Privacy Policy
Last Revised: May 2025
1. Introduction
This Privacy Policy explains how Alpoca Ltd. ("Company," "we," or "us") collects, uses, and protects personal data in relation to its Services provided under the Torch Finance brand, including the tgUSD Telegram miniapp and Web App. By using the Services, you agree to the terms of this Privacy Policy.
2. Information We Collect
We collect the following types of information:
Information you voluntarily provide (e.g., email when contacting us or filling forms)
Device and usage information (e.g., browser type, IP address, access times)
On-chain data observable on public blockchains (e.g., wallet addresses, transaction history)
Information from third parties (e.g., analytics tools, social integrations)
3. How We Use Your Information
We may use your information to:
Provide, operate, and maintain the Services
Improve and personalize the user experience
Communicate with you, including sending service updates and responses
Comply with legal obligations
4. Sharing of Information
We do not sell your personal data. We may share your data with:
Service providers that help us operate the platform (e.g., hosting, analytics)
Law enforcement or regulators when legally required
Third parties with your consent or as part of a business transfer
5. Blockchain Transparency
Due to the nature of public blockchains, your transactions, balances, and wallet addresses are publicly visible. We do not control and cannot erase this data.
6. Wallets
The Company does not store your wallet private keys or seed phrases. You are solely responsible for safeguarding your wallet credentials.
7. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected or to comply with legal, regulatory, or internal policy requirements.
8. Data Security
We implement reasonable technical and organizational safeguards to protect your data from unauthorized access, use, or disclosure.
9. Your Rights
Depending on your jurisdiction, you may have the right to:
Access the personal data we hold about you
Request correction or deletion of your data
Object to or restrict processing
Data portability
Please contact us at [email protected] to exercise any of these rights.
10. Children’s Privacy
Our Services are not intended for children under the age of 13, and we do not knowingly collect personal data from them.
11. International Transfers
Your information may be transferred and processed in countries outside your country of residence, including jurisdictions that may not have equivalent data protection laws.
12. Changes to This Policy
We may update this Privacy Policy from time to time. Any material changes will be posted on https://doc.torch.finance/telegram-usd with a revised effective date.
13. Contact Us
If you have any questions or concerns about this Privacy Policy, please contact us at: [email protected]
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