(last updated on April 12, 2025)

  1. GENERAL PROVISIONS
    1. CSB (hereinafter referred to as “Developer”) has developed this privacy policy (hereinafter referred to as “Policy”) to regulate the collection, storage, distribution, usage and protection of information pertaining to persons who use its service (hereinafter referred to as “Mini-App”).
    2. The current version of this Policy is displayed at the start of Mini-App’s use and is available in Mini-App.
    3. Your continued access to and use of Mini-App shall constitute your acceptance of Policy.
    4. If you do not accept any of Policy terms, you should immediately cease your use of Mini-App.
  2. TERMS AND DEFINITIONS
    1. Telegram – Telegram Messenger Inc.
    2. Developer – The person or legal entity who operates and maintains a mini app on Telegram.
    3. MiniApp – Developer’s interactive platform on Telegram.
    4. User – The person accessing Developer’s Mini-app via their account on Telegram (also “you”).
    5. Personal Data - Any information that Users may be requested to provide to Developer during the use of its Mini-App, including but not limited to: Telegram account name, full surname, first name, patronymic, type of identity document (for example, passport), the number of the identity document (for example, passport number), gender, date of birth, place of birth, nationality, residential address, country/state of residence, the purpose of using Mini-App, sources of income, the nature and details of the business/occupation/job, credit history, contact phone number, e-mail address, transaction and expense history, the blockchain address, location data, additional personal data or documentation at the discretion of Developer.
  3. DISCLAIMERS
    1. Developer’s Mini-App is an independent application that is neither maintained, endorsed, nor affiliated with Telegram.
    2. You understand and agree that this Policy may be amended at any time, and it is your responsibility to review and agree to all changes.
    3. You acknowledge that you have read, understood and agreed to the Terms and Conditions, as well as any other terms made available to you by Developer.
    4. You acknowledge and warrant that you possess all the necessary rights and permissions to use Mini-App in compliance with applicable local laws and legal obligations, including without limitation age restrictions and third-party store terms.
    5. Developer operates under the understanding that all information you provide is submitted in good-faith, and is not obligated to check or verify your statements for errors or inaccuracies. It is your responsibility to ensure that all information you provide is accurate and up-to-date.
    6. You may decide to make some information available in the public domain, either directly on Telegram, elsewhere on the internet, or via third-party services. The information you choose to make public may be accessed by others, in which case it will not be covered or protected by Policy.
  4. COLLECTION OF PERSONAL DATA
    1. The ways in which Telegram natively allows mini-apps to access certain limited information from and about User are described in the Telegram Privacy Policy and Mini App Terms.
    2. Without limiting clause 4.1., Mini-App has the ability to receive additional data from you if you send it messages, upload files to it, or choose to share any personal information described in clause 2.5. but not limited to it.
    3. Mini-App may also collect anonymous data that is not linked to you in any way, such as anonymized diagnostics or usage statistics.
  5. PROCESSING OF PERSONAL DATA
    1. Mini-App only requests, collects, processes and stores data that is necessary for its designated features to function properly and processes your personal data on the legal ground that such processing is necessary to further its legitimate interests, including:
      1. providing services to its Users;
      2. detecting and addressing security issues in respect of its provision of services;
      3. making decisions regarding the provision or continuation of the provision of services to any single User;
      4. administration, operation, provision, improvement and personalization of services in general;
      5. processing User’s payments and transactions, as well as providing User with statements, invoices, receipts and other relevant information related to the services;
      6. monitoring and registering the use of the services and communicating with Users (including for the purpose of investigating and preventing fraud);
      7. detecting, preventing and solving technical problems, with further explanations provided as necessary;
      8. risk assessment and data analysis, internal management and internal/external audit;
      9. contacting User regarding events, services and other services offered by Developer or its affiliated companies;
      10. conducting marketing research, surveys, promotions and contests, as well as analyzing the preferences, interests and behavior of User in relation to the services,
      11. complying with any applicable legal and regulatory requirements (including anti-money laundering obligations and tax obligations),
      12. ensuring compliance with or protection of the rights or property of Developer, its affiliates and other Users,
      13. fulfilling any other purposes described during data collection.
    2. In any event, Developer will only collect or otherwise aggregate user data in compliance with applicable laws, third-party store terms, and for no other purposes than those clearly stated in Policy and necessary to furnish and enhance the functionality of Mini-App.
