Privacy policy

Who handles your data

The data controller is [COMPANY NAME], tax ID [TAX ID], registered at [REGISTERED ADDRESS]. For anything about your data, email [PRIVACY EMAIL].

This policy explains which data we process in chattwin and why. It applies to two groups of people:

• models: people who use the panel to create and set up their bot;
• fans: people who talk to a model's bot on Telegram.

Data we process about models

• Your Telegram account: the ID, name and username Telegram gives us when you log in. We don't receive your phone number or your password.
• Your profile: your stage name and your Sugarcams or VipRoom nicknames, and whether the team has approved your account.
• If you come from VipRoom through its chattwin button: VipRoom sends us your user ID there, your nickname, your public name, the Sugarcams nickname on your profile and your language. We use them to fill in your sign-up and to let the team know VipRoom confirms that profile is yours.
• Your bot: the bot's username and access key (stored encrypted), its profile photo and its description.
• Its personality: your questionnaire answers and their earlier versions.
• Your content: a reference to the photos and teasers you upload. The files stay on Telegram; we only keep their ID and whether they're marked for the bot.
• Your activity in the panel: your schedule, the messages you send to your fans, which legal texts you accepted and a log of settings changes.

Data we process about fans

• Your Telegram account: the ID, your display name and your app's language.
• The conversation: the last 60 messages of each conversation with the bot, and a few notes the bot remembers about you so the conversation makes sense. These notes never include phone numbers, addresses or payment details.
• Your alerts: whether you asked for live alerts and the model's messages, and when we sent them.
• Clicks on the button to enter the room, with the time and where they came from.
• A log of each message (who, when and in which direction) for statistics, without its content.

If you send the bot a photo, video, audio or file, we don't download or store it: we only note that it arrived.

What we use it for

• Providing the service: so the bot can chat, send approved content, give live alerts and take people to the room. Legal basis: the contract with the model and, for fans, our legitimate interest in handling the conversations they start.
• Verifying models and stopping anyone from impersonating someone else. Legal basis: legitimate interest and the contract.
• Sending alerts and messages to fans who asked for them. Legal basis: their consent, which they can withdraw with one button.
• Security: filtering abuse, stopping attempts to get around the limits and keeping an audit log. Legal basis: legitimate interest and legal obligations.
• Statistics for the model and for running the service. Legal basis: legitimate interest.

Artificial intelligence

To write each reply, we send the AI provider the bot's personality, the recent conversation and the fan's notes. Today that provider is xAI (Grok model). What it does with that data is governed by its terms as a data processor: [COMPLETE AFTER REVIEWING THE PROVIDER AGREEMENT].

Who else can see the data

• The model can read their fans' conversations with their bot and write in them after the fan is told.
• The chattwin team, only what's needed for support, account reviews and security.
• VipRoom, to show your bot's card on your profile: it can check whether your bot is active, its Telegram username and what it does. It never sees your conversations or your fans'.
• Providers that help us run the service: Telegram (messaging), xAI (artificial intelligence) and [HOSTING PROVIDER] (servers).

We don't sell your data or use it for third-party advertising.

Transfers outside the European Economic Area

Some providers (such as xAI) are in the United States. When data leaves the European Economic Area we do it with the safeguards the law requires, such as the European Commission's standard contractual clauses. [CONFIRM EACH PROVIDER'S SAFEGUARD]

How long we keep it

• Conversations keep only the last 60 messages; older ones are deleted automatically.
• A model's account data is kept while the account is active and for [PERIOD] after it's closed.
• A fan's data is kept while they keep talking to the bot and for [PERIOD] after their last message.
• The audit log is kept for [PERIOD] so we can respond to any claim.

Your rights

You can ask us to access, correct, delete, restrict, object to or export your data by emailing [PRIVACY EMAIL]. If you're a fan, you can also stop alerts at any time with the bot's button, or block it on Telegram.

If you think we haven't handled your data properly, you can complain to your data protection authority (in Spain, the AEPD: aepd.es).

Cookies

The panel only uses technical cookies it needs to work: your session, the language you choose, the light or dark theme and, if you come from VipRoom, one that remembers for an hour what VipRoom told us so we can fill in your sign-up. We don't use advertising or tracking cookies.

Security

We store the bots' access keys encrypted, only let people into the panel when they log in with their Telegram, and log important changes. No system is foolproof, but if something serious affected your data, we would tell you as the law requires.

Minors

chattwin is only for people aged 18 and over. If we learn that a minor has talked to a bot, we will delete their data.

Changes to this policy

If we change anything important, we publish a new version. Models are asked to accept it the next time they open the panel.