Privacy Policy

This Privacy Policy (hereinafter referred to as the “Policy”) sets forth the procedures for the collection, use, storage, transfer, and protection of users’ personal data when using the website, Telegram bot, Telegram Mini App, and related services (hereinafter collectively referred to as the “Platform”).

The Policy explains what data may be processed, for what purposes it is used, under what circumstances it may be transferred to third parties, and what rights users possess regarding their personal data.

We strive to ensure adequate protection of personal data and to process it in compliance with applicable law.

The scope of information collected depends on the features used, the nature of interaction with the Platform, and requirements applicable to the respective services.

By using the Platform, the user confirms that they have read and understood this Policy. If the user does not agree with its provisions, they should cease using the respective services.

Within the scope of this Policy, the following terms have the meanings set forth below:

“Personal Data” — any information relating to an identified or identifiable natural person.

“User” — a natural person who accesses the Platform or uses its features.

“Platform” — the website, Telegram bot, Telegram Mini App, and other related digital interfaces through which services are provided.

“Data Processing” — any operation performed on personal data, including collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment or combination, restriction, erasure, or destruction.

“Third Parties” — service providers, technology partners, payment institutions, and other entities that may receive or process data in connection with the provision of services.

“Services” — features available through the Platform, including the cryptocurrency wallet, digital asset operations, payment cards, and other available tools.

“Digital Assets” — cryptocurrencies, tokens, and other digital assets supported by relevant Platform features.

Other terms may be defined in this Policy, the Terms of Use, or supplementary documents governing specific services.

This Policy applies to users of the Platform and covers the processing of personal data when using the website, Telegram bot, Telegram Mini App, contacting customer support, and interacting with other related services.

It also applies to data that may be provided directly by the user, collected automatically during use of the Platform, or lawfully received from third parties.

This Policy is intended for users across various countries and jurisdictions. Certain provisions may apply taking into account the laws of the user’s country of residence and the nature of services provided to them.

If applicable law grants the user additional rights regarding personal data, such rights are preserved to the extent prescribed by law.

Depending on the features used, the following categories of information may be processed:

Account and Profile Data:

• username and Telegram identifier (ID);
• details provided during registration or profile setup;
• email address or other contact details if requested;
• account preferences and security settings.

Identification and Verification Data:

• information necessary for identity verification where required for a specific service;
• documents and information submitted during the verification process;
• verification results conducted by authorized service providers.

The provision of such data depends on the requirements of the specific service. It should not be assumed that all features require the same extent of identification data.

Cryptocurrency Wallet and Transaction Data:

• cryptocurrency wallet addresses;
• details regarding digital assets and supported networks;
• transaction amounts, dates, statuses, and transaction hashes/identifiers;
• details regarding top-ups, transfers, swaps/exchanges, and withdrawals;
• information on fees and available balances, if processed by the respective service.

Payment Card and Transaction Data:

• details regarding issued or ordered cards;
• information on payments, authorizations, and declined transactions;
• transaction history, amounts, dates, and transaction statuses;
• data necessary for card maintenance and processing customer requests.

Full card details and other sensitive payment data may be processed by the relevant payment infrastructure provider. The actual composition of data depends on the integration used.

Technical Data:

• IP address and approximate location data, where available;
• device type, operating system, and browser;
• technical logs, error reports, and security event logs;
• information regarding time and method of Platform usage.

Customer Support Inquiry Data:

• contents of messages;
• details provided for inquiry review;
• communication history and support team responses;
• documents and materials voluntarily submitted by the user to resolve an issue.

Preferences and Interaction Data:

• selected settings and preferences;
• participation in referral programs and promotional campaigns;
• consent to receive marketing communications;
• details regarding interaction with available features.

Users should not transmit passwords, secret recovery seed phrases, private keys, or other critical access credentials through support requests or other communication channels unless the corresponding feature explicitly provides a secure method for handling them.

When using the Platform, certain technical information may be collected automatically to ensure operational performance, error analysis, fraud prevention, and enhanced security.

