Privacy Policy

Application: LiveSuperBot (iOS and Android) · Website: https://livesuperbot.com · Telegram Bot: LiveSuperBot

Version: 1.0 – Effective Date: [PUBLICATION DATE]

Pursuant to Regulation (EU) 2016/679 (GDPR) and applicable personal data protection legislation. This privacy policy concerns the LiveSuperBot mobile app, the app.livesuperbot.com website, and the connection with the Telegram Bot.

1. Data Controller

The Data Controller for personal data collected through the LiveSuperBot app is WAYKU SL, the entity managing the LiveSuperBot Service (hereinafter the "Manager"). To exercise the rights referred to in point 9 or for any matter relating to your personal data, you can contact the Controller via the support page, the website https://livesuperbot.com, or the Telegram Bot.

2. Data Collected and Purposes of Processing

2.1 Account Data

When you create an account or log in to the app, the Service processes, depending on the method you choose:

• Email address and password, if you register with email. The password is stored only in encrypted form (hash) and is not readable by the Manager.
• Apple or Google identifier (and the associated email, which with Sign in with Apple may be the private address provided by Apple), if you log in with Apple or Google.
• Telegram ID, public profile first name, last name, and username, if you log in with Telegram or link your Telegram account.
• An internal user identifier assigned by the app and the chosen language.

This data is used exclusively to identify you within the Service, manage the Credit balance associated with the account, provide technical support, and send service communications (confirmations, password recovery, updates, system notifications).

2.2 Push Notifications and Device Data

If you enable notifications, the app records your device's notification token, the platform (iOS or Android), the app version, and the operating system version. The token is provided by Apple (APNs) or Google (FCM) and is used solely to deliver Service signals and notifications to you. You can disable notifications at any time from your device settings.

2.3 Transaction Data

Purchases of Credit Packs within the app are processed by Apple (App Store) or Google (Google Play). The Manager exclusively receives and retains:

• The transaction reference provided by the store and the product purchased.
• The Credits credited and, if applicable, the status of a refund.
• The date and time of the transaction.

The Manager DOES NOT collect, DOES NOT store, and DOES NOT have access to user payment data (card numbers, bank details, etc.), which remain with Apple or Google. If you purchase via the Telegram Bot, the rules of the Payment Providers indicated in the website's privacy policy apply.

2.4 Usage and Diagnostics Data

The Service automatically collects data related to app usage:

• Credit balance and transaction history.
• Technical events and error diagnostics, used to identify and correct malfunctions.
• Technical server logs, which include the IP address of the request. During registration, the IP address is also stored in hashed form, to prevent abuse and multiple registrations.

2.5 Referral Program

If you use the referral program, the Service processes your invitation code, connections with invited users, accrued earnings, and, if you request a withdrawal, the PayPal address you provide.

2.6 Data Not Collected

The LiveSuperBot app DOES NOT collect:

• Geolocation data.
• Address book, photos, files, or other device content.
• Phone numbers.
• Biometric data.
• Data relating to special categories pursuant to art. 9 GDPR.

The app does not contain advertising SDKs and does not track you across apps and websites of other parties.

3. Legal Basis for Processing

• Performance of a contract (art. 6, par. 1, lett. b GDPR): processing necessary to provide the Service requested by the user.
• Legitimate interest (art. 6, par. 1, lett. f GDPR): technical monitoring of the Service, prevention of abuse and fraud.
• Legal obligations (art. 6, par. 1, lett. c GDPR): fulfillment of accounting and tax obligations related to commercial transactions.
• Consent (art. 6, par. 1, lett. a GDPR): for push notifications and for promotional or marketing communications, subject to obtaining the user's explicit consent.

4. Data Retention

• Account data and usage data: retained for the entire duration of the active account and for a maximum period of 12 months from deactivation or prolonged account inactivity.
• Account deletion: if you delete the account from the app, we immediately delete email, password, Apple and Google identifiers, and notification tokens. We only retain necessary accounting data (Credit movements and purchases), devoid of direct references to your identity.
• Transaction data: retained for 10 years from the date of the transaction, in accordance with legal accounting and tax obligations.
• Technical logs: retained for a maximum of 6 months.

Data is deleted or anonymized at the end of the retention period, unless otherwise required by applicable law.

5. Data Disclosure and Sharing

User personal data is NOT sold or transferred to third parties for commercial or profiling purposes. Data may be shared exclusively with:

• Apple and Google: for processing in-app purchases, for logging in with Apple or Google, and for delivering push notifications.
• Telegram: if you use the Telegram Bot or link your Telegram account.
• Payment Providers (Stripe, PayPal): for transactions made via the Telegram Bot and for referral program withdrawals.
• Email service providers (Brevo): for sending service emails, such as address confirmation and password recovery.
• Technology infrastructure providers: servers and cloud services used for the provision of the Service.
• Competent authorities: in case of a legal obligation or a judicial authority order.

6. International Data Transfer

Some providers (e.g., Apple, Google, Stripe, PayPal) may process data outside the European Economic Area (EEA). In such cases, the transfer occurs in accordance with the safeguards provided by the GDPR (art. 46), including the Standard Contractual Clauses approved by the European Commission.

7. Data Security

The Manager adopts appropriate technical and organizational measures to protect users' personal data, including:

• Encrypted communications via HTTPS/TLS protocol.
• Passwords stored only in encrypted form (hash) and sessions protected by revocable tokens.
• Access to data limited to authorized personnel.
• Continuous system monitoring for anomaly detection.
• Regular updates of security systems.

8. Cookies and Tracking Technologies

The app does not use cookies. The app.livesuperbot.com website may only use essential technical cookies for the proper functioning of the pages. No third-party profiling or marketing cookies are used without the user's prior consent.

9. Data Subject Rights

In accordance with the GDPR, the user has the right to:

• Access (art. 15): obtain confirmation of processing and a copy of personal data.
• Rectification (art. 16): request the correction of inaccurate or incomplete data.
• Erasure (art. 17): request the deletion of data ("right to be forgotten"). You can delete your account directly from the app, or from the Delete your account page.
• Restriction of processing (art. 18): request the restriction of processing in certain circumstances.
• Data portability (art. 20): receive your data in a structured, commonly used, and machine-readable format.
• Objection (art. 21): object to processing based on legitimate interest.
• Withdrawal of consent: withdraw consent given at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise your rights, you can contact the Controller via the support page, the website https://livesuperbot.com, or the Telegram Bot. The Manager will respond within 30 days of receiving the request. You also have the right to lodge a complaint with the competent supervisory authority for personal data protection.

10. Minors

The Service is not intended for individuals under 18 years of age. The Manager does not knowingly collect personal data from minors.

11. Changes to this Privacy Policy

The Manager reserves the right to modify this Privacy Policy at any time. Changes will be communicated via the app, the website, and/or the Telegram Bot.

12. Contacts

Support page: Support · Website: https://livesuperbot.com · Telegram Bot: LiveSuperBot