1. General Provisions
- This Policy defines the procedure for processing and protecting the personal data of Crypti Trader users.
- The operator is Matvey Yurievich Pogodayev, individual entrepreneur (self-employed), TIN 540131808961.
- The Policy is developed in accordance with Federal Law No. 152-FZ "On Personal Data".
- Use of the Service constitutes consent to the processing of personal data under the terms of this Policy.
2. Data We Collect
We collect three types of data:
- Provided by the user: Telegram ID, username, email, first and last name, avatar.
- Collected automatically: IP address, browser type, operating system, device, cookies, dates and actions performed.
- Received from third parties: portfolio data from exchanges (Bybit, OKX) via read-only API; data from OAuth providers (Yandex, Google, VK, Telegram).
3. Purposes of Processing
- Providing access to Service features and account management.
- Portfolio synchronization and display.
- Personalized AI analytics.
- Notifications about signals and updates.
- Improving the quality of the Service.
- Compliance with legal requirements (tax reporting).
4. Legal Grounds
- Consent of the data subject (Clause 1, Part 1, Article 6 of FZ-152).
- Performance of a contract to which the user is a party (Clause 5, Part 1, Article 6 of FZ-152).
- Compliance with legal obligations (Clause 2, Part 1, Article 6 of FZ-152).
5. Storage and Protection
- Servers are located in the Russian Federation (Timeweb, Saint Petersburg) in accordance with Part 5, Article 18 of FZ-152.
- AES-256-GCM encryption is used for API keys, HTTPS/TLS for data transmission, and access is restricted.
- Retention period: the entire period of Service use plus 5 years after account deletion (tax law requirement).
6. Transfer to Third Parties
We do not sell or disclose personal data, except in the following cases:
- User consent has been obtained.
- Required by law or authorized government agencies.
- Necessary for service delivery (payment services, hosting, notifications).
7. Cross-Border Transfer
Data may be transferred to the following services with user consent and with appropriate protection measures (Article 12 of FZ-152):
- Telegram (servers outside the Russian Federation).
- Bybit and OKX exchanges (servers outside the Russian Federation).
- AI model providers (servers outside the Russian Federation).
- OAuth providers (Google, VK, Yandex).
8. Cookies
Cookies are used for:
- Authentication and session maintenance.
- Saving user preferences.
- Service usage analytics.
- Cookies can be disabled in browser settings, but this will affect Service functionality.
9. User Rights
The user has the right to:
- Obtain information about the processing of their personal data.
- Demand clarification, blocking, or deletion of inaccurate or unlawfully processed data.
- Withdraw consent to data processing.
- Delete their account and all associated data.
- File a complaint with Roskomnadzor.
- Send requests to pogoda.matvey@gmail.com — review period is 30 days.
10. Changes to the Policy
The operator has the right to make changes to this Policy. The new version takes effect from the moment it is published on the website.
11. Contacts
Matvey Yurievich Pogodayev, TIN 540131808961, pogoda.matvey@gmail.com, @pogodaevDev, cryptitrader.ru