improving the Service, including but not limited to:

• cloud infrastructure services (such as AWS);

• AI model and natural language processing services;

• customer support and conversational platforms;

• system monitoring and analytics tools.

Such providers may include:

• Amazon Web Services (AWS);

• OpenAI;

• Azure OpenAI;

• Gemini;

• Zendesk;

• or other service providers evaluated as maintaining appropriate security and compliance standards.

JTCG shall require such third parties to process data only to the extent necessary and to implement security and confidentiality measures no less protective than reasonable industry standards.

​

10.3 Disclosure under Specific Circumstances

Under the following circumstances, we may review your personal data and provide it to relevant governmental authorities or third parties asserting infringement of their rights and presenting reasonable supporting evidence:

• where prior consent has been obtained from you;

• where required by law or pursuant to orders or requests from judicial or governmental authorities;

• where necessary to enforce this Policy or where you violate this Policy or may infringe the rights of third parties;

• where necessary to protect the lawful rights and interests of other Service users or third parties;

• where necessary to protect the lawful rights and interests of JTCG and its affiliates;

• or where necessary to maintain the normal operation of the Service.

​

10.4 Corporate Transactions or Business Transfers

In connection with:

• corporate restructuring;

• asset transfers;

• mergers and acquisitions;

• investments;

• reorganizations;

• or similar transactions,

JTCG may transfer or disclose relevant information to the extent necessary.

However, JTCG shall require the receiving party to continue processing relevant personal data under protection standards no less protective than those set forth in this Policy.

​

11. External Links

The Service may contain links to third-party websites or applications.

JTCG assumes no responsibility for the practices or conduct of such third-party websites or applications, and this Policy does not apply to any third-party websites or applications.

Before visiting or providing personal information to third-party websites or applications, please review the privacy policies of those respective websites or applications.

​

12. Changes to the Privacy Policy

JTCG may revise this Policy based on business needs or Service adjustments.

Revisions will be published on the Service website or notified to users via email.

If you continue using the Service after any modification or amendment to this Policy, you acknowledge that you have read, understood, and agreed to be bound by the modified or amended Policy.

​

13. Contact Information

If you have any questions regarding this Privacy Policy, please contact:

Company Name: James Tech Consulting Co., Ltd. (JTCG)

Service Brand: Raccoon AI

Contact Email: support@j-tcg.com

Website: https://raccoonai.co

Unified Business Number (Taiwan): 83523216