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1. Data Controller

2. Data We Collect

When you use the Telegram Mini App, we process the following data:

2.1 Automatically Collected

• Telegram User ID (numeric identifier) — to identify your account.
• Telegram username and display name — for leaderboard and friend system.
• Language preference (language_code) — to set interface language.
• Referral code (if any) — for the referral system.
• IP address and User-Agent — for security, fraud prevention, and debugging.

2.2 User-Provided

• IBAN — only when creating a withdrawal request, for bank transfer.
• Crypto wallet address (BTC/ETH) — only when creating a crypto withdrawal.

We do NOT collect passwords, credit cards, KYC documents, or biometric data.

3. Purpose of Processing

• Account creation, session management, and service delivery.
• Processing withdrawal requests (IBAN / crypto transfers).
• Referral, reward, and leaderboard calculations.
• Detection of fraud, multi-accounting, and botnet activity.
• Compliance with legal obligations (AML, financial reporting).
• Anonymous statistical analysis to improve our service.

4. Sharing with Third Parties

Your data may be shared only to the minimum extent necessary in the following cases:

• Payment providers: bank APIs for IBAN transfers, on-chain protocols for crypto.
• Anti-fraud services: reporting suspicious transactions per Curaçao license requirements.
• Legal authorities: upon court order or competent authority request.
• Analytics: only anonymized, non-personal data (user counts, screen view durations).

We never sell your data for advertising purposes.

5. Cookie Policy

The Telegram Mini App does not use traditional browser cookies. Instead, only the following is stored in localStorage:

• Splash screen display counter
• Language preference cache
• Announcement dismissal state

The session token (initData) created by the Telegram WebApp interface is managed by Telegram and refreshes on each launch.

6. Retention Period

• Account data: While the account is active + 12 months after last use.
• Financial transactions (withdrawal records): 10 years by legal requirement.
• System logs: 90 days (for security purposes).
• Account deletion request: Fully deleted within 30 days (excluding legally required records).

7. Your Rights (GDPR / KVKK)

Under the EU GDPR and the Turkish Personal Data Protection Law (KVKK), you have the following rights:

• Right of access: Learn which data we process about you.
• Right to rectification: Have inaccurate data corrected.
• Right to erasure (right to be forgotten): Request deletion of your data.
• Right to object: Oppose certain processing types.
• Right to portability: Receive your data in a machine-readable format.

Submit your request to privacy@valente.media. We respond within 30 days.

8. Children's Privacy

Our service is for users 18 years and older. If we discover a user is under 18, the account is immediately closed, the balance is forfeited, and the data is deleted. Parents can contact us at compliance@valente.media.

9. Changes

This policy may be updated without prior notice. Material changes are announced via the in-app announcement channel. Continued use after a change constitutes acceptance of the new terms.

10. Contact