BONKbot | Terms of Use

Privacy Policy of Telemetry

Last updated: July 2, 2025

Notice at Collection (California users): Please see our Notice at Collection below for a high-level overview of our privacy practices.

Scope of this Policy

This Privacy Policy describes how Triple Spice AG (“Company”, “we,” “us,” or “our”) handles personal information when you use any of the following (collectively, the “Services”):

The BONKbot Telegram bot

The Telemetry web terminal and any future mobile or desktop applications that link to this Privacy Policy
Our websites, dashboards, documentation pages and social media channels that link to this Privacy Policy
Our marketing communications and user-support interactions.

In addition, we may inform you about the processing of your personal data separately, for example in consent forms, terms and conditions, additional privacy notices, forms, and other notices. We use the words “personal information” and “data” here interchangeably with “personal data”.

2. Controller or Business

The responsible person for processing your data under this Privacy Policy (“Controller” or “Business” under CCPA) unless we tell you otherwise in an individual case is:

Triple Spice AG

c/o Wadsack Zug AG, Bahnhofstrasse 7, 6300 Zug. You may contact us regarding data protection matters and to exercise your rights at privacy@bonkbot.io.

3. Personal Information We Collect

Information we collect directly from you:

Account and contact data, such as your Telegram handle and ID, email address (if provided), preferred language, marketing preferences.
Wallet address and public blockchain data, such as public Solana wallet address(es) you link to the bot and transaction records.
Feedback or correspondence, such as information you provide when you report a problem with the Services, share feedback, or otherwise correspond with us.
Marketing information, such as your preferences for receiving marketing communications and details about how you engage with marketing communications

Information we obtain from third parties:

Our Services include interfaces that allow you to connect with third parties, such as when you create an account on the Telemetry web terminal by logging in to your Phantom account. If you connect to a third party site through our Services, you authorize us to access, use and store the information that you agreed the third party site could provide to us based on your settings on that third party site. We will access, use and store that information in accordance with this Privacy Policy. You can revoke our access to the information you provide in this way at any time by amending the appropriate settings from within your account settings on the applicable third party site. Please note that we have no control over, do not review and cannot be responsible for third-party sites and that the terms of this Privacy Policy do not apply to these third-party sites. We encourage you to read the privacy notices of every third-party site you visit/third-party Services you use.

Automatic data collection.

We and our service providers may automatically log information about you, your computer or mobile device, and your interactions over time with our website, web terminal, Telegram bot and our communications, such as:

Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 4G), and general location information such as city, state or geographic area.
Usage data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.

We use the following tools for automatic data collection:

Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand website user activity and patterns. For example, Google Analytics collects information about how users use our website, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our website. For more information on Google Analytics, click here.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
Session replay technologies. We use third-party tools that use cookies and similar technologies to record how users interact with our Services. These tools may capture your clicks, mouse movements, scrolling behavior, keystrokes (such as text you enter), and time spent on each page. We use session replays to understand how people use our Services, identify technical or usability issues, and improve or develop new features.

4. How We Use Personal Information

Provide and operate the Services. To conclude, execute and manage a contract with realyou and provide our services to you, in particular to create and secure your wallet, route and settle your requested swaps of digital assets, display your real-time portfolio, and allow you to process withdrawals.
User support and communications. To respond to requests, troubleshoot failed transactions, and send security alerts, support and other administrative messages.
For research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We may use this data and disclose it to third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.
Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, newsletters, and updates on news and events. You may opt out of our marketing emails as described in the “Opt out of marketing communications” section below.
Compliance and protection. We may use personal information to comply with legal obligations, and to defend our company against legal claims or disputes, including to:
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
- Audit our internal processes for compliance with legal and contractual requirements and internal policies.
- Enforce the terms and conditions that govern our Services.
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

5. Legal Basis for Data Processing

Insofar as we have asked for your consent, we process your data on the basis of this consent. You can withdraw your consent at any time with effect for the future by sending us a written notification (email to: privacy@bonkbot.io ). The withdrawal of your consent affects neither the legality of the processing that we carried out before your withdrawal nor the processing of your data on the basis of other processing grounds.

If we do not need your consent under applicable law, we will not obtain it and we will process your data for other reasons, such as the initiation/execution of a contract or a business relationship with you, a legal obligation, a vital interest of the data subject or another natural person, or to perform a public task. We may also process your personal data if we have a legitimate interest in doing so, which includes, for example, complying with applicable law and marketing our products and services, the interest in better understanding our markets and in safely and efficiently managing and developing our company, including its activities.

