Privacy Policy of BONKbot
LAST UPDATED: 4 SEPTEMBER 2024
This Privacy Policy (“Privacy Policy”) explains and sets out the basis for our collection of personal data when you visit our website (https://www.bonkbot.io/, “Website”) and use our online products and services that include but are not limited to, Telegram bots (e.g. for trading), channels, groups, and any application created and distributed by BONKbot (“BONKbot Services”), when you interact with us in relation to a contract, communicate with us or otherwise deal with us, how we use it, the conditions under which we disclose it to others and the measures we take to keep it secure. In addition, we may inform you about the processing of your data separately, for example in consent forms, terms and conditions, additional privacy notices, forms and other notices. We use the word “data” here interchangeably with “personal data”.
If you provide information to us about any person other than yourself, you must ensure that the data is accurate and that these people understand how their data will be used, that they have given their permission for you to disclose it to us and for you to allow us, and our service providers, to use it. You are welcome to provide them with a copy of this Privacy Policy.
This Privacy Policy is aligned with the EU General Data Protection Regulation (“GDPR”), and the Swiss Data Protection Act (“DPA”). However, the application of these laws depends on each individual case.
Controller
The responsible person for processing your data under this Privacy Policy (“Controller”) unless we tell you otherwise in an individual case is:
Triple Spice AG c/o Wadsack Zug AG Bahnhofstrasse 7
6300 Zug Switzerland
You may contact us regarding data protection matters and to exercise your rights at info@bonkbot.io
Data collection and Purpose of Data Processing
We process the following data about you for the purposes outlined below:
2.1 Overview
When you visit our Website, we collect personal data that is necessary for the functionality and security of our Website.
The data collected includes: IP address; information about the operating system of your end device; cookies; referrer URL; amount of data transferred; date, region and time of the server request; websites accessed or from which access is made; browser type and version; name of your Internet provider; protocols; etc.
2.2 BONKbot Services
We process your data in order to provide you with BONKBot Services and to enter into, perform and administer any related contracts with you.
The data collected includes: your contact details and other information provided by you; Telegram account; telephone number; wallet address; time of registration; information generated when using BONKbot (e.g. requests, time stamps transaction information, etc.); information with regard to a possible conclusion of a contract and about the conclusion of the contract; information about the execution and administration of the contracts; financial data; etc.
2.3 Registration
BONKbot can only be used if you sign up for BONKbot’s Telegram channel. To sign up, follow this Telegram link and press start or send a message with the text “/start”.
The data collected includes: Telegram account; wallet address; time of registration; information generated when using BONKbot (e.g. requests, time stamps transaction information, etc.) etc.
2.4 Communication
When you contact us by email, Telegram support chat, or other means of communication, we collect the data exchanged between you and us for the purposes of communicating with you and provide BONKbot to you, in particular to respond to your enquiries.
The data collected includes contact details provided by you; type, manner, place and time of communication; content of communication; etc.
If you communicate with us via our accounts on third-party platforms like X/Twitter or Telegram, your data will also be processed according to the privacy policies of the respective platform. Further information on the purpose and scope of data processing by third-party platforms can be found in their respective privacy policies.
2.5 Risk Management, Corporate Governance
We process your data as part of our risk management and corporate government in order to protect us from criminal or abusive activity.
2.6 Safety and Security
We process your data to protect our IT and other infrastructure. For example, we process data for monitoring, analysis and testing of our networking and IT infrastructure.
2.7 Compliance with Law and Legal Procedures
We process your data to comply with legal requirements, e.g., money laundering and terrorist financing, tax obligations etc. and we may be required to request further information from you to comply with such requirements (“Know Your Customer”, “KYC”) or as otherwise required by law and legal authorities. Furthermore, we may process your data for the enforcement of legal claims and for the defense in legal disputes and official proceedings.
2.8 Cookies
Our website uses cookies and we may also allow certain third parties to do so (see Section 2.11 below). Cookies are text files that are stored on your device (computer, laptop, smartphone, etc.) and that are necessary for the use of the website as such or certain functions or that enable the analysis of the use of our website.
However, depending on the purpose of these cookies, we may ask for your express prior consent before using them. You can access your current settings by clicking on the “Cookies” button below and you can withdraw your consent at any time using the same link. You can also set your browser to block or override certain types of cookies or alternative technologies, or to delete existing cookies. You can also equip your browser with software that blocks tracking by third parties. You can find more information on the help pages of your browser (usually under the heading “Data Protection”) or on the websites of the third-party providers mentioned in our Consent Management Tool.
2.9 Tool
We use the following tracking tool(s) to ensure a tailored design and the continuous optimization of our Website:
Google Analytics
Google Ireland (based in Ireland) is our provider of “Google Analytics” and acts as our processor. Google Ireland relies on Google LLC (based in the US) as a processor for its services (both “Google”). Google uses performance cookies to track the behavior of visitors to our website (duration, frequency of pages viewed, geographic origin of access, etc.) and compiles reports for us on the use of our website on this basis. We have configured the service so that the IP addresses of visitors are shortened by Google in Europe before being forwarded to the US and thus cannot be traced. We have turned off the "Data Forwarding" and "Signals" settings. Although we can assume that the information we share with Google is not personal data for Google, it is possible that Google can draw conclusions about the identity of visitors from this data for its own purposes, create personal profiles and link this data to the Google accounts of these persons. If you consent to the use of Google Analytics, you explicitly agree to such processing, which also includes the transfer of personal data (in particular usage data for the website, device information and individual IDs) to the US and other countries not offering adequate data protection from a Swiss/EU perspective. Information on the data protection of Google Analytics can be found here https://support.google.com/analytics/answer/6004245 and if you have a Google account, you can find further details on processing by Google here https://policies.google.com/technologies/partner-sites?hl=en.
