Privacy Policy

• Telegram handle/ID – to create and link a wallet via Privy and operate the bot.

• Wallet & on-chain data – wallet addresses, balances, transaction history.

• Trading activity – orders and fills (spot via Kyber, options via Thetanuts RFQ). stablecoin yield on AAVE.

• Technical/operational data – bot interaction logs, diagnostics, and basic device/network metadata provided by Telegram or our infrastructure.

We do not collect government IDs, banking details, or passwords.

• Provide and operate the Service (wallet creation via Privy, order routing to Kyber/Thetanuts).

• We use analysis services to improve our services. 

• Maintain security, prevent fraud/abuse, and improve performance.

• Comply with laws and enforce our terms.

We may share limited personal data with:

‍• Service providers: Privy (custody), Kyber Network (spot execution), Thetanuts (options routing), Telegram (bot interface), and infrastructure vendors (e.g. hosting, analytics).

• Government and state authorities: when required to comply with law or protect rights/safety.

• Affiliates and related entities: for internal administration.

• Corporate transactions: in the event of a merger, acquisition, reorganization, or similar.

We do not sell or rent personal data.

• Authorized personnel with a need-to-know basis, bound by confidentiality.

• Third-party processors engaged under data protection agreements, limited to what is necessary.

We retain data only as long as necessary to:

• operate the Service,

• comply with legal obligations,

• resolve disputes, and

• enforce agreements.

If you wish to remove your wallet identification, email legal@passey.xyz. We will delete or anonymize your data where technically feasible and legally permitted.

Your use of Passey involves transactions on public blockchains (e.g., Bitcoin, Ethereum).

‍• Transparency: Blockchain ledgers are public and record details such as wallet addresses, amounts, and timestamps. These may be subject to forensic analysis, which could lead to re-identification of individuals if combined with other data.

• Immutability: Blockchains are decentralized and not controlled by Passey. We cannot erase, modify, or alter any data once it has been recorded on-chain, even if it contains personal data.

• User responsibility: You should be aware that blockchain transactions may be permanently visible to the public.

Data may be processed in countries outside your residence. We rely on legal transfer mechanisms (e.g., Standard Contractual Clauses) where required.

We implement reasonable and appropriate technical and organizational measures to protect data. However, no system is 100% secure.

The Service is for users 18+. We do not knowingly collect information from minors.

Depending on your jurisdiction, you may have rights to:

• Access, rectify, erase, or restrict your personal data.

• Object to processing or request data portability.

• Withdraw consent where processing is based on consent.

• File a complaint with your local data protection authority.

GDPR/UK GDPR
‍We rely on lawful bases including contract, legitimate interests, legal obligations, and consent.

‍Singapore PDPA
‍You may access and correct your personal data and withdraw consent subject to limits.

‍California CPRA
‍If applicable, you may request to know, delete, correct, and opt-out of certain data sharing.

To exercise these rights, contact us at legal@passey.xyz. We may need to verify your identity.

We may update this Policy. The “Last Updated” date will reflect revisions. Material changes will be notified through the Service.

Passey Services are operated by Marmot Heights Ltd, a BVI entity that has its registered office at ABM Corporate Services, Ltd 1st Floor, Columbus Centre, PO Box 2283, Road Town Tortola VG 1110, British Virgin Islands. 

Requests for any services regarding privacy can be communicated to legal@passey.xyz