The use of cookies and similar technologies, where applied, is carried out in accordance with their designated purpose and applicable statutory requirements.

The primary source of information is data provided by the user upon registration, profile setup, use of services, contact with customer support, or participation in available programs.

Certain data is generated in the course of service operations, including technical logs, activity history, transaction details, and security events.

Where necessary, information may be received from payment service providers, card issuers, blockchain analytics providers, infrastructure partners, and other parties involved in delivering a specific service.

Where necessary and permitted by law, publicly available sources of information may be used to verify transactions, detect fraud, or comply with applicable legal requirements.

Where required by law, processing is carried out based on user consent. Consent may be provided via the Platform interface or another method allowing confirmation of user intent.

The user is entitled to withdraw consent in cases provided by law. Withdrawal does not affect the lawfulness of processing carried out prior to receipt of the withdrawal.

Processing may be necessary to provide requested services, execute the Terms of Use, process transactions, maintain accounts, and fulfill obligations to the user.

Information may be processed to comply with applicable statutory requirements, including anti-fraud rules, financial monitoring, and transaction scrutiny, where applicable to the service or provider involved.

Where permitted by law, data may be processed to maintain security, prevent abuse, improve services, investigate incidents, and defend legitimate rights.

When relying on this basis, user rights and freedoms, as well as the necessity and proportionality of processing, are taken into account.

Data may be used to review claims, investigate disputed transactions, comply with lawful requests of competent authorities, and establish, exercise, or defend legal claims.

The necessity of identity verification depends on the specific service, service provider requirements, and applicable law.

Where verification is required, the user may be obligated to submit additional details or documents. Failure to submit required information may result in the inability to use the corresponding feature or restricted access to it.

Transactions may be screened to detect suspicious activity, technical errors, fraud, and other circumstances that could impact the security or lawfulness of the operation.

In cases provided for by applicable rules or service terms, an operation may be delayed, rejected, or restricted. Depending on circumstances, account data, transaction details, and associated technical data may be utilized to review the operation.

To ensure security and stable operation of services, automated tools may be utilized for transaction analysis, suspicious activity detection, technical anomaly identification, and abuse prevention.

Results of automated analysis may be used to flag operations for additional review, restrict certain actions, or determine the need for manual review.

If applicable law grants the user the right to contest a decision based solely on automated processing that produces legal effects or similarly significantly affects their interests, such right may be exercised in accordance with statutory procedures.

The user is responsible for the veracity of the information they provide. If data has changed or contains an error, the user may contact support to ascertain the feasibility of rectification.

Transactions on public blockchains may be visible to an indeterminate circle of persons. Depending on the network, wallet addresses, transfer amounts, transaction timestamps, and other technical metadata may be publicly accessible.

Information recorded directly onto a public blockchain generally cannot be modified or erased upon user request via conventional data deletion procedures.

A public wallet address does not in itself always disclose the identity of its holder. However, when matched with supplementary information, an address may become linked to an identifiable individual.

Accordingly, the processing of wallet addresses and related transaction details may fall under data protection statutory requirements depending on specific circumstances.

Personal data may be disclosed to third parties when necessary to deliver services, ensure security, perform contractual obligations, or comply with applicable law.

Disclosure is carried out taking into account processing purposes, data nature, and applicable information security standards.

Depending on the features used, recipients of data may include:

• hosting, cloud infrastructure, and technical service providers;
• payment infrastructure providers and card issuers;
• digital asset and transaction processing providers;
• transaction monitoring and fraud detection services;
• technical support and communication tool providers;
• professional advisors, auditors, and insurers, where their participation is necessary;
• public authorities, courts, and other authorized institutions in cases provided by law.

Service providers may access data to the extent required to execute their assigned tasks. Depending on the nature of relationships, they may process data on behalf of another party or act as independent controllers.

Data processing by such providers may additionally be governed by their own privacy policies and contractual terms.

