Kebijakan Privasi

The Application is operated by The Open Squad ("we", "us", "our").

For the purposes described in this Privacy Policy, we act as the data controller with respect to personal data for which we determine the purposes and means of processing.

This Privacy Policy applies to The Open Earn and, unless stated otherwise, to other applications, services, products, brands, or interfaces operated by The Open Squad that link to or reference this Privacy Policy.

References to the "Application" in this Policy may include all such services where applicable.

We may collect the following categories of personal data, to the extent relevant to the operation of the Application:

• Account Data – Telegram ID, username, profile image, account status, referral relationships, and related account-level identifiers.
• Technical Data – IP address, browser, device type, operating system, language, user agent, timestamps, session identifiers, and similar technical metadata.
• Usage Data – activity logs, feature interactions, ad views, clicks, task attempts, participation in promotional mechanics, referral activity, and general use patterns within the Application.
• Transaction Data – balance records, reward history, withdrawal requests, withdrawal logs, wallet addresses, wallet connection metadata, transaction identifiers, and transaction status.
• Support and Review Data – communications with support, submissions relating to disputes or verification, and records of reviews or decisions.
• Anti-Fraud and Risk Data – device and browser characteristics, session consistency signals, network and IP-based indicators, repeated activity patterns, wallet linkage indicators, referral anomalies, anomaly detection signals, and other data reasonably necessary to detect abuse, manipulation, fraud, multi-accounting, or security threats.

We do not intentionally collect sensitive personal data. If a User voluntarily provides sensitive data, they do so at their own discretion unless specifically requested and legally justified.

We process personal data as reasonably necessary to:

• operate and administer the Application;
• authenticate users and maintain account functionality;
• validate activity, task completion, and partner-required verification;
• manage rewards, balances, withdrawals, referrals, and promotional mechanics including The Wheel;
• deliver, attribute, measure, and optimize advertisements, offers, and tasks;
• detect, prevent, investigate, and enforce against fraud, abuse, manipulation, multi-accounting, policy violations, and security threats;
• monitor performance, analytics, stability, and service quality;
• enforce our Terms of Use and other policies;
• respond to lawful requests, comply with legal obligations, and protect our legal rights.

We may monitor IP addresses, device signals, wallet-related signals, technical identifiers, and behavioral patterns to detect suspicious or non-genuine activity.

Where applicable under relevant law, we process personal data on one or more of the following grounds:

• performance of a contract or steps taken at the User's request in connection with the operation of the Application;
• our legitimate interests, including fraud prevention, abuse detection, account integrity, security, analytics, service improvement, ad attribution, enforcement of our Terms, dispute handling, and protection of the Application, our partners, and other users;
• compliance with legal obligations;
• consent, but only where consent is specifically required by applicable law.

Where we rely on legitimate interests, such interests may include fraud prevention, abuse detection, ad attribution, service improvement, analytics, operational integrity, dispute handling, legal defense, and the protection of the Application, our users, and our partners.

Where consent is required by applicable law for particular processing activities, we will seek it in the appropriate manner.

We may use automated and semi-automated processing, including profiling-like techniques, behavioral analysis, technical fingerprinting, anomaly detection, and related systems, to:

• identify suspicious activity;
• validate or invalidate activity;
• assess abuse risk;
• enforce restrictions;
• review withdrawals;
• protect the integrity and lawful operation of the Application.

Such processing may result in: reward denial; reversal of credits; delayed withdrawals; account restriction; suspension; termination.

Where applicable law grants such rights, Users may request further review of certain decisions by contacting us. This does not guarantee reversal of any decision.

We do not sell personal data for money.

We may disclose personal data to:

• service providers and technical vendors – for infrastructure, diagnostics, support, and operational functionality;
• analytics providers – for service analytics, diagnostics, performance monitoring, and attribution;
• advertising partners, offer providers, and attribution partners – for task delivery, validation, attribution, anti-fraud checks, and performance measurement;
• Telegram, TON Connect, wallet providers, and other platform integration providers – for authentication, connection, transaction functionality, or platform integration;
• fraud-prevention, compliance, and security partners – to detect abuse, enforce restrictions, and protect systems, partners, and users;
• professional advisors, counterparties, and competent authorities – where reasonably necessary for compliance, legal claims, investigations, or lawful requests.

Depending on context, third parties may act as processors, service providers, independent controllers, or separate counterparties under their own terms and privacy policies.

Advertising and third-party partners may independently collect and process data under their own privacy policies. We are not responsible for third-party data practices outside our control.

