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Introduction

Welcome to Settler ("we," "our," or "us"). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Telegram Mini App and bot service (collectively, the "Service"). Please read this privacy policy carefully. If you do not agree with the terms of this privacy policy, please do not access the Service.

Information We Collect

1. Information from Telegram

When you use Settler through Telegram, we collect:

• Telegram User ID: A unique identifier provided by Telegram
• Username: Your Telegram username (if available)
• First and Last Name: Your display name on Telegram
• Profile Photo: Your Telegram profile picture URL (if available)
• Chat Information: Group chat IDs and names where you use Settler
• Group Membership: Information about which group chats you belong to

2. Expense and Financial Data

When you use our expense tracking features, we collect:

• Expense Records: Amount, description, category, currency, and date
• Group Expenses: Information about shared expenses with other users
• Balance Information: Calculated balances and debts between users
• Settlement Records: Records of debt settlements (amounts, dates, participants)
• Payment Information: Blockchain transaction hashes for TON settlements (public blockchain data only)

3. TON Wallet Information

If you use TON blockchain features:

• Wallet Address: Your TON wallet public address
• Transaction Hashes: Public blockchain transaction identifiers
• We do NOT store: Private keys, seed phrases, or any wallet credentials

4. Usage Data

We automatically collect:

• Access Logs: Timestamps of when you access the Service
• Feature Usage: Which features you use and how often
• Error Logs: Technical error information for debugging
• Device Information: Basic information about your device (via Telegram Web App API)

5. AI Processing Data

When you use AI features:

• Expense Descriptions: Text you provide for AI categorization
• Voice Commands: Audio transcriptions (not stored; processed in real-time)
• AI Insights Requests: Queries for spending analysis

How We Use Your Information

We use the collected information for:

1. Service Provision

• Creating and managing your user account
• Processing and tracking expenses
• Calculating balances and debts
• Facilitating settlements between users
• Syncing data across your devices

2. AI Features

• Categorizing expenses automatically using OpenAI
• Generating personalized spending insights
• Processing natural language expense commands
• Providing intelligent recommendations

3. Blockchain Integration

• Verifying TON wallet ownership
• Recording settlement transactions on the blockchain
• Displaying transaction history

4. Service Improvement

• Analyzing usage patterns to improve features
• Debugging and fixing technical issues
• Optimizing performance and user experience

5. Communication

• Sending service notifications via Telegram
• Responding to support requests
• Announcing new features or important updates

Data Sharing and Disclosure

Third-Party Services

We share data with the following third-party services:

• Telegram - Platform integration and user authentication
• OpenAI - AI categorization and insights (data not used for model training)
• TON Blockchain - Cryptocurrency settlements (publicly visible)
• Railway - Backend infrastructure hosting
• Cloudflare Pages - Frontend application hosting

When We May Disclose Your Information

• With your explicit consent
• To comply with laws, regulations, or legal processes
• To protect our rights, privacy, safety, or property
• In connection with a merger, acquisition, or sale of assets
• With other members of your groups (expense and balance information)

Data Security

We implement appropriate security measures including:

• Data encryption in transit using HTTPS/TLS
• Secure PostgreSQL database with access controls
• JWT-based authentication with secure tokens
• No custodial storage of wallet private keys
• Regular security audits and updates

However, no method of transmission over the Internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

Your Privacy Rights

You have the right to:

• Access: Request a copy of your data
• Correction: Update incorrect information
• Deletion: Request complete account and data deletion
• Export: Receive your data in a portable format
• Opt-Out: Disable AI features or analytics

GDPR Rights (EU/EEA/UK Users)

Additional rights include restriction of processing, objection to processing, and the right to lodge complaints with supervisory authorities.

CCPA Rights (California Users)

California residents have the right to know what data is collected, whether it's sold (we don't sell data), and can opt-out without discrimination.

How to Exercise Your Rights

Contact us via:

• Telegram: @settlerx_bot (send /support command)
• Use the in-app "Delete Account" feature

We will respond within 30 days.

Data Retention

• Active Data: Retained while you actively use the Service
• Account Deletion: You can request complete deletion at any time
• Inactive Accounts: May be automatically deleted after 2+ years of inactivity
• Blockchain Data: Settlement transactions are permanent and cannot be deleted

Children's Privacy

Settler is not intended for users under 13 years (or 16 in the EU). We do not knowingly collect information from children. If you believe we have collected information from a child, please contact us immediately.

International Data Transfers

Your data may be transferred to and processed in countries other than your own. We ensure appropriate safeguards through Standard Contractual Clauses and compliance with international data protection laws.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be notified via Telegram bot message and in-app notification. Continued use after changes constitutes acceptance.

Company Information

Settler is operated by:

• Legal Entity: citrus LLC
• Registered Address: 30 N Gould St, Ste R, Cheyenne, WY 82001, USA
• Email: [email protected]

Contact Us

• Email: [email protected]
• Telegram Bot: @settlerx_bot
• Website: https://getsettler.com
• App: https://app.getsettler.com

This Privacy Policy is effective as of October 20, 2025.