CryptoRank Telegram Mini App
Privacy Statement
Version updated as on: 7th of July, 2024
This Privacy Statement describes how Algona Business Ltd. and other member operators and affiliates of ‘CryptoRank Telegram Mini App’ service collect, use, share, and otherwise process Personal Data (defined below). The controller of your Personal Data is the Algona Business Ltd. entity with which you engage (the "Operator"). The Operator MAY process data qualifying as personal data about:
	•	Visitors to our Telegram bot @CryptoRank_app_bot  and related App ‘CryptoRank bot’ together with all sub-sections including ‘Mini Game’  (eachreferred as an "App");
	•	Contact persons for our users and/or prospective users;
	•	Contact persons for suppliers of services to the Operator;
	•	Any other individuals about whom the Operator may obtain Personal Data.
Undefined Terms: All terms not defined herein shall be defined according to the terms provided in other sections of the App or or according to their commonly accepted meanings.
In this Privacy Statement, "Personal Data" means information that (either in isolation or in combination with other information held by the Operator) enables you to be identified as an individual or recognized directly or indirectly. 
If you provide us with Personal Data relating to other persons (such as family members, work colleagues, employees, etc.), you are responsible for ensuring the relevant individuals are made aware of the terms of this Privacy Statement and that you are legally entitled to provide us with their Personal Data. You are also responsible for ensuring that their Personal Data is accurate and up-to-date.

Overview 
Unless we specifically state otherwise, the Operator is the controller of the Personal Data we process, and is therefore responsible for ensuring that the systems and processes we use are compliant with data protection laws, to the extent applicable to us.
Operator personnel are required to comply with this Privacy Statement and associated Operator policies when dealing with Personal Data and must also complete data protection training where appropriate to their role.

Collection of Personal Data 
We collect the following categories of Personal Data about App visitors, prospective users, suppliers and other third parties:
	•	Interaction data only: Personal data provided directly by the person (Personal Data owner), such as contact data: Telegram handle and other public data related to given  Telegram profile, required to reach the user and grant the user with the access to the App, content and other product which may be offered on the App.
We collect Personal Data ONLY directly from the data subjects and/or publicly available sources. 

Use of Personal Data 
The purposes for which we use Personal Data, and the legal bases for such processing, are as follows:
	•	To run the App functionalities and to respond to inquiries we use interaction data only.  We need to process your information in this way in order to perform our obligations under our contracts with our users.
	•	To protect the security and effective functioning of our App and information technology systems we use interaction data only.  It is necessary for our legitimate interests to monitor how our App are used to detect and prevent fraud, other crimes and the misuse of our App. This helps us to ensure that you can safely use our App.
	•	To address compliance and legal obligations, such as complying with the Operator's tax reporting obligations, we use interaction data only. This processing is necessary for the purposes of complying with legal requirements to which we are subject.

Sharing of Personal Data 
We may share Personal Data with the following categories of recipients:
	•	Service providers: We share Personal Data with service providers (including Third-Party Service Providers) to enable such parties to perform functions on our behalf and under our instructions in order to carry out the purposes identified above.  These include: infrastructure and IT services providers, for example, Third-Party Service Providers used for the content publishing and provision, payment services providers, our finance systems and our customer relationship management; third party consultants who provide us with support in respect of business analytics and marketing campaigns; and the providers of external venues where we host events. We require such parties by contract to provide reasonable security for Personal Data and to use and process such Personal Data on our behalf only.
	•	Financial institutions: We may share Personal Data with financial institutions in connection with invoicing and payments.
	•	Mandatory disclosures and legal claims: We share Personal Data in order to comply with the Operator's tax reporting obligations, comply with any subpoena, court order or other legal process, to comply with a request from our regulators, governmental request or any other legally enforceable demand.  We also share Personal Data to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims.
If you have questions about the parties with which we share Personal Data, please contact us as specified below. 

Marketing Choices 
You have control regarding our use of Personal Data for direct marketing.  You can choose to not receive such communications at any time. If you no longer wish to receive any marketing communications, remain on a mailing list to which you previously subscribed, or receive any other marketing communication,  please follow the unsubscribe functionality (where applicable) or contact us as per below.