6. How We Disclose Personal Information

Service providers. We may disclose your personal information to third party companies and individuals that provide services on our behalf or help us operate our Services (such as lawyers, bankers, auditors, insurers, user support, hosting, analytics, email delivery, marketing, and database management).
Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transfers. We may sell, transfer or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.
Other third parties, where applicable, at your direction or with your consent.

7. Disclosure of Data Abroad

The data that we collect from you may be transferred to, processed, and stored in, a country outside the European Economic Area (EEA) or Switzerland. In view of the EEA or Switzerland the law in some of those countries may not offer an adequate level of data protection. We only transfer data to these countries when it is necessary for the performance of a contract or for the exercise or defense of legal claims, or if such transfer is based on your explicit consent or subject to safeguards that assure the protection of your data, such as the EU-US Data Privacy Framework, the Swiss-US Data Privacy Framework and/or the Standard Contractual Clauses approved by the European Commission (SCCs), adjusted according to Swiss law, all of the aforementioned if applicable and required.

8. On-Chain Data

By utilizing blockchain technology, you acknowledge that your wallet address and other da-ta/information provided by your transactions, which are considered personal data if relating to an identified or identifiable natural person, are permanently and publicly stored on-chain, which means such data is publicly available to anyone. Neither we, nor any third party, may have any power to alter or delete such data published by its users to the blockchain. If you want to ensure that your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be available or exercisable by you or us due to the technological infrastructure of the blockchain.

You hereby release and indemnify us of any liability associated with data that you transferred to the blockchain.

9. Retention and Storage of Data

We only process your data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of complying with legal retention requirements and where required to assert or defend against legal claims, until the end of the relevant retention period or until the claims in question have been settled. Upon expiry of the applicable retention period, we will securely destroy your data in accordance with applicable laws and regulations.

10. Your Privacy Rights And Choices

Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into the account.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions contained in the marketing communication we send you. You may continue to receive service-related and other non-marketing emails.
Personal information requests. As a user, you may request the following in relation to the personal information we hold about you:
- Information about how we have collected and used your personal information.
- Right to data portability: you may have a right to receive to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily-usable format.
- Restriction of processing or correction of personal information that is inaccurate or out of date.
- Deletion of the personal information that we maintain about you.
- Opt out of the sale of your information or sharing of your information for interest-based advertising. We do not engage in the sale of your personal information, or the sharing of your personal information for such purposes.
- Opt out of “profiling” in connection with decisions that produce legal or similarly significant effects. We do not engage in profiling in connection with decisions that produce legal or similarly significant effects.
- Withdrawal of your consent insofar as we rely on consent as the lawful basis on which we process your personal data.
- Appeal our denial of your personal information request by contacting us as set out in the “How To Contact Us” section below. You also have the right to lodge a complaint with a competent data protection supervisory authority.

To make a request, please email or write to us as provided in the “How to Contact Us” section below. Prior to responding to your requests, we may verify your identity by matching any requested identifying information you provide against the information we have about you. Depending on your jurisdiction, you may designate an authorized agent to make a request on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “How to Contact Us” section below.

Limit online tracking. There are a number of ways to limit online tracking, which we have summarized below. Please note that these tools are not associated with us and we cannot guarantee that they work as their providers advertise them:

Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/.
Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

11. Other sites, mobile applications and services

Through our Services you may find links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use and disclosure of your personal information. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

12. Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

13. Minimum age

Our Services are not intended for use by individuals under the age of majority in their jurisdiction of residence. If we learn that we have collected personal information through the website from an individual that is not at least the age of majority in their jurisdiction of residence without the consent of a parent or guardian as required by law, we will delete it.

14. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website.

15. How to Contact Us

Please direct any questions or comments about this Privacy Policy or our privacy practices to privacy@bonkbot.io.

California Notice at Collection*

While you should read the Privacy Policy in its entirety, the following summarizes our practices currently and during the past 12 months regarding the categories of personal information that we collect and how we use them. We retain your personal information as described in the “Data Retention” section of our Privacy Policy.

*As described further in our Privacy Policy, we may disclose all categories of personal information to our service providers for the purposes described in the Privacy Policy. We also may disclose personal information to authorities and others for legal and compliance purposes, and business transferees in the context of an acquisition or the sale of our business or another corporate transaction.