Effective Date: 25.04.25
Last Updated: 25.04.25

This Privacy Policy (hereinafter referred to as the "Policy") describes how GENZA, a Telegram Mini App developed by Genza Inc., a company incorporated in the State of Delaware, USA, collects, uses, stores, and discloses users' personal data.

1. GENERAL INFORMATION

1.1. The GENZA Mini App is operated by Genza Inc., registered in Delaware, USA. Contact: compliance@genza.io.
1.2. By using the App, the user consents to the terms of this Policy. If the user does not agree with the terms, they should refrain from using the App.
1.3. The App may process personal data as permitted by Telegram's technical infrastructure and its own additional features. Data processing complies with applicable laws, including the EU General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), where applicable.

1. TYPES OF PERSONAL DATA PROCESSED

2.1. During use of the App, we may process the following categories of data:
2.1.1. Telegram Data:

• Telegram ID, username, and display name;
• Profile photo;
• Interface language;
• Device type and operating system;
• Telegram Premium status;
• Telegram client theme settings.

2.1.2. Web3 Data:

• Blockchain address (TON/EVM);
• Token and NFT transaction history;
• Wallet identifiers;
• Participation in in-app economy.

2.1.3. Biometric Data:

• Facial image for 3D avatar generation (with consent);
• Avatar model linked to the user profile.

2.1.4. User Content and AI Data:

• Interactions with the AI pet bot;
• User-generated content (UGC);
• Logs of in-app activity.

2.1.5. Geolocation Data:

• City or region (only when voluntarily provided).

2.1.6. KYC and Payment Data:

• Name, date of birth, and identification documents processed through third-party providers (e.g., SumSub);
• Payment details (if applicable).

1. PURPOSES OF PROCESSING

3.1. Personal data is processed for the following purposes:

• Providing access to the App's functionality;
• User identification and verification;
• Legal compliance, including KYC/AML obligations;
• Executing transactions and delivering NFTs;
• Enhancing user experience, including AI services;
• Security and fraud prevention.

1. LEGAL BASES FOR PROCESSING

4.1. Data is processed based on:

• User consent (Art. 6(1)(a) GDPR);
• Necessity for the performance of a contract (Art. 6(1)(b) GDPR);
• Legal obligations (Art. 6(1)(c) GDPR);
• Legitimate interests (under CCPA, including service provision and security).

1. DATA RETENTION AND DELETION

5.1. Data is retained as follows:

• Telegram data – until the user deletes their account;
• Avatar photos – up to 24 hours;
• AI logs – up to 30 days;
• Blockchain addresses – up to 1 year after the last activity.

5.2. Users may request data deletion by contacting our DPO via in-app functionality or email: compliance@genza.io.

1. DATA SHARING WITH THIRD PARTIES

6.1. We may share data with:

• Telegram (as the host platform);
• Payment and KYC providers (e.g., SumSub);
• AI infrastructure providers (e.g., OpenAI, Azure);
• Unity Technologies (if Unity SDK is used).

6.2. All data transfers are governed by data processing agreements (DPAs) and comply with GDPR and CCPA.

1. USER RIGHTS

7.1. Users have the following rights:

• Right of access;
• Right to rectification;
• Right to erasure ("right to be forgotten");
• Right to restrict processing;
• Right to data portability;
• For California residents – right to opt out of the sale of personal data, right to know the categories of data collected, and right not to be discriminated against for exercising their rights under the CCPA.

7.2. To exercise any of these rights, contact us at: compliance@genza.io or through the App.

1. CHILDREN AND AGE RESTRICTIONS

8.1. The App is strictly intended for users aged 18 and over. Registration and use by individuals under 18 is prohibited.
8.2. We do not knowingly collect data from anyone under the age of 18. If such data is discovered, it will be promptly deleted.

1. CHANGES TO THE POLICY

9.1. We reserve the right to modify this Policy at any time. The current version is always available in the App interface.
Contact for privacy-related inquiries (DPO): compliance@genza.io