Privacy Policy 

1. Key Concepts 

1.1. Application (or Service): A software service published by the Developer on the platform,  included in the app catalog. 

1.2. Developer: Blum Labs Inc. independently or jointly with other persons organizing and (or)  carrying out the processing of Personal data, as well as determining the purposes of  processing Personal data, the composition of Personal data to be processed, actions  (operations) performed with Personal data. The developer publishes the Application on  the platform and uses it in accordance with the terms of the platform.  

1.3. Personal data is information recorded on a tangible medium about a specific person,  identified with a specific person or which can be identified with a specific person, allowing  the identification of that person directly or indirectly by reference to one or more factors  specific to his or her biological, economic, cultural, civic or social identity. Personal data  includes biographical and identifying data, personal characteristics, marital status,  financial status, health status, etc. 

1.4. Policy: This Privacy Policy outlines how information about Users is processed and  protected. 

1.5. User: An individual who has registered and uses the Application. 

2. General Provisions 

2.1. This Policy is an official document of the Developer and defines the procedure for  processing and protecting information about individuals using the Application (i.e. Users). 2.2. This Policy governs solely the relationships between the Developer and the User. It  cannot and does not regulate the relationship between Telegram and its user, nor does it  supersede the Telegram Privacy Policy.  

2.3. The Developer follows all privacy guidelines set forth by the platforms that distribute  Telegram apps, including Apple’s App Review Guidelines and Google’s Developer  Policies. 

2.4. The goal of this Policy is to ensure the proper protection of information about Users,  including their Personal data, from unauthorized access and disclosure. 

2.5. Relations related to the collection, storage, distribution, and protection of information  about Users are governed by this Policy and other official documents of the Developer,  as well as applicable law. 

2.6. The Developer has the right to make changes to this Policy. When changes are made,  the Developer publishes the new version of the Policy. It is recommended that Users  regularly check the terms of this Policy for changes. Continued use of the Application by the User after changes to this Policy indicates acceptance of and agreement with such  changes. 

2.7. User’s continued access to and use of the Application shall constitute his or her acceptance of this Policy, the Telegram Bot Terms and the Telegram Mini App Terms.  2.8. If the User disagrees with the terms of this Policy, the use of the Application must be  immediately terminated. 

3. Conditions for Using the Application

3.1. By providing the Application, the Developer reasonably and in good faith believes that the  User: 

• has all the necessary rights to enable them to start and use the Application; • provides accurate information about themselves as required for the use of the  Application; 

• understands that information shared while using the Application may become  available to other Users and may be copied and distributed by them; 

• understands that some types of information provided to other Users while using the  Application cannot be deleted by the User themselves; 

• is familiar with this Policy, agrees with it, and assumes the rights and obligations  specified in it. 

3.2. The Developer does not verify the accuracy of the information received (collected) about  Users. 

4. Purposes of Processing Information 

The Developer use the personal data collected through the Application to: 

• provide the Service to the User, create and maintain account of the User, verify identity of  the User, process transactions, and provide customer support; 

• improve the Service for the User, identify activity patterns and usage trends; • communicate with the User, send emails to the User, including confirmations and reminders,  respond to User’s requests for assistance, or report on technical issues;  

• fulfill the Developer's obligations to the Users regarding the use of the Application. • update User about changes to the Service, send messages about new features or  promotions that may interest the User; or  

• maintain safety and security, detect, prevent, and respond to potential or actual security  incidents, and protect against other illegal activities.  

5. User Information Composition 

The Developer processes the following information about Users: 

• personal data provided with the User's consent and necessary for the use of the Application; • additional information about User provided by the platform administration with the User's  consent; 

• information provided by User while using the Application; 

• information obtained by the Developer as a result of User actions when using the Application  (e.g., IP addresses, cookies, application usage statistics). 

6. Processing User Personal Data 

6.1. Processing of personal data is based on the principles of: 

• legality and fairness of Personal data processing; 

• correspondence of the purposes of Personal data processing to the purposes  predetermined and declared during the collection of Personal data; 

• correspondence of the volume and nature of processed personal data to the stated  purposes of processing;

• inadmissibility of combining databases containing Personal data for incompatible  purposes. 

6.2. The Developer processes personal and other data of the User with their consent for  providing Services related to the use of the Application. 

6.3. Information is collected by the Developer with the User's consent upon the first launch  and/or use of the Application. 

6.4. By using the Application and entering into legal relations with the Developer, the User  gives his or her consent to the transfer of his or her Personal Data to third parties (including trans-border) when this is necessary for the Developer to properly fulfill its  obligations in accordance with applicable law or fulfill obligations to the User. 