Data may be disclosed to competent authorities where such disclosure is mandated by applicable law, judicial orders, or binding lawful requests.

In the event of a reorganization, merger, acquisition, financing, or asset sale, data may be transferred to relevant transaction participants to the extent required for transaction execution, subject to applicable confidentiality and data protection requirements.

Personal data is not sold to third parties as a standalone commodity. This provision does not preclude data transfer to service providers or other processing described in this Policy.

Personal data is retained only for the period necessary for the purposes set forth in this Policy, unless a longer retention period is required or permitted by applicable law.

The retention period depends on data category, service nature, duration of relationship with the user, and statutory compliance needs.

In particular:

• account data may be retained for the duration of service use and following its termination if necessary for dispute resolution or statutory compliance;
• transaction details may be retained for the period necessary for transaction accounting, investigation of disputed matters, and compliance with applicable requirements;
• customer support communications may be retained during inquiry review and for a reasonable period thereafter;
• technical logs may be retained for a limited duration unless extended retention is required for security incident investigations;
• records of consent for marketing communications may be retained to demonstrate user choices and honor opt-out requests.

Upon expiration of the retention period, data is deleted, anonymized, or otherwise removed from active use, unless continued retention is required by law or for establishing, exercising, or defending legal claims.

A user request for data erasure is considered in accordance with applicable law and potential record retention obligations.

To safeguard information against unauthorized access, modification, disclosure, loss, or destruction, reasonable technical measures are implemented, proportionate to the nature of processed data and associated risks.

Depending on systems utilized, such measures may include access control, in-transit encryption, event logging, vulnerability management, and payment infrastructure safeguards.

Access to personal data is restricted to personnel who require it to perform their assigned functions. When engaging third-party providers, the nature of services, terms of cooperation, and confidentiality obligations are taken into account.

Users are strongly advised to implement robust account protection measures, never disclose verification codes to third parties, and immediately report suspicious activity.

Where additional security features are available in the service used, including two-factor authentication (2FA), users are advised to enable them.

Notwithstanding the implementation of reasonable measures, no method of data transmission or storage can guarantee absolute security. Consequently, it is impossible to entirely eliminate all risks associated with digital services.

In the course of service delivery, messages may be sent to the user regarding account security, transaction statuses, updates to terms of service, and other critical events.

Such communications are necessary for proper service functionality and are not classified as marketing communications.

Promotional and marketing messages are sent in cases and manners permitted by applicable statutory law.

Where user consent is required for such communications, it is requested in an appropriate manner.

The user may opt out of marketing communications via available unsubscribe mechanisms or by contacting support. Opting out does not affect receipt of mandatory service notifications necessary for service provision or security.

For inquiries concerning this Policy, the user may contact support via the “Help” section in the application or utilize official communication channels listed on the website.

When submitting an inquiry, users are advised to describe the matter and provide details necessary for its review. Passwords, private keys, or secret recovery phrases must never be included in any message.

If a user believes their personal data is being processed in breach of applicable requirements, they may submit a complaint for investigation.

The user is also entitled to contact a competent data protection authority in cases and manners provided by applicable law.

The processing of personal data is carried out taking into account the legislation applicable to the relevant relationships and services.

The specific applicable law is determined taking into account the legal entity providing the corresponding service, contractual conditions, and mandatory statutory rules. This Policy does not of itself establish jurisdiction not substantiated by appropriate legal instruments.

Users are encouraged to first submit an inquiry through official communication channels to review the matter and seek an amicable resolution.

This does not restrict the user’s right to seek recourse before competent authorities or courts where such right is provided by applicable law.

If any provision of this Policy is found to be invalid or unenforceable, this does not affect the validity of the remaining provisions, unless otherwise provided by applicable law.

This Policy is applied in conjunction with the Terms of Use and other documents governing specific services. In the event of discrepancies between documents, interpretation is conducted taking into account applicable law and the nature of respective relationships.

The user may review the active version of the Policy on the official website or in the corresponding section of the Platform.