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Privacy Policy

Last Updated: January 2026

IMPORTANT: This Privacy Policy describes how we may collect, use, and share information. However, we make no guarantees regarding data security, privacy protection, or our ability to prevent unauthorized access, data breaches, or misuse of your information. By using our services, you acknowledge and accept all risks associated with data collection and storage.

1. Introduction

COIN ("we," "our," or "us") operates the COIN website ("Website") and Telegram Mini App ("TMA"). This Privacy Policy describes how we may collect, use, and share information when you use our services.

We make no representations or warranties regarding:

  • The security of your information
  • Our ability to prevent data breaches or unauthorized access
  • The accuracy or completeness of information we collect
  • Our compliance with all applicable privacy laws

By using our services, you acknowledge that data transmission over the internet is inherently insecure and that we cannot guarantee the security of your information.

2. Information We May Collect

We may collect various types of information, though we make no guarantees about what we collect, how we collect it, or how we use it. Information we may collect includes:

2.1 Information You Provide

We may collect information you voluntarily provide, including but not limited to:

  • Account registration information (username, email, etc.)
  • Telegram account information (when using TMA)
  • Contact information
  • Transaction information
  • Communications with us

We are not responsible for information you choose to share or provide to us.

2.2 Automatically Collected Information

We may automatically collect information including:

  • Usage data and analytics
  • Device information (IP address, browser type, operating system)
  • Location data (general location based on IP address)
  • Log data and server information
  • Cookies and tracking technologies

We may use various tracking technologies without your explicit consent, and you acknowledge that we may collect this information automatically.

2.3 Blockchain Information

PUBLIC BLOCKCHAIN DATA: Information stored on the TON blockchain (wallet addresses, transactions, token balances) is publicly accessible and immutable. We have no control over this information and cannot delete, modify, or protect it. This information is permanently visible to anyone.

Blockchain transactions are public by nature. We are not responsible for any privacy implications of using blockchain technology.

3. How We May Use Information

We may use collected information for various purposes, including but not limited to:

  • Providing, maintaining, and improving our services (though we make no guarantees about service quality)
  • Processing transactions and managing accounts
  • Communicating with you (including marketing communications)
  • Analytics and business intelligence
  • Security and fraud prevention (though we cannot guarantee security)
  • Legal compliance (as we determine necessary)
  • Any other purpose we deem appropriate

We reserve the right to use your information for any purpose we deem necessary or appropriate, subject to applicable law.

4. Information Sharing and Disclosure

WE MAY SHARE YOUR INFORMATION WITH THIRD PARTIES FOR ANY REASON WE DEEM APPROPRIATE, INCLUDING BUT NOT LIMITED TO:

4.1 Service Providers

We may share information with third-party service providers who perform services on our behalf. We are not responsible for how these third parties handle your information. These providers may include:

  • Hosting and cloud storage providers
  • Payment processors
  • Analytics services
  • Customer support platforms
  • Email and communication services
  • Any other service providers we choose to use

We make no guarantees about the security practices or privacy policies of third-party service providers.

4.2 Public Blockchain

As noted above, blockchain information is publicly accessible. We cannot and do not control who accesses this information.

4.3 Legal Requirements

We may disclose your information when we believe it is necessary or appropriate to:

  • Comply with legal obligations, court orders, or government requests
  • Enforce our Terms of Service
  • Protect our rights, property, or safety
  • Respond to legal process or regulatory inquiries
  • Prevent or investigate fraud or security issues

We may disclose information without notice to you and are not obligated to inform you of such disclosures.

4.4 Business Transfers

In the event of a merger, acquisition, reorganization, or sale of assets, your information may be transferred. We are not obligated to notify you of such transfers, and we assume no responsibility for how your information is handled after such transfers.

4.5 With Your Consent or Without It

We may share your information with third parties with your consent, or in certain circumstances, without your explicit consent when we determine it is necessary or appropriate.

5. Telegram Mini App Specific Information

When using the TMA, we may access information from your Telegram account as permitted by Telegram's API and your privacy settings. We are not responsible for:

  • Telegram's data practices or privacy policies
  • How Telegram handles your information
  • Changes to Telegram's terms or API
  • Any security breaches or issues with Telegram's platform

Your use of the TMA is also subject to Telegram's Terms of Service and Privacy Policy, which we do not control.

6. Cookies and Tracking Technologies

We use cookies, web beacons, and similar tracking technologies. We may use these technologies without your explicit consent where permitted by law.

