$LAVE$ Privacy Policy

This is an English translation for convenience. In case of any discrepancy the Russian version prevails.

1.Primary policy

The Telegram Standard Privacy Policy for Bots and Mini Apps applies to $LAVE$ and is incorporated into this document by reference as its integral part.

The Telegram Mini Apps Terms of Service also apply, including provisions on data that Telegram passes to a third-party mini app.

This supplement (the "Supplement") clarifies only the specifics of data processing in $LAVE$. Where the standard policy does not describe a specific $LAVE$ feature, this Supplement applies. Mandatory Telegram rules and applicable law prevail.

Telegram and $LAVE$ are independent services. The Operator of $LAVE$ is independently responsible for data it receives and processes after transfer from Telegram.

2.What data $LAVE$ processes

Depending on the features used, the Service may process:

• Telegram ID, public name, username and photo;
• language, platform, Telegram Premium flag and message permission;
• IP address, approximate country, login dates, technical logs and session ID;
• game progress, balance, inventory, ranking, game and referral connections;
• descriptors, reactions, messages, posts and reports;
• UTM/referral tags and product events;
• the fact, time and version of the 18+ and legal-document acceptance;
• Telegram Stars invoice, charge ID, purchase, status and refund;
• GRAM reward accruals, TON payout requests, wallet address, tx hash and status;
• support inquiries and moderation decisions.

For the entertainment "dossier", the approximate age of a Telegram account, Premium status, available information about gifts, saved music and emoji status, and random joke values may be used. They are not verified facts.

The Service does not access private Telegram correspondence based on joke interface phrases, does not sell personal data and does not use Telegram data to train or test AI models.

3.Processing purposes

Data is used only for:

• login, account creation and game operation;
• saving progress and game connections;
• Stars purchases, refunds, GRAM rewards and payout requests;
• security, anti-fraud, abuse prevention and investigation of violations;
• user content, reports and moderation;
• support and fulfilling user requests;
• analytics, diagnostics, A/B tests and Service improvement;
• legal compliance and defense of legal claims.

Mandatory data is processed to provide the Service, for security and to enforce the terms. Optional processing for which the law requires consent begins only after the corresponding user choice.

4.GRAM and payments

Digital purchases inside Telegram are made via Telegram Stars.

GRAM cannot be purchased. It is only granted by the Operator as a game/promo reward. To pay out a reward in TON, the amount, the accrual basis, the wallet address, the request status and the public tx hash are processed.

The Operator does not receive a bank card number via Telegram Stars. A confirmed TON transaction is a public blockchain record and cannot be deleted by the Operator from the TON network.

5."Phantoms" and non-user data

Another user may specify a publicly available Telegram username/ID of a person who does not yet use $LAVE$. For a "phantom" game record, the Telegram ID, username, public name, photo and connection to the inviting user may be temporarily processed.

This data must not be used for covert surveillance, mass collection, database sale, advertising or AI training. Free user text about a "phantom" is prohibited.

A person may request hiding, object to processing and demand deletion via /delete_data in support. To protect against deletion of others' data, confirmation of the relevant Telegram account may be required.

6.Data transfers

To the extent necessary, data may be received by:

• Telegram - for the Mini App, bot, Stars, messages and share features;
• providers of hosting, databases, queues, CDN, backup and protection;
• TON Connect, the wallet chosen by the user, the TON network and a blockchain API provider;
• support and moderation contractors with limited access;
• a court, regulator or other authorized body where disclosure is mandatory.

$LAVE$ does not sell data and does not pass it to advertising brokers.

7.Retention

Data is stored while the account exists and it is necessary for the Service's features. After a deletion request, data is deleted or anonymized from active systems without undue delay, usually no later than 30 days.

Exceptions:

• payment, tax, anti-fraud and legal records may be kept for a mandatory period;
• a minimal identifier may be retained to prevent repeat violations or the recreation of a deleted "phantom";
• data disappears from backups as they are rotated on schedule;
• the Operator cannot delete independent copies held by recipients, in Telegram or a confirmed blockchain record.

The entertainment "dossier" and non-user data must not be kept longer than necessary for the relevant feature.

8.Rights and deletion via support

The user or another person may request:

• information about their data - /my_data;
• correction or restriction - /privacy;
• deletion of the account and data - /delete_data;
• stopping optional messages - via notification settings or /privacy.

A request is sent to support. The Operator may verify identity via the requester's Telegram account and responds within the applicable legal deadline, but no later than 30 days unless a shorter period is mandatory.

Deleting the Telegram account or the chat with the bot may not by itself delete $LAVE$ data; use /delete_data for that.

9.Age and security

The Service is intended only for people aged 18 and over. Upon reasonable discovery of a minor, the account is blocked and the data is deleted or restricted, keeping only the mandatory minimum.

The Operator applies proportionate security measures and restricts access to data. Absolute security of any information system is not guaranteed. The user is responsible for the security of the Telegram account, device, wallet and private keys.

10.Changes and contacts

The current version of the Supplement is published at a permanent link with a date and number. Material new processing purposes requiring consent do not apply until it is obtained.

The Service is operated by the independent developer/operator of $LAVE$. For legally significant matters, contact support: @slaves_support_rebot.

• Privacy requests: /privacy, /my_data, /delete_data
• General inquiries: @slaves_rebot
• Content reports: /report

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