This Privacy Policy ("Policy") sets forth the data protection and privacy practices of Epos Development Limited ("Aspis," "we," "us," or "our"), a company incorporated under the laws of the British Virgin Islands with company number 2148009 and registered office at Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands, regarding the collection, use, processing, retention, transfer, and disclosure of personal data obtained through your access to and use of the Aspis Telegram App (the "App" or "Services").
By accessing or using the Services, you acknowledge that you have read, understood, and agree to the collection and use of your personal data as described in this Policy.

1. Scope of Policy and Applicability
This Policy applies to all individuals who interact with the Services, including end users, wallet holders, and other parties submitting data via the App. It is intended to comply with applicable data protection laws, including the General Data Protection Regulation (EU GDPR and UK GDPR), the California Consumer Privacy Act (CCPA), and other applicable local laws to the extent such laws apply to Aspis.

2. Categories of Personal Data Collected
We may collect the following categories of personal data, directly or indirectly, when you use the Services:

• Telegram User ID and handle;
• Blockchain Wallet Address, associated on-chain identifiers, and linked transaction metadata;
• Email Address, when provided for communications or support;
• Device Information and Technical Data, such as browser type, device model, operating system, screen resolution, IP address, and access logs;
• Interaction Data, including AI prompt history, queries, commands, and usage metrics.

We do not intentionally collect real names, physical addresses, national identifiers, or sensitive personal information unless voluntarily submitted.

3. Lawful Basis for Processing Personal Data
We rely on the following lawful grounds to process your personal data:

• Contractual necessity – to enable you to use and benefit from the Services;
• Legitimate interests – to maintain platform integrity, investigate abuse, and optimize functionality;
• Legal obligations – such as compliance with financial crime regulations, data retention requirements, and sanctions enforcement;
• Consent – where expressly given for specific uses, such as receiving marketing communications. If you provide your email address for updates or marketing purposes, we will obtain your explicit consent. You may withdraw this consent at any time by clicking the “unsubscribe” link in any such communication or by contacting us at info@aspis.finance.

4. Purposes for Data Collection and Use
Your personal data is processed for the following purposes:

• To operate and maintain the technical functionality of the Services;
• To personalize and improve your user experience;
• To provide support, respond to inquiries, and deliver communications;
• To detect, prevent, and address fraud, abuse, and violations of our Terms of Use;
• To comply with legal and regulatory obligations imposed on Aspis.

5. Data Sharing and Disclosure
We do not sell or rent personal data. We may share data with:

• Authorized third-party processors such as hosting providers, analytics vendors, and security platforms, under strict contractual obligations;
• Affiliates or successors in the context of a business merger, reorganization, or acquisition;
• Regulators, courts, law enforcement, or government agencies, when required by applicable law, subpoena, or legal process.

Any third-party access is granted solely for purposes aligned with this Policy.

6. Cross-Border Transfers
Your personal data may be stored or processed in jurisdictions outside of your country of residence. Where such transfers occur, we implement appropriate safeguards in accordance with applicable laws, including the use of Standard Contractual Clauses or equivalent mechanisms.

7. Data Retention and Minimization
We retain personal data only for as long as reasonably necessary to fulfill the purposes described in this Policy, or as required by law. We follow data minimization principles and delete or anonymize data when retention is no longer justified.
Retention periods may vary depending on the category of data, the context of collection, and legal obligations. For example, AI interaction logs are retained for up to 12 months unless a longer period is required. Interaction logs may be anonymized and aggregated to improve the AI assistant's functionality and performance. Such logs do not include personally identifiable information. Wallet addresses and email addresses are retained until you disconnect or request deletion.

8. Security of Data
We maintain administrative, technical, and physical safeguards designed to protect your data against unauthorized access, disclosure, or loss. These include but are not limited to:

• Data encryption in transit and at rest;
• Access control and authentication procedures;
• Network monitoring and incident response plans.

While we endeavor to protect all information, no method of transmission over the internet or method of electronic storage is completely secure.

9. Your Data Protection Rights
Depending on your jurisdiction, you may have the following rights:

• Right to access the personal data we process about you;
• Right to rectification of inaccurate or incomplete data;
• Right to erasure ("right to be forgotten") under certain conditions;
• Right to object to or restrict processing;
• Right to withdraw consent where processing is based on consent;
• Right to data portability;
• Right to lodge a complaint with a supervisory authority.

To exercise any of these rights, contact us at info@aspis.finance. We may require verification of your identity. We will respond to verified data subject requests within 30 days, unless an extension is required due to complexity or volume.

10. Children's Privacy
Our Services are intended solely for users aged 18 and older. We do not knowingly collect or process personal data from individuals under the age of 18. If you believe a minor has submitted data, please contact us immediately for prompt deletion.

11. Cookies and Tracking Technologies
Our web application uses cookies and similar tracking technologies to enhance your user experience, enable core functionality, perform analytics, and personalize content. These technologies may collect data such as browser type, IP address, and usage behavior.
By using the web version of our Services, you consent to our use of cookies. You can control or disable cookies through your browser settings. Please note that disabling cookies may limit your ability to use certain features.
A more detailed explanation of our cookie usage, including the types of cookies and their purposes, is provided in our separate Cookie Policy, which is incorporated by reference into this Privacy Policy.

12. Changes to This Policy
We may update or amend this Privacy Policy from time to time to reflect changes in legal requirements or our business practices. Updated versions will be published with a new effective date.
We encourage you to review this Policy regularly. Material changes may be communicated directly via the App or official announcements.

13. Contact Us
If you have any questions, requests, or concerns about this Privacy Policy or your personal data, please contact us at:
Epos Development Limited
Email: info@aspis.finance

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