Personal data may be processed, accessed, or stored in jurisdictions other than the User's own.

Where required by applicable law, we rely on appropriate safeguards, contractual measures, necessity for service operation, legitimate interests, or other lawful transfer mechanisms.

Cross-border processing may occur as an inherent part of providing Telegram-based, blockchain-related, advertising-supported, and partner-integrated services.

By using the Application, the User acknowledges that such cross-border processing may occur as part of the operation of the service.

We retain personal data for as long as reasonably necessary for the purposes described in this Privacy Policy, including:

• account administration and service delivery;
• fraud prevention and security;
• enforcement of our Terms;
• dispute handling and investigation;
• legal compliance;
• maintenance of suppression, block, or internal risk lists intended to prevent repeated abuse or re-registration.

Retention periods may vary depending on: the type of data; whether the account remains active; the sensitivity and risk profile associated with the data; the existence of a dispute, review, or legal obligation; whether ongoing retention is necessary for security, fraud prevention, compliance, or protection of the Application and its users.

Even after deletion requests, certain data may be retained where reasonably necessary to prevent re-registration, detect abuse, comply with law, defend legal claims, or enforce restrictions.

Depending on applicable law, Users may have rights to request:

• access to their personal data;
• correction of inaccurate data;
• deletion of certain data;
• restriction of certain processing;
• objection to certain processing;
• portability of certain data;
• review of certain automated decisions.

These rights are not absolute and may be limited where processing remains necessary for: fraud prevention; security; legal compliance; enforcement of our Terms; defense of legal claims; protection of the Application, our partners, or other users.

Requests may be denied where an exemption or lawful basis for refusal applies.

Where deletion is granted, the User's account may be permanently disabled.

We implement reasonable technical, organizational, and administrative measures designed to protect personal data.

However, no system can be guaranteed to be fully secure, and use of Telegram, blockchain systems, wallets, third-party tools, and internet-based services involves inherent risks.

Users are responsible for maintaining the security of their own: devices; Telegram accounts; wallets; access credentials; related environments.

To the maximum extent permitted by applicable law, we are not liable for unauthorized access, hacking, service compromise, data breaches, or loss of data beyond our reasonable control.

We may use: cookies or similar technologies where applicable; local storage; SDKs; attribution technologies; fingerprinting or fingerprint-like techniques; analytics tools; security technologies.

We use these technologies to operate the Application, measure performance, attribute tasks, detect abuse, enforce restrictions, and improve reliability, security, and functionality.

Where consent is required by applicable law for a particular technology or purpose, we will seek such consent in the appropriate manner.

Certain strictly necessary, security-related, or fraud-prevention technologies may operate without separate opt-in where permitted by law.

The Application may include third-party advertisements, links, offers, tasks, integrations, and external content.

We do not control and do not guarantee the legality, safety, accuracy, or privacy practices of third-party content or services.

Users interact with such third-party content at their own risk and should review applicable third-party terms and privacy policies where relevant.

We may update this Privacy Policy from time to time.

The updated version will become effective when published or otherwise communicated through the Application or associated channels.

Continued use of the Application after an update may constitute acknowledgment of the updated Policy, to the extent permitted by applicable law.

The Application is not intended for individuals under the age of 18.

We do not knowingly collect personal data from minors. If we become aware that personal data from a minor has been collected in violation of this Policy, we may delete it and restrict the associated account.

The Application is not intended for users located in jurisdictions where access to or use of the Application would be unlawful, restricted, or contrary to our internal compliance policies, including, without limitation, the United States and other Restricted Jurisdictions as determined by us from time to time.

By using the Application, the User represents and warrants that:

• they are not located in, resident of, or accessing the Application from any such jurisdiction;
• they are not acting on behalf of any person or entity whose access or use would be prohibited.

We reserve the right to restrict, suspend, or terminate access to the Application if we suspect a violation of this Section.

We are not responsible for any use of the Application in violation of applicable laws.

User data is obtained through Telegram APIs, Telegram authorization, and related official interfaces, and is limited to information made available through those interfaces or otherwise provided by the User in connection with use of the Application.

The Application does not access private messages, contacts, or other Telegram data not made available through Telegram's authorized interfaces.

Telegram acts as an independent controller with respect to its own processing activities. Users should refer to Telegram's own privacy materials for details regarding Telegram's data practices.

For privacy-related requests, contact: sales@theopensquad.com

We may request information reasonably necessary to verify identity, authority, and the scope of a request before responding.

Response times are not guaranteed.