DISCLAIMER 
We do not collect any data beyond the interaction data based on the public profile(s) you share with us. We use such data only to provide you with access to the Content and necessary support to use the Service.
We use only standard tools like Google Ads and Google Analytics, Yandex Metrika, Facebook pixel, and do not directly collect any cookies.
We do not create any internal profiles on our users to identify the individual behind the public profile unless required by law or authority.

Data Subject Rights 
You have the following rights:
	•	Access. Subject to certain exceptions, you have the right to request a copy of the Personal Data we are processing about you, which we will provide to you in electronic form. At our discretion we may require you to prove your identity before providing the requested information.  If you require multiple copies of your Personal Data, we may charge a reasonable administration fee.
	•	Rectification. You have the right to require that any incomplete or inaccurate Personal Data that we process about you is amended.
	•	Deletion. You have the right to request that we delete Personal Data that we process about you, unless we are required to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
	•	Restriction. You have the right to request that we restrict our processing of your Personal Data where:
	•	you believe such data to be inaccurate;
	•	our processing is unlawful; or
	•	we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it. 
	•	Portability. You have the right to request that we transmit the Personal Data we hold in respect of you to another controller, where this is:
	•	personal information which you have provided to us; and
	•	we are processing that data on the basis of your consent or in order to perform our obligations under contract to you (such as to provide Content services).
	•	Objection. Where the legal justification for our processing of your Personal Data is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation.  We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
	•	Withdrawing Consent.  If you have consented to our processing of your Personal Data, you have the right to withdraw your consent at any time, free of charge  This includes cases where you wish to opt out from marketing messages that you receive from us. 

Data Security 
We have implemented technical and organisational measures in an effort to safeguard the Personal Data in our custody and control. Such measures include:
	•	restricting access to Personal Data to staff and service providers on a need-to-know basis;
	•	using reputable Third-Party Service Providers;
While we endeavour to always protect our Apps,  systems, sites, operations and information against unauthorized access, use, modification and disclosure, due to the inherent nature of the Internet as an open global communications vehicle and other risk factors, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.
You also have an important role in protecting your Personal Data. You should not share any username, password or other authentication data provided to you with anyone, and we recommend that you do not re-use passwords across more than one App or application.  If you have any reason to believe that your username or password has been compromised, please contact us as detailed below.

Other Issues 
	•	What are the consequences of not providing Personal Data?
You are not required to provide all Personal Data identified in this Privacy Statement to use our App or to interact with us offline, but the functionality will not be available if you do not provide Personal Data. 
	•	Do we engage in automated decision- making without human intervention?
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
	•	How long do we retain Personal Data?
We typically retain Personal Data related to marketing activities for as long as you accept marketing communications from us, and we will securely delete such data in accordance with applicable law upon request.  For Personal Data that we collect and process for other purposes, we will typically retain such Personal Data for as long as it is necessary to fulfill the purposes outlined in this Privacy Statement and as otherwise specified in applicable record retention policies and procedures.
	•	Are third party apps or sites governed by this Privacy Statement?
The App may contain links and references to other apps or sites administered by unaffiliated third parties.  This Privacy Statement does not apply to such third party sites.  When you click a link to visit a third party app or site, you will be subject to that app's or site’s privacy practices.  We encourage you to familiarize yourself with the privacy and security practices of any linked third party apps or sites before providing any Personal Data on that app or site.
	•	How will we handle any changes to this Privacy Statement?
We may update this Privacy Statement from time to time as our services and privacy practices change, or as required by Applicable Law.  The effective date of our Privacy Statement is posted below, and we encourage you to visit our App periodically to stay informed about our privacy practices.  We will post the updated version of the Privacy Statement on our App, and ask for your consent to the changes if legally required.

CONTACTS 
If You have any comments or questions concerning Your access and/or use of the Service or in relation to these Privacy Statement, please contact the Operator using the following contact details: 
For general queries: support@cryptorank.io
Privacy team: support@cryptorank.io