You may be able to control some cookies through your browser settings, but disabling cookies may limit functionality. We are not responsible for the effectiveness of your cookie controls or the impact of disabling cookies.

We may use third-party tracking and analytics services that collect information about your online activities across different websites and services.

7. Data Security

NO SECURITY MEASURES ARE PERFECT OR IMPENETRABLE. WE CANNOT AND DO NOT GUARANTEE THE SECURITY OF YOUR INFORMATION.

While we may implement certain security measures, you acknowledge and agree that:

  • Data transmission over the internet is inherently insecure
  • No method of electronic storage is 100% secure
  • We cannot guarantee absolute security
  • We are not liable for any security breaches, unauthorized access, or data loss
  • You use our services at your own risk

You are solely responsible for maintaining the security of your account credentials, private keys, and wallet passwords. We are not responsible for any losses resulting from compromised credentials.

8. Data Retention

We may retain your information for as long as we deem necessary or appropriate, which may be indefinitely. We are not obligated to:

  • Delete your information upon request
  • Retain your information for any specific period
  • Notify you when we delete your information

Information stored on the blockchain cannot be deleted and is permanent.

We may retain information even after you request deletion if we determine it is necessary for legal, business, or other purposes.

9. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information. However:

  • We are not obligated to honor all requests
  • We may charge fees for certain requests
  • We may require verification that may be burdensome
  • We may deny requests for various reasons
  • We are not obligated to respond within any specific timeframe

If you wish to exercise any rights, you may contact us, but we make no guarantees that we will honor your requests or respond to your inquiries.

We reserve the right to modify, limit, or deny your rights as permitted by applicable law.

10. Children's Privacy

Our services are not intended for individuals under 18. However, we do not actively verify the age of users and are not responsible for determining user eligibility. If we become aware that we have collected information from a child under 18, we may, but are not obligated to, delete such information.

Parents and guardians are solely responsible for monitoring their children's use of our services.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We are not responsible for:

  • Compliance with data protection laws in your jurisdiction
  • How your information is handled in other countries
  • Differences in data protection standards between countries

By using our services, you consent to the transfer of your information to any country, regardless of data protection laws.

12. Third-Party Links and Services

Our services may contain links to third-party websites or integrate with third-party services. We are not responsible for:

  • The privacy practices of third parties
  • The content or security of third-party websites
  • How third parties handle your information

You access third-party services at your own risk.

13. Changes to This Privacy Policy

We may modify this Privacy Policy at any time, for any reason, with or without notice. We are not obligated to:

  • Notify you of changes
  • Obtain your consent for changes
  • Maintain previous versions of this policy

Your continued use of our services after changes constitutes acceptance of the updated policy, whether or not you are aware of the changes.

It is your responsibility to review this Privacy Policy periodically.

14. No Warranties Regarding Privacy

WE MAKE NO WARRANTIES, REPRESENTATIONS, OR GUARANTEES REGARDING:

  • The security of your information
  • Our ability to prevent unauthorized access or data breaches
  • Our compliance with all applicable privacy laws
  • The accuracy or completeness of information we collect
  • Our data handling practices
  • Our response to privacy-related requests

15. Limitation of Liability

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE FOR ANY DAMAGES, LOSSES, OR HARM RESULTING FROM:

  • Unauthorized access to or use of your information
  • Data breaches or security incidents
  • Loss, corruption, or deletion of your information
  • Disclosure of your information to third parties
  • Failure to protect or secure your information
  • Any other privacy-related issues

Our total liability, if any, shall not exceed $100 or the amount you paid to us, whichever is less.

16. California Privacy Rights (CCPA)

If you are a California resident, you may have certain rights under the California Consumer Privacy Act. However, we are not obligated to honor all requests, and we may deny requests for various reasons permitted by law.

We do not sell personal information, but we may share information with third parties as described in this policy.

17. European Privacy Rights (GDPR)

If you are located in the European Economic Area, you may have certain rights under the General Data Protection Regulation. However, we may limit or deny these rights as permitted by law, and we are not obligated to honor all requests.

We process your information based on various legal bases, including our legitimate interests, which may override your privacy rights in certain circumstances.

18. Contact Information

If you have questions about this Privacy Policy (though we assume no obligation to respond), you may attempt to contact us through the methods provided on our website.

We reserve the right to not respond to privacy-related inquiries and assume no obligation to provide support or assistance.

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