Privacy Policy

Privacy Policy of Sanji Software Inc.

LAST UPDATED: September 3, 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.sanjibot.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 Sanji Software Inc. (“Sanji 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:

Sanji Software Inc.

You may contact us regarding data protection matters and to exercise your rights at sanjitwitter@proton.me.

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, 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 Sanji Services

We process your data to provide you with Sanji Services and to enter into, perform, and administer any related contracts with you.

The data collected includes: your contact details, Telegram account, telephone number, wallet address, time of registration, information generated when using Sanji (e.g., requests, timestamps, transaction information, etc.), information with regard to a possible conclusion of a contract, information about the execution and administration of contracts, financial data, etc.

2.3 Registration

Sanji Software Inc. can only be used if you sign up for Sanji’s Telegram channel. To sign up, follow the 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 Sanji (e.g., requests, timestamps, 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 providing Sanji Software Inc. to you, in particular to respond to your inquiries.

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 governance 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 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. Cookies are text files that are stored on your device and 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 set your browser to block or override certain types of cookies or to delete existing cookies.

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, 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, including:

Service Providers

Contractual Partners

Authorities

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.

Profiling and Automated Decision Taking

We might analyze aspects of your individual personality, behavior, interests, and habits and make predictions or decisions about them for the purposes laid out in Section 2.

On-Chain Data

When you use blockchains, you acknowledge that your wallet address and other data provided by your transactions are permanently and publicly stored on-chain. Neither we nor any third party has any power to delete such data.

Retention and Storage of Data

We only process your data for as long as necessary to fulfill the purposes we collected it for.

Security of your Data

We take appropriate security measures to prevent unauthorized access to your personal data. However, we cannot fully guarantee protection from cyber-attacks or other security risks.

Your Rights

You may request information about the data processed about you, and you may have the right to rectification, erasure, restriction, or objection to processing. Furthermore, you can revoke your consent at any time.

Amendment of this Privacy Policy

We may change this Privacy Policy from time to time to reflect the continuous development of our Website and Sanji Services.