  6. DATA PROTECTION
    1. Developer takes reasonable measures to ensure the safe handling of Users’ Personal Data in accordance with this Policy, and no transfer of the User’s Personal Data will be carried out to the organization or country unless appropriate control measures are taken, including the security of the User’s personal data and other personal information.
    2. User information is handled, transferred and stored in compliance with applicable laws, including all necessary precautions to prevent unauthorized access, modification, deletion, or distribution.
    3. Due to the nature of all online apps, data breaches may occur regardless of security measures taken by Developer. Should such a breach take place and lead to undesired exposure of User’s personal data, User agrees not to hold Developer liable for that misfortune or any of its consequences.
  7. DATA TRANSFER
    1. Developer has the right to share User’s personal data with the following persons for the above purposes:
      1. third-party service providers;
      2. employees of Developer and its affiliates;
      3. professional consultants of Developer and its subsidiaries;
      4. any person or organization with whom Developer enters into a legal relationship or in which the Developer participates for the purpose of marketing, advertising or promoting services, for example, social media platforms, online platforms or third-party websites;
      5. any person to whom Developer is obliged to disclose information in accordance with applicable law or court decision;
      6. any person or organization to whom User authorize the receipt of their personal data;
      7. any actual or alleged legal successor or recipient of Developer’s business and/or its affiliates.
    2. Developer also has the right to transfer generalized or anonymized personal data to the above-mentioned persons in order to facilitate the administration, operation, provision and improvement of services or monetize and otherwise utilize User data for applications outside the scope of this Mini-App.
  8. STORAGE OF PERSONAL DATA
    1. User’s personal data may be stored on computers located outside the state, province, country or other government jurisdiction in which User resides, where data protection laws may differ from the laws of User’s jurisdiction.
    2. Developer has the right to transfer data, including Personal Data, outside User’s jurisdiction and process it there.
    3. User’s consent to this Policy and the provision of such information by User means User’s consent to such transfer.
  9. THE PERIOD OF STORAGE OF PERSONAL DATA
    1. Developer stores User’s personal data only for the time necessary for the purposes set out in this Policy.
    2. Developer stores and uses User’s personal data to the extent necessary to comply with Developer’s legal obligations, resolve disputes and ensure compliance with Developer’s legal agreements and policies.
    3. Developer shall not be held liable for Telegram’s deletion of User data from its servers in response to abuse of charges.
  10. COMMUNICATIONS
    1. In order to ensure the quality of services, Developer has the right to send operational notifications to User, regarding important issues related to User’s account or the application.
    2. Developer has the right to inform User about news and promotions. User’s acceptance of the Policy shall be viewed as explicit consent to receiving promotional materials.
  11. FURTHER RIGHTS AND OBLIGATIONS
    1. Developer may:
      1. seek verification of the identity of User submitting data requests if they suspect unauthorized access to or misuse of personal information;
      2. impose reasonable limits on the number of data requests User can submit within a given timeframe, in order to prevent abuse of the request system.
    2. Developer shall:
      1. provide an easily accessible avenue for User to consult Policy, and for them to exercise all rights Policy entitles them to under applicable law;
      2. take reasonable effort to promptly process and respond to lawful requests from users.
    3. User may:
      1. submit a request to Developer for a copy of all personal data Third-Party Service collected and stored in connection with them;
      2. submit a request to Developer for the timely deletion of all personal data it collected and stored in connection with them, with the exception of essential data that Developer may preserve if and as permitted by applicable law. Examples of essential data vary by jurisdiction and may include but are not limited to data required for performing legal obligations, defense of legal claims, public interest or transactional history for the purpose of fulfilling tax obligations;
    4. amend, restrict, or object to the processing of their data, or exercise the option to revoke any previously given consent at any time and for any reason, including withdrawing from Policy entirely and thereby discontinuing their use of Mini-App.
    5. User shall:
      1. provide accurate and up-to-date information when submitting data requests to Developer, and cooperate with any reasonable measures necessary for Developer to fulfill these requests;
      2. adhere to the terms set forth in Policy and any additional policy enacted by Developer or Telegram.
  12. CHANGES TO THIS PRIVACY POLICY
    1. While Developer does not anticipate frequent changes, it will review and may update this Policy from time to time. Any changes to this Policy will become effective when posted in Mini-App. Please check the respective section of Mini-App to see any updates or changes to this Policy.