2.10 Plugins and Our Presence on Third-Party Platforms
We do not use plugins on our Website. If our Website contains icons from or links to other third-party providers (e.g. Twitter/X, Telegram), we only use these for passive linking to the pages of the respective providers.
Please find further information on the purpose and scope of data collection and processing by the third-party providers in their respective privacy policies. This also applies with regard to our own presence on third party platforms (e.g. Twitter/X, Telegram).
2.11 Links to Third-Party Offerings
Our Website may contain third-party offerings. Please note that when you use such links, your data such as IP address, personal browser settings, etc., are transmitted to these third parties. We have no control over the offers of third parties, do not check them and are not responsible for them. Please note that the terms of this privacy policy do not apply to these third-party offering or their content or to the collection of your data after you have clicked on links to such third-party websites or have taken advantage of these third-party offerings. We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites. For further information on third party services and links please also see our terms of use (“Terms”).
Legal Basis for Data Processing
Where we ask for your consent, we process your data based on such consent. Where we did not ask for your consent and where required under applicable law, we process your data on other legal grounds, such as:
a contractual obligation;
a legal obligation;
a vital interest of the data subject or of another natural person;
to perform a public task;
our legitimate interest.
Disclosure of Data to Third Parties
As part of our data processing, we may share your data with third parties, in particular to the following categories of recipients:
Service Providers
We may share your information with service providers and business partners around the world with whom we collaborate to fulfill the above purposes (e.g. IT provider , advertising service provider, security companies, banks, insurance companies, telecommunication companies, credit information agencies, address verification provider, lawyers) or who we engage to process personal data for any of the purposes listed above on our behalf and in accordance with our instructions only.
Contractual Partners
In case required under the respective contract we share your data with other contractual partners. If we sell or buy any business or assets, we may disclose your data to the prospective seller or buyer of such business or assets to whom we assign or novate any of our rights and obligations.
Authorities
We may pass on data to offices, courts and other authorities in Switzerland or abroad if we are legally obliged or entitled to do so or if this appears necessary to protect our interests. The authorities are responsible for processing data about you that they receive from us.
Transfer of Data Abroad
The data that we collect from you may be transferred to, processed and stored in, a country outside the European Economic Area (EEA) or Switzerland. In view of the EEA or Switzerland, the law in some of those countries may not offer an adequate level of data protection. We only transfer data to these countries when it is necessary for the performance of a contract or for the exercise or defense of legal claims, or if such transfer is based on your explicit consent or subject to safeguards that assure the protection of your data, such as the US-EU Data Privacy Framework, the US-CH Data Privacy Framework (if and insofar as in force and applicable) and/or the Standard Contractual Clauses approved by the European Commission (SCCs), adjusted according to Swiss law, if applicable and required.
Profiling and Automated Decision Taking
We might analyze aspects of your individual’s personality, behavior, interest and habits make predictions or decisions about them for the purposes laid out in section 2, e.g. to perform statistical analysis or to prevent misuse and security risks. This analysis identifies correlations between different behaviors and characteristics to create profiles for individuals. For example, we may use profiling to determine in which services you might be interested. We may also use profiling to assess your creditworthiness. We do not use profiling that can produce legal effects concerning you or similarly significantly affect you without human review.
In certain circumstances, automated decision taking might be necessary for reasons of efficiency and consistency. In such cases, we will inform you accordingly and take the measures required by applicable law.
On-Chain Data
When you use blockchains, you acknowledge that your wallet address and other data/information provided by your transactions, which are considered personal data if relating to an identified or identifiable natural person, are permanently and publicly stored on-chain, which means such data is publicly available to anyone. Neither we, nor any third party, has any power to delete such data published by its users to the blockchain. If you want to ensure that your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be available or exercisable by you or us due to the technological infrastructure of the blockchain.
You hereby release and indemnify us of any liability associated with data that you transferred to the blockchain.
Retention and Storage of Data
We only process your data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of complying with legal retention requirements and where required to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. Upon expiry of the applicable retention period we will securely destroy your data in accordance with applicable laws and regulations.
Security of your Data
We take appropriate organizational and technical security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. However, we and your personal data can still become victims of cyber-attacks, cybercrime, brute force, hacker attacks and further fraudulent and malicious activity including but not limited to viruses, forgeries, malfunctions and interruptions which are out of our control and responsibility. We have also put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Your Rights
To the extent provided for by applicable law, you may request information about the data processed relating to you, its origin and recipients and the purpose of the data processing. You may also have the right to rectification, erasure, restriction or objection to processing, as well as to data portability to another controller.
Furthermore, you can revoke your consent at any time with effect for the future. All you need to do is send us an informal e mail.
Please note that the foregoing rights are subject to legal restrictions and may interfere with or make impossible the provision of our services.
Amendment of this Privacy Policy
Due to continuous development of our Website and the contents thereof and our BONKbot Services, changes in law or regulatory requirements, we might need to change this Privacy Policy from time to time. Our current Privacy Notice can be found at our Website.
Bonkbot
2024