6.5. The Developer has the right to use the Personal Data of the User to send news,  promotions and other information related to the products and Services provided by the  Developer. The Developer has the right to transfer Personal Data to third parties so that  they can help in the implementation of marketing and advertising projects or send  marketing newsletters. By using the Application, the User accepts this Policy and agrees  to receive such marketing communications. The subject of Personal data has the right to  refuse to receive such information by contacting the Developer with a corresponding  application. 

6.6. The Developer stores Personal Data for five years from the date of receipt from the User,  unless other periods are provided for by law or the nature of the relationship between the  Developer and the User. The Developer has the right to carry out indefinite storage  (archiving) of Personal Data, if this does not contradict current legislation. 

7. User Rights and Responsibilities 

7.1. Users have the following rights: 

• the right to know what data the Developer has about the User; 

• the right to correct, delete, or update Personal data of the User. The Developer  sometimes may not be able to modify or delete certain information. For example, the  Developer is required by law to keep certain information for a defined period; 

• the right to opt out of receiving electronic marketing communications from the  Developer. The Developer may periodically send you emails and messages  promoting the use of the Service. The User can opt out (unsubscribe) of receiving  these messages by following the instructions included in each email or message. If  the User has any additional questions, the User may contact the Developer at  legal@blum.io 

7.2. The User has the right to know that the Developer has Personal data relating to him or  her and to receive the following information from the Developer: 

• legal grounds and purposes of processing Personal Data; 

• the purposes and methods used for processing Personal data; 

• processed Personal Data related to the relevant User, the source of their receipt; • terms of processing of Personal data, including periods of their storage; 

• the procedure for the User to exercise his rights; 

• information about completed or intended cross-border data transfers other information required by law. 

7.3. The User has the right to contact the Developer with a request to delete his or her  Personal Data. In this case, the Developer deletes Personal Data except in cases where the obligation to store Personal Data is assigned to the Developer in accordance with the  law.  

7.4. User can send inquiries regarding the use of their Personal data to the Developer in  writing or in the form of an electronic document signed by a qualified electronic signature. 7.5. Inquiries should include: 

• the User's identity document number and issuing authority details; 

• information confirming the User's relations with the Developer; 

• the User's or their representative's signature. 

7.6. The Developer will review and respond to the inquiry within 30 days of receipt. 7.7. All correspondence is confidential and will not be disclosed without the User's written  consent. Personal data and other information will be used solely to respond to the inquiry  or as required by law. 

8. Measures to Protect User Information 

8.1. The Developer takes all necessary legal, organizational and technical measures to  protect Personal data from unauthorized or accidental access, modification, blocking,  copying, provision, distribution of personal data, as well as from other unlawful actions in  relation to Personal data: 

• prevents unauthorized persons from accessing equipment used for processing  Personal Data; 

• prevents unauthorized reading, copying, modification or removal of data media; • prevents unauthorized recording of Personal Data and modification or destruction of  recorded Personal Data and provides the possibility of establishing retroactively:  when, by whom and what Personal Data were changed; 

• ensures the security of data processing systems intended for the transfer of Personal  Data, regardless of the means of data transmission; 

• ensures control of employee access to received Personal Data; 

• excludes unauthorized reading, copying, modification and destruction of Personal  Data during the transfer and transportation of Personal Data; 

• ensures the confidentiality of information obtained during the processing of Personal  Data; 

• ensures compliance with the protection of personal data during their processing in  personal data information systems, the implementation of which ensures established  levels of personal data security. 

8.2. User information is handled, transferred and stored in compliance with applicable laws,  including all necessary precautions to prevent unauthorized access, modification,  deletion, or distribution. 

8.3. The Developer will never share User data with third parties, including with Developer’s  own additional services or bots (if any, as the case may be) unless explicitly authorized  by User or required by law, such as in response to a lawful court order. 

9. Policy Limitations 

This Policy does not apply to the actions and resources of third parties. The Developer is not  responsible for the actions of third parties that have gained access to User information due to the nature of the Application's platform, which is accessible to any internet User. User is advised to  carefully consider the amount of information they share. 

10. Children’s privacy 

Users must be at least 18 years of age to register with and use the Application. The Application is not for the use of children under 13. The Developer not intend to collect Personal data from  children under 13. 

11. Disclaimers 

11.1. The User acknowledge that the User have read, understood and agreed to the Telegram  Bot Terms and the Telegram Mini App Terms, as well as any other terms made available  to the User by Developer. 

11.2. Developer operates under the understanding that all information the User provides is  submitted in good-faith, and is not obligated to check or verify User’s statements for errors  or inaccuracies. It is responsibility of the User to ensure that all information the User  provides is accurate and up-to-date. 

11.3. The User may decide to make some information available in the public domain, either  directly on Platform, elsewhere on the internet, or via Application. The information the  User chooses to make public may be accessed by other users of Application via Theor  on the internet, in which case it will not be covered or protected by Policy. 

12. Questions or concerns 

All questions regarding the application of this Policy can be directed to the email address  legal@blum.io