Gift Club Privacy Policy

    This policy explains what personal data Gift Club collects when you play the Gift Club mini app in Telegram (@YourGiftClubBot) or visit giftclub.app, why we collect it, who we share it with and what you can ask us to do with it. It should be read together with our Terms and Conditions.

    1. Who we are

    Gift Club ("we", "us") operates the Gift Club mini app and this website and decides how the personal data described here is used. You can reach us about anything in this policy through our support bot, @YourGiftClubSupportBot.

    We process personal data in accordance with the Law of Ukraine "On Personal Data Protection". If you live in the European Union or the United Kingdom, the GDPR also gives you the rights described in section 9.

    2. Data we collect

    2.1 From Telegram when you open the app

    Telegram passes the mini app a signed set of launch data. From it we store your Telegram user ID, username, first and last name, profile photo link, language setting and whether you have Telegram Premium. These fields are refreshed each time you open the app, so a change you make in Telegram reaches us on your next launch. We do not receive your phone number, your contacts or your messages.

    2.2 Device and connection data

    When you play, pay or change a balance we record your IP address, a random device identifier the app generates and keeps on your device, your browser user agent, Telegram platform and app version. We also store your time zone, screen size and Telegram client version. We use these to secure accounts and to detect fraud, bots and multi-accounting, and to fix problems on specific devices.

    2.3 Gameplay and transactions

    • Your account history: sign-up and last-login dates, level and XP, streaks, the games you play, your bets and results, and the records used to verify provably fair rounds.
    • Your balances of Stars, XP and TON and every change to them, the prizes you win and the gifts and NFTs you claim or exchange.
    • Stars purchases: amount, status and time. Payments are made through Telegram, so we never receive your card or bank details.

    2.4 TON wallet

    If you connect a TON wallet, we store its address and the details of TON transfers between it and Gift Club (amount, transaction hash, sending wallet). NFT prizes are sent to the address you connected.

    2.5 Friends, referrals and links

    If you join through someone's invite, open a gift link or add a friend, we record who is connected to whom. We also record the link or campaign that brought you to the app, so we can credit referrals and tell which channels work.

    2.6 What you send us

    Feedback you submit in the app, answers to short in-app surveys, and messages to support. The payment-support flow in the bot asks for an email address so we can reply about a payment; giving it is optional and it is used only for that request. Feedback is stored with technical details of your device to help us reproduce the issue.

    2.7 Bot messages

    We keep a record of the messages our bot sends you, whether each one was delivered, and your notification settings.

    3. How we use your data

    • To run the game — your account, balances, prizes, purchases and gift or NFT delivery. This is necessary to provide the service you asked for.
    • To keep it fair and secure — detecting cheating, bots, duplicate accounts, referral abuse and payment fraud, and enforcing the Terms. This is our legitimate interest and protects other players.
    • To support you — answering questions, fixing failed payments and investigating reports.
    • To message you through the bot — about your rewards, streaks, friends and events, and occasional announcements. See section 9 for how to turn these off.
    • To improve the product — usage analytics and error reports tell us what works and what breaks.
    • To meet legal obligations — keeping transaction records and responding to lawful requests.

    4. What other players can see

    Your Telegram name, username and profile photo appear to other players where the game is social: leaderboards, friends lists, PvP matches, gifts you send and the recent-wins feed. The recent-wins feed is also shown on this website, with your first name and photo next to the prize.

    Share images and invite cards you create show your first name and photo. They are stored at public links so they can be displayed in Telegram and elsewhere, which means anyone with the link can open them.

    5. Who we share data with

    We do not sell your personal data. We use these service providers, each only for the purpose listed:

    • Telegram — the platform the app runs in; processes Stars payments, delivers bot messages and Telegram Gifts.
    • TON network services (TonCenter, TON Connect) — to read TON transfers and to connect your wallet. Transactions on the TON blockchain are public by design.
    • Google Analytics — visitor statistics for this website only; see section 6.

    We may also disclose data when the law requires it, to protect players or our service from fraud or abuse, or to a successor if Gift Club is reorganised or sold, under this same policy.

    6. This website

    giftclub.app needs no account. It uses Google Analytics 4, which sets cookies to count visits and records the pages you view, your approximate location, device and browser type, and clicks on the buttons that open the app. Google processes this data under its own privacy policy. You can block these cookies in your browser settings or with Google's opt-out add-on.

    The site also keeps one flag in your browser's session storage so the same win notifications are not shown to you twice. It is cleared when you close the tab.

    7. Storage on your device

    The mini app stores settings on your device: your language, sound preferences, last bet sizes, which tips you have seen, the random device identifier from section 2.2 and, if you connected one, your TON wallet session. Clearing Telegram's cache removes them; the app works again on next launch, apart from the wallet, which you will need to reconnect.

    8. How long we keep data

    We keep your account data for as long as your account exists. Transaction, balance and security records — purchases, prizes, balance changes and the IP and device data attached to them — are kept for as long as they are needed to resolve disputes and chargebacks, prevent fraud and meet legal obligations, which can be longer than the account itself.

    When you ask us to delete your account, we delete or anonymise your profile and the data linked to it, except for the records we have to keep for those reasons.

    9. Your choices and rights

    You can ask us to:

    • tell you what personal data we hold about you and give you a copy;
    • correct data that is wrong;
    • delete your account and personal data;
    • stop or restrict a particular use of your data, or object to it.

    Send the request to @YourGiftClubSupportBot from the Telegram account it concerns, so we can confirm it is yours. We will answer within 30 days. Deleting your account is permanent and forfeits any Stars, gifts and NFTs still held inside Gift Club, as described in the Terms; claim anything you want to keep first.

    Bot messages. You can turn off reminder, friend and event notifications in the app's Settings. Messages about your own purchases and prizes, and general announcements, stop only if you stop or block the bot in Telegram.

    Wallet. You can disconnect your TON wallet in the app at any time.

    If you believe we have handled your data unlawfully, you can complain to the Ukrainian Parliament Commissioner for Human Rights or, in the EU or UK, to your local data protection authority. We would appreciate the chance to fix it first.

    10. Where data is processed

    Telegram and some of the providers in section 5 process data in other countries, including the United States. Where data leaves the country you are in, we rely on the providers' standard safeguards for international transfers.

    11. Children

    Gift Club is not for children under 13, and users under 18 need a parent's or guardian's permission, as set out in the Terms. We do not knowingly collect data from children under 13. If you believe a child under 13 is using the app, contact @YourGiftClubSupportBot and we will close the account and delete its data.

    12. Security

    Traffic to the app and this site is encrypted with HTTPS. Every request from the mini app is checked against Telegram's signature before we act on it, and access to player data is limited to the people who run Gift Club. No system is perfectly secure, but we will tell affected players and the authorities of a breach where the law requires it.

    13. Changes to this policy

    When we change what we collect or how we use it, we update this page and the date at the bottom. We announce significant changes in the app or through the bot before they take effect.

    14. Contact

    Questions about this policy or your data: @YourGiftClubSupportBot on Telegram.

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