Privacy Policy

Last updated: 05/July/2025

1. Introduction

Welcome to Tsubasa ("we", "us", "our"). We are committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Telegram bot service.

By using our service, you agree to the collection and use of information in accordance with this policy. If you disagree with any part of this policy, please discontinue use of our service.

2. Information We Collect

Automatically Collected Information

  • Telegram User ID: Your unique Telegram identifier
  • Username: Your Telegram username (if available)
  • Message Content: Text messages you send to our bot
  • Interaction Data: Commands used and bot responses
  • Usage Metrics: Frequency of use, feature usage statistics

Information You Provide

  • Account Information: When you create an account on our platform
  • Payment Information: Billing details for premium subscriptions
  • Support Communications: Messages sent to our support team
  • Feedback: Reviews, ratings, and feedback you provide

Technical Information

  • Device Information: Device type, operating system
  • Connection Data: IP address, timestamp of interactions
  • Error Logs: Technical logs for service improvement
3. How We Use Your Information

We use the collected information for the following purposes:

  • Service Provision: To provide and maintain our AI bot service
  • Personalization: To remember conversation context and preferences
  • Improvement: To analyze usage patterns and improve our service
  • Support: To respond to your inquiries and provide customer support
  • Security: To detect and prevent fraud, abuse, and security threats
  • Legal Compliance: To comply with legal obligations and enforce our terms
  • Analytics: To understand user behavior and optimize our service
4. Data Storage and Security

Security Measures

  • Encryption: All data is encrypted in transit and at rest
  • Access Controls: Strict access controls and authentication
  • Regular Audits: Security audits and vulnerability assessments
  • Secure Infrastructure: Industry-standard cloud security practices

Data Retention

  • Conversation Data: Stored for up to 90 days for context
  • Account Information: Retained while your account is active
  • Usage Analytics: Aggregated data retained for 2 years
  • Legal Requirements: Some data may be retained longer for legal compliance

Note: While we implement robust security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security but are committed to protecting your data.

5. Information Sharing and Disclosure

We Do NOT Sell Your Data

We do not sell, trade, or otherwise transfer your personal information to third parties for commercial purposes.

We may share your information only in the following limited circumstances:

  • Service Providers: With trusted third-party service providers who assist in operating our service
  • Legal Requirements: When required by law, court order, or government request
  • Safety Protection: To protect our rights, privacy, safety, or property
  • Business Transfers: In connection with a merger, acquisition, or asset sale
  • Consent: With your explicit consent for specific purposes

Any third parties we work with are bound by confidentiality agreements and are required to use appropriate security measures.

6. Your Rights and Choices

Your Data Rights

  • Access: Request access to your personal information
  • Correction: Request correction of inaccurate information
  • Deletion: Request deletion of your personal information
  • Portability: Request export of your data in a portable format
  • Restriction: Request restriction of processing your data
  • Objection: Object to certain types of processing

How to Exercise Your Rights

To exercise any of these rights, please contact us using the information provided in section 10. We will respond to your request within 30 days.

Note: Some rights may be limited by applicable law or legitimate business interests.

Account Deletion

You can delete your account at any time by contacting our support team. Upon deletion, we will remove your personal information within 30 days, except where retention is required by law.

7. Cookies and Tracking

Our service operates primarily through Telegram and does not use traditional web cookies. However, we may use similar technologies for:

  • Session Management: To maintain conversation context
  • Analytics: To understand usage patterns (anonymized)
  • Security: To detect and prevent abuse

If you access our web dashboard, we may use cookies as described in our Cookie Policy.

8. Third-Party Services

Our service integrates with the following third-party services:

  • Telegram: Our service operates on the Telegram platform
  • Cloud Infrastructure: We use secure cloud services for hosting
  • Payment Processors: For processing subscription payments
  • Analytics Tools: For understanding service usage (anonymized)

These third parties have their own privacy policies. We encourage you to review their policies as well.

9. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we make changes, we will:

  • Update the "Last updated" date at the top of this policy
  • Notify users of significant changes through our service
  • For material changes, provide advance notice when possible

Your continued use of our service after changes become effective constitutes acceptance of the updated policy.

10. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

Email: privacy@yourcompany.com

Data Protection Officer: dpo@yourcompany.com

Address: [Your Company Address]

Phone: [Your Company Phone]

We will respond to all inquiries within 30 days.

11. International Users

Our service is available globally. If you are located outside of [Your Jurisdiction], please note that:

  • Your information may be transferred to and processed in [Your Jurisdiction]
  • We comply with applicable international data protection laws
  • We provide appropriate safeguards for international transfers
  • You have the same rights regardless of your location
12. Children's Privacy

Age Restriction

Our service is not intended for children under the age of 13. We do not knowingly collect personal information from children under 13.

If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately. We will take steps to remove such information and terminate the child's account.

This privacy policy is effective as of 05/July/2025. By using our service, you acknowledge that you have read and understood this policy.